AQ-2022-004-RULE330 REPORT TO THE BOARD OF SUPERVISORS.PDF

Air Quality Department 
301 W. Jefferson St., Suite 410  
Phoenix, Arizona 85003 
 
P: 602-506-6010 
E: AQMail@maricopa.gov 
 
 
 
 
 
 
 
 
 
 
 
 
 
Enhanced Regulatory Outreach Program 
Maricopa County Air Quality Department 
Notice of Public Hearing 
Subject:  
 
Rule 330 (Volatile Organic Compounds) 
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 330 (Volatile Organic Compounds). 
 
You may comment on the proposed rule using the Enhanced Regulatory Outreach Program 
(EROP)  online comment form. 
 
AQ-2022-004-Rule 330 (Volatile Organic Compounds) 
 
The Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 330 to  
clarify the applicability of the rule and update and restructure the rule. Proposed revisions  
include the addition of an applicability section, revising the VOC emission limits from daily 
limits to an annual limit, adding standardized operation and maintenance (O&M) plan 
language, and adding standardized compliance schedule language. 
 
Members of the public may attend the Board meetings in person or view the meetings 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. In addition, a copy of the Report to the Board of Supervisors 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-2022-004-Rule 330 (Volatile Organic Compounds) 
Agenda Item:  
(Pending) 
Supervisor Districts: 
All Districts 
The Maricopa County Air Quality Department (MCAQD) complied with all statutory and county 
policies throughout this rulemaking process. Per the Enhanced Regulatory Outreach Program 
(EROP) Policy: “In addition to the required staff report, an executive summary of the report 
including an overview of stakeholder input and staff responses will be provided to the Board 
of Supervisors at least one week prior to any Board of Supervisors’ public hearing.” 
Overview of the Report to the Board of Supervisors: 
The purpose of Rule 330 (Volatile Organic Compounds) is to limit volatile organic compound 
(VOC) emissions from the use of organic solvents or processes that emit volatile organic 
compounds. The last significant revision to the rule occurred in 1996. MCAQD is proposing to 
revise Rule 330 to clarify the applicability of the rule and update and restructure the rule. 
MCAQD is proposing to clarify the rule applicability. Proposed revisions are designed to 
clarify Rule 330 is a catchall rule that regulates VOC emitting operations not regulated under a 
source-specific rule in the Maricopa County Air Pollution Control Regulations (MCAPCR). In 
the event none of the source-specific rules regulating VOCs in the MCAPCR apply to a source, 
Rule 330 will be used to regulate the source’s VOC emissions. 
Further clarification to the rule applicability includes removing the regulation of solvents from 
the rule as they are more appropriately regulated under Rule 331 (Solvent Cleaning). Proposed 
revisions related to the removal of solvent regulation include revisions to the purpose, 
removal of some definitions, and revisions to the standards and recordkeeping sections.

In addition, MCAQD is proposing to restructure the rule to ensure consistency within the 
MCAPCR. Proposed revisions include revising the VOC emission limits from daily limits to an 
annual limit, adding standardized operation and maintenance (O&M) plan language, and 
adding compliance schedule language. 
Overview of Stakeholder Input and Staff Responses: 
MCAQD received written feedback from five (5) stakeholders. Two (2) stakeholders 
expressed opposition and three (3) 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 106

Maricopa County 
Air Quality Department 
Planning and Analysis Division 
Report to the 
Board of 
Supervisors 
Rule 330 (Volatile 
Organic Compounds)
September 2024

Board of Health Meeting Date: 
July 22, 2024 
Board Hearing Date: 
Case Number/Title:  
Agenda Item: 
Supervisor Districts: 
Applicant:  
Request: 
Support/Opposition: 
September 25, 2024 
AQ-2022-004-Rule 330 (Volatile Organic Compounds) 
(Pending) 
All Districts 
Staff 
Approve revision of Maricopa County Air Pollution Control 
Regulations, Rule 330 (Volatile Organic Compounds). 
The purpose of Rule 330 is to limit volatile organic 
compound (VOC) emissions from the use of organic 
solvents or processes that emit volatile organic compounds. 
The last significant revision to the rule occurred in 1996. 
MCAQD is proposing to revise Rule 330 to clarify the 
applicability of the rule and update and restructure the rule. 
MCAQD is proposing to clarify the rule applicability. 
Proposed revisions are designed to clarify Rule 330 is a 
catchall rule that regulates VOC emitting operations not 
regulated under a source-specific rule in the Maricopa 
County Air Pollution Control Regulations (MCAPCR). In the 
event none of the source-specific rules regulating VOCs in 
the MCAPCR apply to a source, Rule 330 will be used to 
regulate the source’s VOC emissions. 
Further clarification to the rule applicability includes 
removing the regulation of solvents from the rule as they are 
more appropriately regulated under Rule 331 (Solvent 
Cleaning). Proposed revisions related to the removal of 
solvent regulation include revisions to the purpose, removal 
of some definitions, and revisions to the standards and 
recordkeeping sections. 
In addition, MCAQD is proposing to restructure the rule to 
ensure consistency within the MCAPCR. Proposed revisions 
include revising the VOC emission limits from daily limits to 
an annual limit, adding standardized operation and 
maintenance (O&M) plan language, and adding compliance 
schedule language. 
During the rulemaking process, MCAQD has received written 
feedback from five (5) stakeholders. Three (3) stakeholders 
expressed neither support nor opposition for the proposed 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
4 of 106

changes and two (2) stakeholders expressed opposition to 
the proposed changes. 
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 April 2022. 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 
330. 
A newspaper notice of the Board of Supervisors public 
hearing will be published in the Arizona Business Gazette on 
August 22, 2024, and August 29, 2024. This regulatory 
change will take effect immediately upon approval by the 
Board of Supervisors. 
Presented By: 
Philip A. McNeely, R.G., Director 
Prepared By: 
Planning and Analysis Division 
Attachments: 
Preamble required by Arizona Revised Statutes (A.R.S.) § 
49-471.07 (See the Draft Notice of Final Rulemaking)
Summary of the proposed regulatory change (See Item 4 of 
the Draft Notice of Final Rulemaking) 
Analysis of input received during the process and how that 
input was responded to (See Item 9 of the Draft Notice of 
Final Rulemaking) 
Language of proposed regulatory change or amendment 
(See the Draft Notice of Final Rulemaking) 
Strikethrough/underline of Draft Rule 330 
Clean version of Draft Rule 330 
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 
5 of 106

Maricopa County 
Air Quality Department 
Planning and Analysis Division 
Draft Notice 
of Final 
Rulemaking 
Rule 330 
(Volatile Organic 
Compounds)
September 2024

Draft Notice of Final Rulemaking 
Maricopa County Air Pollution Control Regulations 
Regulation III – Control of Air Contaminants 
Rule 330 (Volatile Organic Compounds) 
The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 330 (Volatile 
Organic Compounds). 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 Statute (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:  
April 6, 2022
Return to list of attachments
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
7 of 106

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 330 (Volatile Organic Compounds) is to limit volatile organic 
compound (VOC) emissions from the use of organic solvents or processes that emit 
volatile organic compounds. The last significant revision to the rule occurred in 1996. 
MCAQD is proposing to revise Rule 330 to clarify the applicability of the rule and update 
and restructure the rule.
MCAQD is proposing to clarify the rule applicability. Proposed revisions are designed to 
clarify Rule 330 is a catchall rule that regulates VOC emitting operations not regulated 
under a source-specific rule in the Maricopa County Air Pollution Control Regulations 
(MCAPCR). In the event none of the source-specific rules regulating VOCs in the 
MCAPCR apply to a source, Rule 330 will be used to regulate the source’s VOC 
emissions.
Further clarification to the rule applicability includes removing the regulation of solvents 
from the rule as they are more appropriately regulated under Rule 331 (Solvent 
Cleaning). Proposed revisions related to the removal of solvent regulation include 
revisions to the purpose, removal of some definitions, and revisions to the standards 
and recordkeeping sections.
In addition, MCAQD is proposing to restructure the rule to ensure consistency within the 
MCAPCR. Proposed revisions include revising the VOC emission limits from daily limits 
to an annual limit, adding standardized operation and maintenance (O&M) plan 
language, and adding compliance schedule language.
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)).
Return to list of attachments
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
8 of 106

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)):
This rulemaking is proposing to revise Rule 330. 
(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 330 to make the rule applicability broader.
Proposed revisions are designed to make Rule 330 a catchall rule that can regulate
VOC emitting operations not regulated under a source-specific rule. In the event
none of the source-specific rules regulating VOCs in the MCAPCR apply to a source,
Rule 330 will be used to regulate the source’s VOC emissions.
(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)).
Currently, Rule 330 includes daily emission limitations for activities such as
operations involving heat and solvent cleaning. MCAQD is proposing to revise Rule
330 to change the daily emission limit to an annual emission limit. The requirement
to maintain daily emission calculations can be burdensome on businesses and does
not reflect similar emission limitations in other recently revised rules. The daily
emission limitation on operations involving heat is proposed to be removed due to
the activity being limited in applicability. Furthermore, language pertaining to solvent
cleaning is proposed to be removed due to Rule 331 (Solvent Cleaning) being the
more appropriate rule to regulate the activity. If Rule 330 is not revised, the
applicability of the rule will continue to create confusion amongst the regulated
community.
(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 330 to make the rule applicability broader. In the
event a specialized industry that emits VOCs is not captured under another source-
specific rule of the MCAPCR, Rule 330 can be used to regulate the VOC emissions.
A brief summary of the information included in the economic, small business and 
consumer impact statement (A.R.S. § 41-1055(A)(2)). 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
9 of 106

The proposed revisions to Rule 330 will enhance the rule by removing provisions that 
are either outdated or more appropriately regulated in other source-specific rules of the 
MCAPCR. Additionally, the rule is proposed to be updated to align with other recently 
revised rules. Examples include replacing daily emission limits with an annual emission 
limit and adding standardized O&M Plan recordkeeping requirements.  
This rulemaking is anticipated to have an overall positive impact on the regulated 
community by updating standards that are incorporated into other recently revised rules 
to maintain consistency. The proposed revisions are expected to provide clarity to 
business owners by creating a clear understanding of Rule 330 applicability and 
requirements.  
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 equipment, 
materials, and/or substances that emit VOCs which are not regulated under 
requirements and standards in other source-specific rules of the MCAPCR and are 
not exempt as detailed in Section 103 of the draft rule. Examples of affected facility 
types include cannabis oil extraction, chemical processing and manufacturing, 
industrial laundry, polyester resin usage, and tire retreading.
(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)).
A cost benefit analysis of the following:
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
10 of 106

This rulemaking should not impose any new costs on MCAQD or on any other 
agencies affected by the proposed rulemaking. The rulemaking should benefit 
MCAQD by clarifying the applicability of the rule and restructuring the rule to ensure 
consistency within the MCAPCR. 
(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)).
This rulemaking does not impose any significant new compliance burdens on 
permitted sources or introduce additional regulatory requirements. Therefore, 
MCAQD does not anticipate this rulemaking will have an economic impact on any 
businesses. 
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 equipment, materials, and/or substances that emit VOCs which are not
regulated under requirements and standards in other source-specific rules of the
MCAPCR and are not exempt as detailed in Section 103 of the draft rule.
(b) The administrative and other costs required for compliance with the proposed
rulemaking (A.R.S. § 41-1055(B)(5)(b)).
This rulemaking does not impose any significant new compliance burdens on
permitted sources or introduce additional regulatory requirements. Therefore,
MCAQD does not anticipate this rulemaking will have an economic impact on any
businesses.
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
11 of 106

(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)). 
This rulemaking does not impose any significant new compliance requirements 
on small businesses and does not establish any significant new reporting 
requirements for small businesses. 
ii. Establish less stringent schedules or deadlines in the rule for compliance or 
reporting requirements for small businesses (A.R.S. § 41-1035(2)). 
This rulemaking does not impose any significant new compliance requirements 
on small businesses and does not establish any significant new reporting 
requirements for small businesses. 
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 is unlikely to impose any new design or operational 
requirements on small businesses. Any design or operational changes that would 
result from rulemaking would be minimal, such as operational requirements for 
handling, disposal, and storage of VOC-containing material.   
v. Exempt small businesses from any or all requirements of the rule (A.R.S. § 41-
1035(5)). 
This rulemaking contains exemptions as outlined in Section 103 of the draft rule. 
(d) The probable cost and benefit to private persons and consumers who are directly 
affected by the proposed rulemaking (A.R.S. § 41-1055(B)(5)(d)). 
This rulemaking should not result in any significant costs for private persons and 
consumers. 
A statement of the probable effect on state revenues (A.R.S. § 41-1055(B)(6)). 
The rulemaking will not impose increased monetary or regulatory costs on other state 
agencies, political subdivisions of this state, persons, or individuals so regulated. 
Without costs to pass through to customers, there is no projected change in consumer 
purchase patterns and, thus, no impact on state revenues from sales taxes. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
12 of 106

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)). 
MCAQD is not aware of any less intrusive or costly methods to achieve the purpose of 
this rulemaking. 
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 
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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
13 of 106

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). This rulemaking is not 
making the rule more stringent. 
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: 
 
 
May 4, 2022  
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 
(b) The following discussion addresses each of the elements required for a concise 
explanatory statement, as prescribed by A.R.S. § 49-471.07(B): 
i. 
A description of any change between the proposed rule or ordinance, the final 
rule or ordinance or notice of final supplemental rule or ordinance. 
The following changes were made after the Notice of Proposed Rulemaking was 
published on June 5, 2024: 
1. Added an exemption under Section 103 regarding solvent cleaning and 
adjusted the numbering in Section 103 as a result of the added exemption. 
The added exemption, subsection 103.2, reads as follows: 
“This rule does not apply to: Solvent cleaning operations, including wipe 
cleaning, which are subject to the requirements of Rule 331 (Solvent 
Cleaning) of the MCAPCR.” 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
14 of 106

2. Revised the language in Section 301. The section now reads as follows:
“An owner or operator shall not discharge 25 or more tons of VOCs per year,
prior to any emission controls, from activities involving equipment, materials,
and/or substances that emit VOCs that are not regulated under requirements
and standards in other source-specific rules of Regulation III, unless the
emissions are controlled in accordance with Section 302 of this rule.”
3. Revised the introduction paragraph in Section 302. The paragraph now reads
as follows:
“EMISSION CONTROL: VOC emissions to the atmosphere requiring control
pursuant to Section 301 of this rule shall be controlled by at least one of the
following methods:”
4. 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.”
5. 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.”
ii.
A summary of the comments and arguments for and against the notice and the
county’s response to the comments and arguments.
The following discussion evaluates the arguments for and against the rule and 
includes responses to comments received on the proposed rule or the preamble 
in the Notice of Proposed Rulemaking. MCAQD received written comments from 
five (5) stakeholders. All of the comments were reviewed and evaluated by 
MCAQD.
Comment #1:
Modify section 503.2 [renumbered to Section 503.1(b)] of Rule 330 to be 
consistent with section 503.2 [renumbered to Section 503.3(b)] of Revised Rule 
338:
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) [renumbered to Section 504.1(e)] of this rule (EPA Method 18) or the 
method in Section 504.1(e) [renumbered to Section 504.1(g)] of this rule (EPA 
Method 25).
Return to list of attachments
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
15 of 106

Response #1:  
MCAQD evaluated your comment and agrees with the suggestion. The proposed 
language has been incorporated into the draft rule.  
Comment #2:  
Modify section 503.3 [renumbered to Section 503.1(c)] of Rule 330 to match 
section 503.3 of Revised Rule 338 [renumbered to Section 503.3(c)]: 
The ECS capture efficiency shall be determined using one of the methods in 
Section 504.1(e) [renumbered to Section 504.1(h)] 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) [renumbered to Section 504.1(b)] 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. 
Response #2:  
MCAQD has evaluated your comment and agrees with the suggestion. The 
proposed language has been incorporated into the draft rule. 
Comment #3:  
According to the staff report, “the last significant revision to the rule occurred in 
1996” and the Maricopa County Air Quality Department (MCAQD) is proposing to 
revise Rule 330 to clarify, update, and restructure the rule. RadTech believes that 
Rule 330 presents an opportunity for Maricopa County to achieve voluntary 
emission reductions above and beyond those presently required in the rule, 
through regulatory flexibility that will encourage conversion to UV/EB/LED. In its 
current form, Rule 330 seems to focus on Emission Control Systems (ECS) as the 
only means of compliance. The one-sided approach unfairly excludes pollution 
prevention technologies such as UV/EB/LED which puts our businesses at a 
disadvantage as compared to systems using conventional solvents with ECS. 
Thus, our organization cannot support the rule in its current form.  
Response #3:  
Rule 330 does not require facilities that emit less than 25 tons of VOCs per year 
to install an ECS. This emission threshold encourages alternative emission 
reduction methods, such as the use of materials with lower VOC contents. 
Facilities are not discouraged from utilizing alternative emission reduction 
measures as long as the activities comply with the provisions in Rule 330.  
Should a facility emit more than 25 tons of VOCs per year, Rule 330 Section 302 
provides four emission control methods. Facilities may choose to either operate 
an approved ECS, use VOC material containing no more than 20% VOC by weight, 
use a material with a VOC vapor pressure at 68° F not exceeding 1.0 millimeter of 
mercury column (mm Hg), or use methods, measures, or control technologies 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
16 of 106

determined to meet Reasonably Available Control Technology (RACT) as 
approved by the Control Officer. Based on the information provided about 
UV/EB/LED products, Section 302 would permit the use of these products as an 
option for pollution prevention technology.  
Comment #4:  
Section 103-- Exemptions 
Request for Exemption Our materials are typically well below 50 grams/liter in 
VOC content which is minimal compared to the proposed limits. We respectfully 
request that UV/EB/LED materials be exempted from the rule requirements. An 
exemption would be an incentive for businesses to voluntarily choose 
UV/EB/LED technology resulting in additional emission reductions for Maricopa 
County. We respectfully request an exemption.  
Response #4:  
Rule 330 applies to the use of equipment, materials, and/or substances that emit 
VOCs which are not regulated under requirements and standards in other source-
specific rules within the MCAQD rules. It is a catchall rule meant to capture VOC 
emitting operations not captured under a source-specific rule. Most UV/EB/LED 
coatings will be regulated under source specific rules such as Rule 336 (Surface 
Coating Operations and Industrial Adhesive Application Processes) and Rule 337 
(Graphic Arts). Any UV/EB/LED coating that may fall under Rule 330 regulation 
will have minimal requirements if total VOC emissions from a source using the 
coatings fall below 25 tons per year.  
Additionally, there is no permitting requirement in Maricopa County for facilities 
that emit any regulated air pollutant in an amount less than the permitting 
thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting threshold is 
0.5 tons per year). These exemptions are in place to encourage businesses to 
adopt products and practices which limit impacts on air quality.  
Comment #5:  
Section 200-- Definitions  
The rule narrowly focuses the definitions section on ECS. This approach does not 
take into consideration other technologies and may have the unintended 
consequence of giving a certain process an unfair competitive advantage. The 
rule should be technology neutral and include definitions for all available 
technologies. We would very much appreciate the inclusion of a definition for 
energy curable materials in the rule. We propose a definition like the one in 
SCAQMD rules:  
ENERGY CURABLE MATERIALS are single component reactive products that cure 
upon exposure to visible-light, ultraviolet light, or to an electron beam.  
Response #5: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
17 of 106

Thank you for providing MCAQD with a definition for energy curable materials. 
However, a definition is not necessary since MCAQD will not be including any 
additional provisions regarding these materials in the rule.  
Comment #6:  
Section 500—Monitoring & Records  
Recordkeeping requirements are burdensome on businesses and in the case of 
UV/EB/LED operations, are not crucial because the materials are well below the 
rule limits. Exempting energy curable materials from overly prescriptive 
recordkeeping requirements (Section 500-Monitoring &Records) will alleviate 
regulatory burdens on the Maricopa County business community and benefit air 
quality.  
Response #6:  
Should the VOC emissions generated from the UV/EB/LED activities require an 
air quality permit, then minimal recordkeeping would be required. Examples 
include a current list of all VOC-containing materials subject to the rule, monthly 
usage of the materials, and disposal records for the materials. Businesses most 
likely maintain records very similar to these as part of their regular business 
practices.  
As previously mentioned, there is no permitting requirement in Maricopa County 
for facilities that emit any regulated air pollutant in an amount less than the 
permitting thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting 
threshold is 0.5 tons per year). These exemptions are in place to encourage 
businesses to adopt products and practices which limit impacts on air quality.  
Comment #7:  
Section 504--Test Methods  
The Environmental Protection Agency and the SCAQMD have long recognized 
that EPA Method 24 is not suitable for thin film UV/EB/LED Materials. Thus, 
RadTech urges Maricopa County to include ASTM D7767-11 as suitable test 
method for UV/EB/LED products subject to Rule 336. We propose the following 
language:
The VOC content of thin film Energy Curable Coatings, Adhesives and Sealants 
may be determined by manufacturers using ASTM Test Method 7767 Standard 
Test Method to Measure Volatiles from Radiation Curable Acrylate Monomers, 
Oligomers, and the Blends and Thin Film Coatings Made from Them.  
Response #7: 
Since ASTM D7767-11 is not currently an EPA-approved test method, the MCAQD 
will not include it in Rule 330. However, Section 504 of the rule does allow for the 
use of alternative EPA-approved test methods. If ASTM D7767-11 is approved by 
the EPA in the future, then it can be considered as a suitable test method. 
Comment #8: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
18 of 106

According to the staff report, “the last significant revision to the rule occurred in 
1996” and the Maricopa County Air Quality Department (MCAQD) is proposing to 
revise Rule 330 to clarify, update, and restructure the rule. Rule 330 presents an 
opportunity for Maricopa County to achieve voluntary emission reductions above 
and beyond those presently required in the rule, through regulatory flexibility that 
will encourage conversion to UV/EB/LED. In its current form, Rule 330 seems to 
focus on Emission Control Systems (ECS) as the only means of compliance. The 
one-sided approach unfairly excludes pollution prevention technologies such as 
UV/EB/LED which puts our businesses at a disadvantage as compared to 
systems using conventional solvents with ECS. Thus, our organization cannot 
support the rule in its current form.  
 
Response #8:  
Rule 330 does not require facilities that emit less than 25 tons of VOCs per year 
to install an ECS. This emission threshold encourages alternative emission 
reduction methods, such as the use of materials with lower VOC contents. 
Facilities are not discouraged from utilizing alternative emission reduction 
measures as long as the activities comply with the provisions in Rule 330.  
 
Should a facility emit more than 25 tons of VOCs per year, Rule 330 Section 302 
provides four emission control methods. Facilities may choose to either operate 
an approved ECS, use VOC material containing no more than 20% VOC by weight, 
use a material with a VOC vapor pressure at 68° F not exceeding 1.0 millimeter of 
mercury column (mm Hg), or use methods, measures, or control technologies 
determined to meet Reasonably Available Control Technology (RACT) as 
approved by the Control Officer. Based on the information provided about 
UV/EB/LED products, Section 302 would permit the use of these products as an 
option for pollution prevention technology.  
 
Comment #9:  
Section 103-- Exemptions— 
Request for Exemption UV/EB/LED materials are typically well below 50 
grams/liter in VOC content which is minimal compared to the proposed limits. 
We respectfully request that UV/EB/LED materials be exempted from the rule 
requirements. This exemption would be an incentive for businesses to voluntarily 
choose UV/EB/LED technology resulting in additional emission reductions for 
Maricopa County. We respectfully request the inclusion of this exemption.  
 
Response #9:  
Rule 330 applies to the use of equipment, materials, and/or substances that emit 
VOCs which are not regulated under requirements and standards in other source-
specific rules within the MCAQD rules. It is a catchall rule meant to capture VOC 
emitting operations not captured under a source-specific rule. Most UV/EB/LED 
coatings will be regulated under source specific rules such as Rule 336 (Surface 
Coating Operations and Industrial Adhesive Application Processes) and Rule 337 
(Graphic Arts). Any UV/EB/LED coating that may fall under Rule 330 regulation 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
19 of 106

will have minimal requirements if total VOC emissions from a source using the 
coatings fall below 25 tons per year.  
 
Additionally, there is no permitting requirement in Maricopa County for facilities 
that emit any regulated air pollutant in an amount less than the permitting 
thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting threshold is 
0.5 tons per year). These exemptions are in place to encourage businesses to 
adopt products and practices which limit impacts on air quality.  
 
Comment #10:  
Section 200-- Definitions  
The rule narrowly focuses the definitions section on ECS. This approach does not 
take into consideration other technologies and may have the unintended 
consequence of giving high VOC producing processes an unfair competitive 
advantage. The rule should be technology neutral and include definitions for all 
available technologies. We would very much appreciate the inclusion of a 
definition for energy curable materials in the rule. We propose the following 
definition:  
 
ENERGY CURABLE MATERIALS are single component reactive products that cure 
upon exposure to visible-light, ultraviolet light, or to an electron beam.  
 
Response #10:  
Thank you for providing MCAQD with a definition for energy curable materials. 
However, a definition is not necessary since MCAQD will not be including any 
additional provisions regarding these materials in the rule.  
 
Comment #11:  
Section 500—Monitoring & Records  
Recordkeeping requirements are burdensome on businesses and in the case of 
UV/EB/LED operations, are not necessary because the materials are well below 
the rule limits. Exempting energy curable materials from overly prescriptive 
recordkeeping requirements (Section 500- Monitoring & Records) will alleviate 
regulatory burdens on the Maricopa County business community and 
simultaneously benefit the air quality of the region.  
 
Response #11:  
Should the VOC emissions generated from the UV/EB/LED activities require an 
air quality permit, then minimal recordkeeping would be required. Examples 
include a current list of all VOC-containing materials subject to the rule, monthly 
usage of the materials, and disposal records for the materials. Businesses most 
likely maintain records very similar to these as part of their regular business 
practices.  
 
As previously mentioned, there is no permitting requirement in Maricopa County 
for facilities that emit any regulated air pollutant in an amount less than the 
permitting thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
20 of 106

threshold is 0.5 tons per year). These exemptions are in place to encourage 
businesses to adopt products and practices which limit impacts on air quality.  
 
Comment #12:  
Section 504--Test Methods  
The Environmental Protection Agency and the SCAQMD have long recognized 
that EPA Method 24 is not suitable for thin film UV/EB/LED Materials. We urge 
Maricopa County to include ASTM D7767-11 as a suitable test method for 
UV/EB/LED products subject to Rule 330. We propose the following language:  
The VOC content of thin film Energy Curable Coatings, Adhesives and Sealants 
may be determined by manufacturers using ASTM Test Method 7767 Standard 
Test Method to Measure Volatiles from Radiation Curable Acrylate Monomers, 
Oligomers, and the Blends and Thin Film Coatings Made from Them.  
 
Response #12:  
Since ASTM D7767-11 is not currently an EPA-approved test method, the MCAQD 
will not include it in Rule 330. However, Section 504 of the rule does allow for the 
use of alternative EPA-approved test methods. If ASTM D7767-11 is approved by 
the EPA in the future, then it can be considered as a suitable test method. 
 
Comment #13:  
Have a question on Rule 330 as this rule change will affect facilities in different 
ways. It states “The owner or operator shall not discharge more than 25 tons of 
VOCs prior to control into the atmosphere per year from any equipment, 
materials, and/or substances that emit VOCs unless the entire amount of such 
discharge has been reduced in accordance with Section 302 of this rule.”  
We are having some discussion on what does the yellow highlighted wording 
means. For example, an actual facility has VOC control on processes above 15 
lbs/day but does not have control on another separate process that is 9 lbs/day 
as emissions are below the current Rule 330 for heated process of 15 lbs/day. 
However, with the draft Rule 330 (1) do we look at after control emissions for 
current process and before control for uncontrolled process, or (2) do we look as 
both processes before control? The latter would mean VOC control needing to be 
added for relatively small emissions process at 9 lbs/day? 
 
Response #13:  
The language in Section 301 of the rule is applicable to processes prior to any 
emission controls.  
 
Comment #14:  
Since I have been working on air permitting cooling towers for VOCs and HAPs, I 
have been getting asked what 300-level rule does cooling towers go under, if at 
all. I know Rule 330 is the general “catch-all” rule but have not seen it that way in 
permits. The other issue is, if it is Rule 330, with the revised draft Rule 330 
looking like 25 tons per year before control as threshold, how would a source 
abate VOC emissions for cooling towers that meets this threshold? There are 
some sources that look like would be in that situation. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
21 of 106

The draft revised Rule 330 has all combined sources at facility before control 
added up to see if above 25 tons per year (talked with [MCAQD representatives] 
to confirm this applicability) but did not ask about cooling towers yet. Wanted to 
ask you. So, for example: 
1. 
Rule 330 process abated now with 20 tpy VOCs before control 
2. 
Second process at 6 tpy before control and after control 
3. 
Cooling towers at 0.5 tpy 
Since total before control is above 25 tpy then control would be needed for 
everything (two processes and cooling towers). Does this make sense with 
revised draft Rule 330? 
 
Response #14:  
Section 302.4 was drafted as a fourth control option for businesses to use to 
comply with Section 301. Specifically, Section 302.4 provides an option to use 
methods, measures, or control technologies determined to meet RACT as 
approved by the Control Officer. The EPA defines RACT as the lowest emission 
limitation a particular source is capable of achieving by the application of control 
technology that is reasonably available considering technological and economic 
feasibility. With sufficient documentation demonstrating RACT is being 
implemented for controlling emissions from an applicable process, such as 
cooling tower emissions, the owner or operator will be in compliance with 
Section 301.  
 
Comment #15:  
The cooling towers in question [of Rule 330 applicability] are not considered 
insignificant activities per Rule 100 Section 200.63. These are permitted cooling 
towers and on permit equipment list. Some cooling towers in total in a facility 
could have PTE VOC emissions above 25 tons per year by themselves. 
 
Response #15:  
Although the cooling towers may have the potential to trigger the requirement in 
Section 301, the proposed language is applicable to actual emissions, prior to 
emission controls, rather than potential emissions. Should the cooling towers 
meet or exceed the 25 tons per year threshold in conjunction with other VOC-
emitting activities, appropriate emission control methods would need to be 
implemented in accordance with Section 302. As mentioned in Response #14, 
Section 302.4 provides an option to use methods, measures, or control 
technologies determined to meet RACT as approved by the Control Officer. With 
sufficient documentation demonstrating RACT is being implemented for 
controlling emissions from an applicable process, such as cooling tower 
emissions, the owner or operator will be in compliance with Section 301.  
 
Comment #16:  
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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
22 of 106

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. 
Response #16:  
MCAQD added Section 103.2 to the exemption section of the rule. The exemption 
states that solvent cleaning operations, including wipe cleaning, which are 
subject to the requirements of Rule 331 (Solvent Cleaning) of the MCAPCR are 
exempt from Rule 330. Therefore, wipe cleaning is not regulated by the emission 
control requirements of Rule 330.  
Comment #17:  
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. 
Response #17:  
Rule 330 is applicable to equipment, materials, and/or substances that are not 
regulated under requirements and standards in other source-specific rules of 
Regulation III. Most activities conducted at Intel are regulated by source specific 
rules in the MCAPCR rules, such as Rule 338 (Semiconductor Manufacturing). 
Exact Wording of the Rule 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 330 (VOLATILE ORGANIC COMPOUNDS) 
Return to list of attachments
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
23 of 106

INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
APPLICABILITY 
307 
103 
EXEMPTIONS 
SECTION 200 – DEFINITIONS 
201 
DAY 
202 
EMISSION CONTROL SYSTEM (ECS) 
202 
NON-COMPLYING SOLVENT 
203 
ORGANIC COMPOUND 
204 
ORGANIC SOLVENT 
203 
PARTS PER MILLION BY VOLUME DRY (PPMVD) 
204 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 
205 
VOC CONTENT OF MATERIAL 
SECTION 300 – STANDARDS 
301 
LIMITATIONS - OPERATIONS INVOLVING HEAT 
302 
LIMITATIONS-NON-COMPLYING SOLVENTS 
303 
LIMITATIONS - PROCESS LINES 
304 
302 
EMISSION CONTROL REDUCTIONS REQUIRED 
305 
303 
EQUIPMENT CLEANUP  
304 
WORK PRACTICES – HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL  
305 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS  
306  
VOC CONTAINMENT AND DISPOSAL 
307 
EXEMPTIONS 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
24 of 106

SECTION 400 – ADMINISTRATIVE REQUIREMENTS  
401 
COMPLIANCE SCHEDULE 
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING PROVIDING AND MAINTAINING 
MONITORING DEVICES 
502 
ECS RECORDKEEPING REQUIREMENTS DETERMINATION OF COMPLIANCE 
503 
COMPLIANCE DETERMINATION RECORDKEEPING AND REPORTING 
504 
TEST METHODS INCORPORATED BY REFERENCE  
 
 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
25 of 106

Revised 07/13/1988; Revised 09/21/1992; Revised 06/19/1996; Revised 09/25/2013; Revised 
MM/DD/YYYY 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 330 (VOLATILE ORGANIC COMPOUNDS) 
SECTION 100 – GENERAL 
101 
PURPOSE: To limit emissions of volatile organic compounds (VOCs) into the 
atmosphere that may result from the use of equipment, materials, and/or substances 
organic solvents or processes that emit volatile organic compounds VOCs.  
102 
APPLICABILITY: This rule applies to the use of equipment, materials, and/or 
substances that emit VOCs which are not regulated under requirements and standards 
in other source-specific rules of Regulation III. 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). 
307 
103 
EXEMPTIONS: The provisions of This rule does shall not apply to: 
307.1 Organic solvent manufacturing facilities and the overland transport of organic 
solvents and materials containing VOC. 
307.2 The use of equipment, materials, and/or substances which meet applicable 
requirements and standards specified by other rules of Regulation III. 
307.3 
103.1 The spraying or other employment of insecticides, pesticides, or herbicides. 
103.2 Solvent cleaning operations, including wipe cleaning, which are subject to the 
requirements of Rule 331 (Solvent Cleaning) of the MCAPCR. 
307.4 
103.3 The following Standard Industrial Classification (SIC) codes: 
a. Industry Group 331 (Steel Works, Blast Furnaces, and Rolling and Finishing 
Mills): SIC codes 3312 and 3313. 
b. Industry Group 332 (Iron and Steel Foundries): SIC codes 3321, 3322, 3324, 
and 3325. 
c. Industry Group 333 (Primary Smelting And Refining Of Nonferrous): SIC codes 
3331, 3334, and 3339. 
d. Industry Group 334 (Secondary Smelting And Refining Of Nonferrous): SIC 
code 3341. 
e. Industry Group 336 (Nonferrous Foundries (castings)): SIC codes 3363, 3364, 
3365, 3366, and 3369. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
26 of 106

f. Industry Group 339 (Miscellaneous Primary Metal Products): SIC code 3398. 
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. 
Foundries; smelters; melting or roasting of metal, ore, or dross; all operations 
included under Standard Industrial Classification codes 3312, 3313, 332, 333, 
334, 336, and 3398; and all on-site mold making activities at such operations and 
industries. 
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions 
shall apply, in addition to those definitions found in Rule 100 (General Provisions and 
Definitions) of the rules within the MCAPCR these rules. In the event of any inconsistency 
between any of the rules within the MCAPCR Maricopa County Air Pollution Control Rules, the 
definitions in this rule take precedence.   
201 
DAY: A period of 24 consecutive hours beginning at midnight. 
202 
EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control 
Officer, used to reduce emissions of VOCs. Such a system consists of an emissions 
collection system and an emissions processing subsystem. 
202 
NON-COMPLYING SOLVENT: A solvent which exceeds the applicable percentage 
composition limit for any of the four chemical groupings listed below. 
202.1 Group I: One or more of the following families of compounds having the olefinic 
or cyclo-olefinic type of unsaturation − hydrocarbons, alcohols, aldehydes, esters, 
ethers, and/or ketones; except perchloroethylene: 5 percent by volume. 
202.2 Group II: One or more aromatic compounds having eight or more carbon atoms 
to the molecule except ethylbenzene, methyl benzoate, and phenyl acetate: 8 
percent by volume. 
202.3 Group III: One or more of the following compounds and compound types 
−ketones having a branched hydrocarbon structure, ethylbenzene, 
trichloroethylene, and/or toluene: 20 percent by volume. 
202.4 An aggregate of any combination of the above three groups: 20 percent by 
volume. 
202.5 Whenever any organic solvent or any constituent of an organic solvent may be 
classified from its chemical structure into more than one of the above groups of 
organic compounds, it shall be considered a member of the most reactive 
chemical group that it can be classified into, that is, that group having the lowest 
percentage composition limit. 
203 
ORGANIC COMPOUND: Any compound of carbon excluding carbon monoxide, carbon 
dioxide, carbonic acid, carbonates, and metallic carbides. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
27 of 106

204 
ORGANIC SOLVENT: Any organic compound which is liquid at actual conditions of use 
or storage and which is used as a diluent, thinner, dissolver, viscosity reducer, 
extractant, cleaning agent or is a reactant or product in a manufacturing process. 
203 
PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express 
concentration that is corrected to a dry basis. 
204 
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 
503.3 of this rule. 
205 
VOC CONTENT OF MATERIAL: The weight of VOC per volume of material, as calculated 
according to the formula in Section 503.4 of this rule. 
SECTION 300 – STANDARDS 
301 
LIMITATIONS: An owner or operator shall not discharge 25 or more tons of VOCs per 
year, prior to any emission controls, from activities involving equipment, materials, 
and/or substances that emit VOCs that are not regulated under requirements and 
standards in other source-specific rules of Regulation III, unless the emissions are 
controlled in accordance with Section 302 of this rule. 
LIMITATIONS-OPERATIONS INVOLVING HEAT: No person shall discharge more than 15 
pounds (6.8 kg) of volatile organic compounds into the atmosphere in any one day from 
any machine, equipment, device, or other article in which any volatile organic compound 
or any material containing a volatile organic compound comes into contact with flame 
or is evaporated at temperatures exceeding 200° F (93.3° C), in the presence of oxygen, 
unless the entire amount of such discharge has been reduced in accordance with 
Section 304 of this rule. 
302 
LIMITATIONS-NON-COMPLYING SOLVENTS: Excluding emissions subject to Section § 
301 above, no person shall discharge more than 40 pounds (18 kg) of volatile organic 
compounds into the atmosphere in any one day from any machine, equipment, device or 
other article for employing, applying, evaporating or drying any non-complying solvent 
(as defined in Section 202 of this rule) or material containing such non-complying 
solvent, unless the entire amount of such discharge has been reduced in accordance 
with Section § 304 of this rule. 
303 
LIMITATIONS-PROCESS LINES: Emissions of VOCs from any series of machines, 
equipment, devices or other articles which are designed for processing any item 
including but not limited to continuous web(s), strip(s), or wire(s) and which use 
operations described in Sections 301 and/or 302 of this rule shall be collectively subject 
to the limitations of and compliance with those sections. 
304 
302 
EMISSION CONTROL REDUCTIONS REQUIRED: VOC emissions to the atmosphere of 
volatile organic compounds requiring control pursuant to Section 301 or 302 of this rule 
shall be controlled reduced by at least one of the following methods: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
28 of 106

302.1 Operating an approved Emission Control System (ECS) in accordance with 
Section 305 of this rule; 
304.3 
302.2 Using low VOC material containing no more than 20% percent VOC by weight 
volume (as determined by the applicable test method(s) and excluding non-
precursor organic compounds and water), provided that no VOC from the 
material comes into contact with flame; or 
302.3 Using a material with a VOC vapor pressure at 68° F (20° C) not exceeding 1 
millimeter of mercury column (mm Hg); or  
302.4 Using methods, measures, or control technologies determined to meet 
Reasonably Available Control Technology (RACT) as approved by the Control 
Officer. 
304.1 Incineration, provided that 90 percent or more of the carbon in the volatile 
organic compounds entering the incineration device is oxidized to carbon dioxide 
and overall control efficiency (capture plus processing) is at least 85 percent by 
weight; or 
304.2 Adsorption, provided that overall control efficiency (capture plus processing) is 
at least 85 percent by weight; or 
304.4 Processing in a manner not less effective than in subsection 304.1 or 304.2 of 
this rule and verified by test methods of this rule. 
304.5 The owner or operator using an emissions control device to reduce emissions in 
accordance with this section shall provide the Control Officer with an Operation 
and Maintenance (O&M) Plan. This plan shall specify key system operating 
parameters, such as temperatures, pressures and/or flow rates, necessary to 
determine compliance with this rule and describe in detail procedures to 
maintain the approved emission control system. The Control Officer's written 
approval of this plan shall be required for compliance with this rule to be 
achieved. 
305 
303 
EQUIPMENT CLEANUP: A An owner or operator person shall not use any liquid 
materials containing more than 10% percent VOC by weight volatile organic compounds 
for the cleanup of equipment unless: 
305.1 
303.1 The used cleaning liquids are collected in a container which is closed when not in 
use and is disposed of in a manner such that VOCs volatile organic compounds 
are not discharged emitted into the atmosphere. or 
305.2 
303.2 The equipment is disassembled and cleaned in a non-porous container solvent 
vat which is closed when not in use. or  
305.2 
303.3 Cleaning is done by other methods, approved in writing by the Control Officer, 
which limit evaporation. 
304 
WORK PRACTICES – HANDLING, DISPOSAL, AND STORAGE OF VOC-CONTAINING 
MATERIAL: An owner or operator shall store, handle, and dispose of VOC-containing 
material in a manner that prevents the evaporation of VOC to the atmosphere. Work 
practices limiting VOC emissions include, but are not limited to, all of the following: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
29 of 106

304.1 
Store all VOC-containing materials in closed, leak free containers. Containers 
shall remain covered with a leak tight cover, when not in use, unless emissions 
are captured and controlled by an approved ECS that complies with Section 305 
of this rule. 
304.2 
Minimize spills of VOC-containing materials. 
304.3 
Convey VOC-containing materials from one location to another in closed 
containers, pipes, or via sewage treatment works. 
  
304.4 
Containers in which VOC-containing materials are stored must have a legible 
label identifying the container’s contents. 
304.5 
Disposal of waste or surplus VOC-containing materials shall be done in a 
manner that does not promote VOC evaporation, such as, but not limited to, via 
sewage treatment works or having the waste hauled off-site in sealed 
containers. 
305 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS: 
305.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 302.1 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, as determined per Section 503.1 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), as determined per Section 503.2. 
305.2 Operation and Maintenance (O&M) Plan Required for ECS:  
a. An owner or operator shall provide and maintain (an) O&M Plan(s) for any 
ECS and any ECS monitoring devices used pursuant to this rule or to a 
Maricopa County Air Quality Permit. 
b. The owner or operator shall submit to the Control Officer for approval the 
O&M 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. 
305.3 Providing and Maintaining ECS Monitoring Devices: An owner or operator 
incinerating, adsorbing, or otherwise processing VOC emissions pursuant to this 
rule shall provide, properly install and maintain in calibration, in good working 
order devices described in the facility’s O&M Plan that indicate temperatures, 
pressures, rates of flow, or other operating conditions necessary to determine if 
the ECS is functioning properly and is properly maintained. Records shall be kept 
pursuant to Section 502 of this rule which demonstrate that the ECS meets the 
overall control standard required by Section 305.1 of this rule and is operated in 
accordance with the equipment manufacturer's specifications. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
30 of 106

305.4 O&M Plan Responsibility: An owner or operator of a facility that is required to 
have an O&M Plan pursuant to Section 305.2 of this rule must fully comply with 
all O&M Plans that the owner or operator has submitted for approval, but which 
have not yet been approved, unless notified otherwise by the Control Officer in 
writing. 
305.5 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. 
306  
VOC CONTAINMENT AND DISPOSAL: No person shall store, discard, or dispose of VOC 
or VOC-containing material in a way intended to cause or to allow the evaporation of 
VOC to the atmosphere. Reasonable measures shall be taken to prevent such 
evaporation which include but are not limited to the following:  
306.1 All materials from which VOC can evaporate, including fresh solvent, waste 
solvent and solvent-soaked rags and residues, shall be stored in closed 
containers when not in use; and  
306.2 Such containers one gallon and larger shall be legibly labeled with their contents; 
and  
306.3 Records of the disposal/recovery of such materials shall be kept. Records of 
hazardous waste disposal shall be kept in accordance with hazardous waste 
disposal statutes. 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS  
401 
COMPLIANCE SCHEDULE: 
401.1 ECS Installation at New Sources: For sources that commence construction after 
[revision date], compliance with the ECS requirements shall be achieved upon 
source startup. 
401.2 ECS Installation at Existing Sources: When an emission control system will be 
installed to achieve compliance with the ECS requirements of Section 302.1 of 
this rule, an owner or operator shall comply with the following increments of 
progress and be in compliance with the requirements by the timeframe specified: 
a. Within 6 months of becoming subject to Section 301 of this rule, submit a 
compliance schedule and permit application, or notification in lieu of permit 
application if already permitted as future abatement, to the Control Officer. 
b. Within 24 months of final permit issuance, or notification in lieu of permit 
application if already permitted as future abatement, be fully compliant with 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
31 of 106

the ECS requirements in Section 302.1 of this rule and submit to the Control 
Officer a complete source test report indicating compliance. 
Any person employing a control device as of September 21, 1992, to meet the 
emissions reductions requirement of this rule shall by November 20, 1992, file an 
Operation and Maintenance Plan with the Control Officer pursuant to Section 501 of this 
rule. 
SECTION 500 – MONITORING AND RECORDS 
501 
PROVIDING AND MAINTAINING MONITORING DEVICES: Any person incinerating, 
adsorbing, or otherwise processing organic materials pursuant to this rule shall 
provide, properly install and maintain in calibration, in good working order and in 
operation, devices specified in the Operation and Maintenance Plan as well as in either 
the Permit to Operate or the Installation Permit for indicating temperatures, pressures, 
rates of flow, or other operating conditions necessary to determine if air pollution 
control equipment is functioning properly and is properly maintained. 
502 
DETERMINATION OF COMPLIANCE: Determination of the organic solvent content and 
composition of a solvent or material shall be made as of the time that the solvent or 
material is in its final form for application or employment, notwithstanding any prior 
blending, reducing, thinning or other preparation for application or employment. 
Emissions resulting from air or heat drying of products for the first 12 hours after the 
removal from any machine, equipment, device or other article shall be included in 
determining compliance with this rule. 
503 
501 
RECORDKEEPING AND REPORTING: Any person 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.  
503.1 
501.5 Current List:  
a. Maintain a current list of all VOC-containing materials subject to this rule. The 
list shall express VOC content in one of the following forms:  
(1) Pounds VOC per gallon; or 
(2) Grams VOC per liter; or 
(3) The percent VOC by weight along with the specific gravity or density. 
b. A facility choosing to comply with Section 302 of this rule by using a material 
with a VOC vapor pressure at 68° F (20° C) not exceeding 1 millimeter of 
mercury column (mm Hg) shall have on site the written value of the total VOC 
vapor pressure of such material in one of the following forms: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
32 of 106

(1) A manufacturer’s technical data sheet; 
(2) A manufacturer’s safety data sheet (MSDS); or 
(3) Actual test results. 
state the VOC content of each in pounds per gallon or grams per liter. 
coatings, adhesives, makeup solvents, and any other VOC-containing 
materials; VOC content shall be expressed less water and non-precursor 
compounds for materials which are not used for cleaning or cleanup. 
503.2 
501.6 Monthly Usage Records: Maintain monthly records of the amount purchased or 
used of all VOC-containing materials subject to this rule. Records shall be totaled 
by the end of the month for the previous month. the amount of each coating; 
adhesive; makeup solvent; solvent used for surface preparation, for cleanup, and 
for the removal of materials; and any other VOC-containing material used. 
Identify any materials subject to the emission limits in Section 301 or Section 
302 and keep separate totals for these materials. 
503.3 Operation and Maintenance: Maintain a continuous record of the times an 
approved emission control device is used to comply with this rule. Maintain daily 
records of the O&M Plan's key system operating parameters. Account for any 
periods of operation when the control device was not operating. Maintain records 
of all maintenance performed according to the O&M Plan. 
503.4 
501.7 Discarded Materials: Maintain monthly records of the type, amount, and method 
of disposing of VOC-containing materials on each day of disposal. 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 an ECS is used at a facility pursuant to this rule, the owner or 
operator shall make a permanent record of the key system operating parameters 
as required by the O&M Plan 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 
operational. 
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. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
33 of 106

502.5 An explanation shall be entered for scheduled maintenance that is not performed 
during the period designated for it in the O&M Plan. 
503 
COMPLIANCE DETERMINATION: 
503.1 ECS Efficiency: An owner or operator that complies with Section 305.1(a) of this 
rule by using an ECS shall demonstrate compliance using the following methods 
and equations: 
a. Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100 
Where, 
EffO 
= Overall ECS efficiency expressed as a percentage; and 
EffCo = ECS control efficiency expressed as a percentage; and 
EffCa = ECS capture efficiency expressed as a percentage. 
b. The ECS control efficiency shall be determined by measuring the VOC content
of gaseous emissions entering and exiting the ECS using the method in
Section 504.1(e) of this rule (EPA Method 18) or the method in Section
504.1(g) of this rule (EPA Method 25).
c. The ECS capture efficiency shall be determined using one of the methods in
Section 504.1(h) 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(b) 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.
503.2 Alternative for Very Dilute Input: An owner or operator that complies with 
Section 305.1(b) of this rule shall demonstrate compliance by using the method 
in Section 504.1(g) of this rule (EPA Method 25A). 
503.3 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, 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
34 of 106

i
W  =
Weight of the “i”th VOC compound in grams 
w
W  =
Weight of water in grams 
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
M  =
Molecular weight of the “j”th non-precursor organic 
compound 
c
PP  =
VOC composite partial pressure at 68°F in mm Hg 
i
VP  =
Vapor pressure of the “i”th VOC compound at 68°F in mm 
Hg 
18 = 
Weight of one gram-mole of water 
n = 
Total number of different (dissolved) VOCs 
m = 
Total number of different (dissolved) non-precursor 
organic compounds 
503.4 Formula for VOC Content of Material: The VOC content of material shall be 
calculated by the following equation: 
VOC CONTENT OF MATERIAL as a percent =
W
W
W
m
s
w
es
W
−
−
 X 100% 
Using consistently either pounds or grams in the calculations, where: 
Ws   = 
Weight of volatile material in pounds (or grams), including 
water, non-precursor organic compounds, and dissolved 
vapors 
Ww  
= 
Weight of water in pounds (or grams) 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
35 of 106

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 pounds or grams 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) 
504 
TEST METHODS INCORPORATED BY REFERENCE: The following test methods are 
approved for use for the purpose of determining compliance with this rule. The test 
methods are incorporated by reference in Rule 360 and Appendix G of the Maricopa 
County Air Pollution Control Regulations. Alternative test methods as approved by the 
Administrator or other EPA-approved test methods may be used upon prior written 
approval from the Control Officer. When more than one test method is permitted for the 
same determination, an exceedance under any method will constitute a violation. 
504.1 
EPA Test Methods: 
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).
504.6 
b. Ventilation/draft rates shall be determined by EPA Methods 2 
(“Determination of Stack Gas Velocity and Volumetric Flow Rate”), 2A 2a 
(“Direct Measurement of Gas Volume Through Pipes and Small Ducts”), 2C 
2c (“Determination of Stack Gas Velocity and Volumetric Flow rate in Small 
Stacks or Ducts”), and 2D 2d (“Measurement of Gas volumetric Flow Rates 
in Small Pipes and Ducts”) (40 CFR 60, Appendix A-1). 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
36 of 106

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).
504.4 
e. Measurement of VOC emissions subject to this rule shall be conducted in 
accordance with EPA Test Method 18 (“Measurement of Gaseous Organic 
Compound Emissions by Gas Chromatography”) (40 CFR 60, Appendix A-6). 
and/or by, in combination with the appropriate capture efficiency method. 
504.1 
f. Measurement of VOC content of materials shall be conducted and reported 
in accordance with EPA Test Method 24 (“Determination of Volatile Matter 
Content, Water Content, Density, Volume Solids, and Weight Solids of 
Surface Coatings”) (40 CFR 60, Appendix A-7). 
g. 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”) or an applicable sub-method of Method 25 (40 CFR 60, Appendix
A-7).
504.5 
h. 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). 
Capture/control efficiency shall be determined by mass balance in 
combination with ventilation/draft rate determinations or by  "Using a 
Temporary Total Enclosure for Capture Efficiency Testing", EPA-450/4-91-
020. 
504.2 
EPA-Approved American Society for Testing and Materials (ASTM) Standards: 
a. ASTM D3792-91, “Standard Method for Water Content of Water-Reducible
Paints by Direct Injection into a Gas Chromatograph”.
b. ASTM E169-93, “General Techniques of Ultraviolet Quantitative Analysis”.
c. ASTM E260-96, “General Practice for Packed Column Gas
Chromatography”.
504.2 The non-complying organic compound content shall be determined using the 
ASTM Standard Recommended Practices for General Gas Chromatography 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
37 of 106

Procedures, E 260-85; General Techniques of Infrared Quantitative Analysis, E 
168-67; or General Techniques of Ultraviolet Quantitative Analysis, E 169-87.
504.3 Measurements of the water and exempt solvent vapor content shall be 
conducted in accordance with ASTM Test Methods D 4457-85 and D 3792-86. 
504.7 Temperature measurements shall be done with an instrument with an accuracy 
and precision of less than one-half degree Fahrenheit (0.25°C) for temperatures 
up to 480°F (250°C). Higher temperatures shall be determined by instruments no 
less accurate than 1.0 percent of full scale unless the Control Officer specifies 
greater accuracy. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
38 of 106

MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 330 (VOLATILE ORGANIC COMPOUNDS) 
INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
APPLICABILITY 
103 
EXEMPTIONS 
SECTION 200 – DEFINITIONS 
201 
DAY 
202 
EMISSION CONTROL SYSTEM (ECS) 
203 
PARTS PER MILLION BY VOLUME DRY (PPMVD) 
204 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 
205 
VOC CONTENT OF MATERIAL 
SECTION 300 – STANDARDS 
301 
LIMITATIONS 
302 
EMISSION CONTROL 
303 
EQUIPMENT CLEANUP 
304 
WORK PRACTICES – HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL 
305 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
COMPLIANCE SCHEDULE 
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING 
502 
ECS RECORDKEEPING REQUIREMENTS 
503 
COMPLIANCE DETERMINATION 
504 
TEST METHODS INCORPORATED BY REFERENCE 
Return to list of attachments
Clean Version of Draft Rule 330
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
39 of 106

Revised 07/13/1988; Revised 09/21/1992; Revised 06/19/1996; Revised 09/25/2013; Revised 
MM/DD/YYYY 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 330 (VOLATILE ORGANIC COMPOUNDS) 
SECTION 100 – GENERAL 
101 
PURPOSE: To limit emissions of volatile organic compounds (VOCs) from the use of 
equipment, materials, and/or substances that emit VOCs. 
102 
APPLICABILITY: This rule applies to the use of equipment, materials, and/or 
substances that emit VOCs which are not regulated under requirements and standards 
in other source-specific rules of Regulation III.  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). 
103 
EXEMPTIONS: This rule does not apply to: 
103.1 The spraying or other employment of insecticides, pesticides, or herbicides. 
103.2 Solvent cleaning operations, including wipe cleaning, which are subject to the 
requirements of Rule 331 (Solvent Cleaning) of the MCAPCR. 
103.3 The following Standard Industrial Classification (SIC) codes: 
a. Industry Group 331 (Steel Works, Blast Furnaces, and Rolling and Finishing
Mills): SIC codes 3312 and 3313.
b. Industry Group 332 (Iron and Steel Foundries): SIC codes 3321, 3322, 3324,
and 3325.
c. Industry Group 333 (Primary Smelting And Refining Of Nonferrous): SIC codes
3331, 3334, and 3339.
d. Industry Group 334 (Secondary Smelting And Refining Of Nonferrous): SIC
code 3341.
e. Industry Group 336 (Nonferrous Foundries (castings)): SIC codes 3363, 3364,
3365, 3366, and 3369.
f.
Industry Group 339 (Miscellaneous Primary Metal Products): SIC code 3398.
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.
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
40 of 106

SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions shall
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of 
the rules within the MCAPCR. In the event of any inconsistency between any of the rules within 
the MCAPCR, the definitions in this rule take precedence.  
201 
DAY: A period of 24 consecutive hours beginning at midnight. 
202 
EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control 
Officer, used to reduce emissions of VOCs. Such a system consists of an emissions 
collection system and an emissions processing subsystem. 
203 
PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express 
concentration that is corrected to a dry basis. 
204 
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 
503.3 of this rule. 
205 
VOC CONTENT OF MATERIAL: The weight of VOC per volume of material, as calculated 
according to the formula in Section 503.4 of this rule. 
SECTION 300 – STANDARDS 
301 
LIMITATIONS: An owner or operator shall not discharge 25 or more tons of VOCs per 
year, prior to any emission controls, from activities involving equipment, materials, 
and/or substances that emit VOCs that are not regulated under requirements and 
standards in other source-specific rules of Regulation III, unless the emissions are 
controlled in accordance with Section 302 of this rule. 
302 
EMISSION CONTROL: VOC emissions to the atmosphere requiring control pursuant to 
Section 301 of this rule shall be controlled by at least one of the following methods: 
302.1 Operating an approved Emission Control System (ECS) in accordance with 
Section 305 of this rule; 
302.2 Using VOC material containing no more than 20% VOC by weight (as determined 
by the applicable test method(s) and excluding non-precursor organic 
compounds and water);  
302.3 Using a material with a VOC vapor pressure at 68° F (20° C) not exceeding 1 
millimeter of mercury column (mm Hg); or 
302.4 Using methods, measures, or control technologies determined to meet 
Reasonably Available Control Technology (RACT) as approved by the Control 
Officer. 
303 
EQUIPMENT CLEANUP: An owner or operator shall not use any liquid materials 
containing more than 10% VOC by weight for the cleanup of equipment unless: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
41 of 106

303.1 The used cleaning liquids are collected in a container which is closed when not in 
use and is disposed of in a manner such that VOCs are not discharged into the 
atmosphere.  
303.2 The equipment is disassembled and cleaned in a non-porous container which is 
closed when not in use.   
303.3 Cleaning is done by other methods, approved in writing by the Control Officer, 
which limit evaporation. 
304 
WORK PRACTICES – HANDLING, DISPOSAL, AND STORAGE OF VOC-CONTAINING 
MATERIAL: An owner or operator shall store, handle, and dispose of VOC-containing 
material in a manner that prevents the evaporation of VOC to the atmosphere. Work 
practices limiting VOC emissions include, but are not limited to, all of the following: 
304.1 
Store all VOC-containing materials in closed, leak free containers. Containers 
shall remain covered with a leak tight cover, when not in use, unless emissions 
are captured and controlled by an approved ECS that complies with Section 305 
of this rule. 
304.2 
Minimize spills of VOC-containing materials. 
304.3 
Convey VOC-containing materials from one location to another in closed 
containers, pipes, or via sewage treatment works. 
  
304.4 
Containers in which VOC-containing materials are stored must have a legible 
label identifying the container’s contents. 
304.5 
Disposal of waste or surplus VOC-containing materials shall be done in a 
manner that does not promote VOC evaporation, such as, but not limited to, via 
sewage treatment works or having the waste hauled off-site in sealed 
containers. 
305 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS: 
305.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 302.1 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, as determined per Section 503.1 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), as determined per Section 503.2 of this rule. 
305.2 Operation and Maintenance (O&M) Plan Required for ECS:  
a. An owner or operator shall provide and maintain (an) O&M Plan(s) for any 
ECS and any ECS monitoring devices used pursuant to this rule or to a 
Maricopa County Air Quality Permit. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
42 of 106

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.
305.3 Providing and Maintaining ECS Monitoring Devices: An owner or operator 
incinerating, adsorbing, or otherwise processing VOC emissions pursuant to this 
rule shall provide, properly install and maintain in calibration, in good working 
order devices described in the facility’s O&M Plan that indicate temperatures, 
pressures, rates of flow, or other operating conditions necessary to determine if 
the ECS is functioning properly and is properly maintained. Records shall be kept 
pursuant to Section 502 of this rule which demonstrate that the ECS meets the 
overall control standard required by Section 305.1 of this rule and is operated in 
accordance with the equipment manufacturer's specifications. 
305.4 O&M Plan Responsibility: An owner or operator of a facility that is required to 
have an O&M Plan pursuant to Section 305.2 of this rule must fully comply with 
all O&M Plans that the owner or operator has submitted for approval, but which 
have not yet been approved, unless notified otherwise by the Control Officer in 
writing. 
305.5 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: 
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 ECS Installation at Existing Sources: When an emission control system will be 
installed to achieve compliance with the ECS requirements of Section 302.1 of 
this rule, an owner or operator shall comply with the following increments of 
progress and be in compliance with the requirements by the timeframe specified: 
a. Within 6 months of becoming subject to Section 301 of this rule, submit a
compliance schedule and permit application, or notification in lieu of permit
application if already permitted as future abatement, to the Control Officer.
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
43 of 106

b. Within 24 months of final permit issuance, or notification in lieu of permit 
application if already permitted as future abatement, be fully compliant with 
the ECS requirements in Section 302.1 of this rule and submit to the Control 
Officer a complete source test report indicating compliance. 
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 all VOC-containing materials subject to this rule. The 
list shall express VOC content in one of the following forms: 
(1) Pounds VOC per gallon; or 
(2) Grams VOC per liter; or 
(3) The percent VOC by weight along with the specific gravity or density. 
b. A facility choosing to comply with Section 302 of this rule by using a material 
with a VOC vapor pressure at 68° F (20° C) not exceeding 1 millimeter of 
mercury column (mm Hg) shall have on site the written value of the total VOC 
vapor pressure of such material 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 Monthly Usage Records: Maintain monthly records of the amount purchased or 
used of all VOC-containing materials subject to this rule. Records shall be totaled 
by the end of the month for the previous month.   
501.7 Discarded Materials: Maintain monthly records of the type, amount, and method 
of disposing of VOC-containing materials. Records of legal disposal include but 
are not limited to shipping papers or quantity discharged to sewage treatment 
works. 
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 an ECS is used at a facility pursuant to this rule, the owner or 
operator shall make a permanent record of the key system operating parameters 
as required by the O&M Plan which may include the following, when applicable: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
44 of 106

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 
operational. 
502.3 For each day or period the O&M Plan requires maintenance, the owner or 
operator shall make a permanent record of the maintenance actions taken within 
3 business days of the maintenance completion. 
502.4 Corrective action taken, if any. 
502.5 An explanation shall be entered for scheduled maintenance that is not performed 
during the period designated for it in the O&M Plan. 
503 
COMPLIANCE DETERMINATION: 
503.1 ECS Efficiency: An owner or operator that complies with Section 305.1(a) of this 
rule by using an ECS shall demonstrate compliance using the following methods 
and equations: 
a. Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100 
Where,
EffO 
= Overall ECS efficiency expressed as a percentage; and 
EffCo 
= ECS control efficiency expressed as a percentage; and 
EffCa 
= ECS capture efficiency expressed as a percentage. 
b. The ECS control efficiency shall be determined by measuring the VOC content
of gaseous emissions entering and exiting the ECS using the method in
Section 504.1(e) of this rule (EPA Method 18) or the method in Section
504.1(g) of this rule (EPA Method 25).
c. The ECS capture efficiency shall be determined using one of the methods in
Section 504.1(h) 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(b) 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.
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
45 of 106

503.2 Alternative for Very Dilute Input: An owner or operator that complies with 
Section 305.1(b) of this rule shall demonstrate compliance by using the method 
in Section 504.1(g) of this rule (EPA Method 25A). 
503.3 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 
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
M  = 
Molecular weight of the “j”th non-precursor organic 
compound 
c
PP  = 
VOC composite partial pressure at 68°F in mm Hg 
i
VP  = 
Vapor pressure of the “i”th VOC compound at 68°F in mm 
Hg 
18 = 
Weight of one gram-mole of water 
n = 
Total number of different (dissolved) VOCs 
m = 
Total number of different (dissolved) non-precursor 
organic compounds 
503.4 Formula for VOC Content of Material: The VOC content of material shall be 
calculated by the following equation: 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
46 of 106

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) 
504 
TEST METHODS INCORPORATED BY REFERENCE: The following test methods are 
approved for use for the purpose of determining compliance with this rule. The test 
methods are incorporated by reference in Rule 360 (New Source Performance 
Standards) and Appendix G (Incorporated Materials) of the MCAPCR. Alternative test 
methods as approved by the Administrator or other EPA-approved test methods may be 
used upon prior written approval from the Control Officer. When more than one test 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
47 of 106

method is permitted for the same determination, an exceedance under any method will 
constitute a violation. 
504.1 EPA Test Methods: 
a. EPA Methods 1 (“Sample and Velocity Traverses for Stationary Sources”) and 
1A (“Sample and Velocity Traverses for Stationary Sources with Small Stacks 
or Ducts”) (40 CFR 60, Appendix A-1). 
b. EPA Methods 2 (“Determination of Stack Gas Velocity and Volumetric Flow 
Rate”), 2A (“Direct Measurement of Gas Volume Through Pipes and Small 
Ducts”), 2C (“Determination of Stack Gas Velocity and Volumetric Flow rate in 
Small Stacks or Ducts”), and 2D (“Measurement of Gas volumetric Flow Rates 
in Small Pipes and Ducts”) (40 CFR 60, Appendix A-1). 
c. EPA Methods 3 (“Gas Analysis for the Determination of Dry Molecular 
Weight”), 3A (“Determination of Oxygen and Carbon Dioxide Concentrations in 
Emissions From Stationary Sources (Instrumental Analyzer Procedure”), 3B 
(“Gas Analysis for the Determination of Emission Rate Correction Factor or 
Excess Air”), and 3C (“Determination of Carbon Dioxide, Methane, Nitrogen, 
and Oxygen from Stationary Sources”) (40 CFR 60, Appendix A-2). 
d. EPA Method 4 (“Determination of Moisture Content in Stack Gases”) (40 CFR 
60, Appendix A-3). 
e. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions by 
Gas Chromatography”) (40 CFR 60, Appendix A-6).  
f.  EPA Method 24 (“Determination of Volatile Matter Content, Water Content, 
Density, Volume Solids, and Weight Solids of Surface Coatings”) (40 CFR 60, 
Appendix A-7). 
g. 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). 
h. 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). 
504.2 EPA-Approved American Society for Testing and Materials (ASTM) Standards: 
a. ASTM D3792-91, “Standard Method for Water Content of Water-Reducible 
Paints by Direct Injection into a Gas Chromatograph”. 
b. ASTM E169-93, “General Techniques of Ultraviolet Quantitative Analysis”. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
48 of 106

c. ASTM E260-96, “General Practice for Packed Column Gas Chromatography”. 
 
 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
49 of 106

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 
50 of 106

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 
51 of 106

MARICOPA COUNTY BOARD OF HEALTH 
AUGUST 28, 2023 – MEETING MINUTES 
 
3 
 
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 
 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
52 of 106

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 
53 of 106

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 
54 of 106

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 
55 of 106

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 
56 of 106

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 
57 of 106

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 
58 of 106

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 
59 of 106

1
Subject:
FW: Comments for Rule 330 (Volatile Organic Compounds) and Rule 331 (Solvent Cleaning) 
Revisions
From: Hannah Luke (AQD)  
Sent: Thursday, June 29, 2023 12:56 PM 
To: Hana De Leon <hana.deleon@nxp.com> 
Cc: Peggy Felice <peggy.felice@nxp.com> 
Subject: RE: Comments for Rule 330 (Volatile Organic Compounds) and Rule 331 (Solvent Cleaning) Revisions 
Hi Hana, 
Thank you for sending me your comments on draft rules 330 and 331. I have incorporated the suggestions into the draft 
rule.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Wednesday, June 21, 2023 5:25 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com> 
Subject: FW: Comments for Rule 330 (Volatile Organic Compounds) and Rule 331 (Solvent Cleaning) Revisions 
Hello Hannah, 
As agreed in the meeting yesterday, I am forwarding you our comments for Rules 330 and 331. 
Hana 
From: Hana De Leon  
Sent: Tuesday, June 20, 2023 7:53 AM 
To: 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): 
Copies of all written and electronic Stakeholder input
Return to list of attachments
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
60 of 106

2

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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
61 of 106

1
From:
Michelle Mada (AQD)
Sent:
Tuesday, July 25, 2023 1:41 PM
To:
Michele Ross (COA)
Cc:
Gregory Verkamp (AQD); Kimberly Butler (AQD); Hannah Luke (AQD)
Subject:
RE: Online Form Submittal: Citizen Comments
Thank you Michele. 
Michelle Mada 
Administrative Operations Specialist 
Air Quality 
Planning and Analysis 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-372-1465 C: 602-695-5890
E: Michelle.Mada@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: Michele Ross (COA) <Michele.Ross@maricopa.gov>  
Sent: Tuesday, 25 July, 2023 1:08 PM 
To: Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Will Adrian (AQD) 
<William.Adrian@maricopa.gov> 
Subject: FW: Online Form Submittal: Citizen Comments 
Hello, 
Please see citizen comment below and attachment. 
Thank you, 
Michele Ross 
Program Manager 
County Manager’s Office 
O: 602-506-0583 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: noreply@civicplus.com <noreply@civicplus.com>  
Sent: Monday, July 24, 2023 4:34 PM 
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (HSD) <Kathy.Semder@Maricopa.Gov>; Andy 
Linton (ENV) <Andy.Linton@Maricopa.Gov>; Bill Leal (DOT) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (PND) 
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov>; Michele Ross (COA) 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
62 of 106

2
<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-2022-004-Rule 330 (Volatile Organic Compounds) 
Department 
Air Quality 
I would like to  
Express opposition 
First Name 
Rita 
Last Name 
Loof 
Organization 
RadTech International 
City 
Bethesda 
Zip 
Field not completed. 
Email 
rita@radtech.org 
Phone Number 
9092400866 
Phone Type 
Mobile 
Would you like someone to 
contact you? 
Yes 
Comments 
Our organization is opposing Rule 330 as outlined in the 
attached public comment letter.  
If applicable, attach 
supporting documentation 
associated with your 
comment. The only file 
types supported are MS 
Office and Adobe Acrobat. 
RadTech Public Comments Rule 330 072423.pdf
Email not displaying correctly? View it in your browser.  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
63 of 106

The Honorable Board of Health 
Maricopa County  
July 24th, 2023 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 330—Volatile Organic 
Compounds—OPPOSE unless Amended  
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 330 –
Volatile Organic Compounds. RadTech International is the trade association for the Ultraviolet/ 
Electron Beam/Light Emitting Diode (UV/EB/LED) industry.  The organization represents over 
800 members nationwide involved in a myriad of markets ranging from solar panel 
manufacturing to finger nail polish.  
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, they are 
specifically formulated to react to energy (light or a beam of electrons).  The nature of the 
process is such that virtually no Volatile Organic Compounds (VOCs) are generated. The 
materials are generally high viscosity and thus there are no regulatory concerns with generation 
of particulate matter from spraying.  Additionally, UV/EB/LED processes are electric and thus 
do not produce combustion contaminants such as NOx, SOx and Greenhouse Gases. 
The South Coast Air Quality Management District has some of the most stringent air quality 
regulations in the nation. In many of its rulemakings, the agency has recognized the 
sustainability advantages, including energy efficiency, of ultraviolet and electron beam curing 
technology.  SCAQMD provides incentives to companies who convert to UV/EB through 
exemptions from permitting and recordkeeping. The agency recognized UV/EB as Best 
Available Control Technology for many industry sectors and the technology has recently been 
included in the Statewide BACT Clearinghouse for the California Air Resources Board. 
UV/EB technology meets the regulatory definition of “super-compliant” in the SCAQMD which 
applies to coatings with a Volatile Organic Compound (VOC) content of less than 50 grams per 
liter.  RadTech holds a seat on the South Coast Air Quality Management Plan Advisory 
Committee.  Our Association provides input to the agency on how to achieve clean air goals and 
implementation of UV/EB is one strategy which has been included in the Air Quality 
Management Plan. The most recent AQMP now includes UV/EB as control strategy. According 
to SCAQMD findings: “These programs may also provide manufacturers with incentives to 
accelerate the deployment of cleaner technologies.  Such an example is the use of energy-curing 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
64 of 106

technologies which includes ultraviolet light (UV), electron beam (EB), heat and light emitting 
diode (LED) cured coatings. 
The California State Senate has adopted a resolution recognizing the many benefits of ultraviolet 
(UV) and electron beam (EB) technologies and the contributions of RadTech. The proclamation 
acknowledges the “invaluable” contributions made by RadTech to the State of California and 
beyond, and cites the Association’s ideals of community service. It commends RadTech for its 
“outstanding commitment to improving the environment and economy through its programs.” 
The Environmental Protection Agency has classified UV/EB technology as Lowest Achievable 
Emission Rate. The EPA Control Techniques Guidelines documents state: “This technology is 
gaining greater acceptance and, where applicable, achieves a near 100 percent reduction of VOC 
emissions”. 
With UV/EB technology, facilities can achieve emission reductions above and beyond those 
required by even the most stringent of regulations. There is no need to install air pollution 
control devices which may emit combustion contaminants such as Nitrogen Oxides or Sulfur 
Oxides. The products do not contain Toxic Air Contaminants and have no secondary adverse 
impacts such as emissions of greenhouse gases.  
Requested Rule Language Changes 
According to the staff report, “the last significant revision to the rule occurred in 1996” and the 
Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 330 to clarify, 
update, and restructure the rule. RadTech believes that Rule 330 presents an opportunity for 
Maricopa County to achieve voluntary emission reductions above and beyond those presently 
required in the rule, through regulatory flexibility that will encourage conversion to 
UV/EB/LED.  In its current form, Rule 330 seems to focus on Emission Control Systems (ECS) 
as the only means of compliance.  The one sided approach, unfairly excludes pollution 
prevention technologies such as UV/EB/LED and puts our businesses at disadvantage as 
compared to systems using conventional solvents with ECS.  Thus, our organization cannot 
support the rule in its current form. 
Section 103-- Exemptions-- Request for Exemption 
Our materials are typically well below 50 grams/liter in VOC content which is minimal 
compared to the proposed limits.  We respectfully request that UV/EB/LED materials be 
exempted from the rule requirements.  An exemption would be an incentive for businesses to 
voluntarily choose UV/EB/LED technology resulting in additional emission reductions for 
Maricopa County.  We respectfully request an exemption. 
Section 200-- Definitions  
The rule narrowly focuses the definitions section on ECS.  This approach does not take into 
consideration other technologies and may have the unintended consequence of giving a certain 
process an unfair competitive advantage.  The rule should be technology neutral and include 
definitions for all available technologies. We would very much appreciate the inclusion of a 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
65 of 106

definition for energy curable materials in the rule.  We propose a definition like the one in 
SCAQMD rules: 
ENERGY CURABLE MATERIALS are single component reactive products that cure upon 
exposure to visible-light, ultraviolet light, or to an electron beam.  
Section 500—Monitoring & Records 
Recordkeeping requirements are burdensome on businesses and in the case of UV/EB/LED 
operations, are not crucial because the materials are well below the rule limits.  Exempting 
energy curable materials from overly prescriptive recordkeeping requirements (Section 500-
Monitoring &Records) will alleviate regulatory burdens on the Maricopa County business 
community and benefit air quality.  
Section 504--Test Methods 
The Environmental Protection Agency and the SCAQMD have long recognized that EPA 
Method 24 is not suitable for thin film UV/EB/LED Materials.  Thus, RadTech urges Maricopa 
County to include ASTM D7767-11 as suitable test method for UV/EB/LED products subject to 
Rule 336.  We propose the following language:  
The VOC content of thin film Energy Curable Adhesives and Sealants may be determined by 
manufacturers using ASTM Test Method 7767 Standard Test Method to Measure Volatiles from 
Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from 
Them. 
The RadTech Association looks forward to working with Maricopa County on this rulemaking 
and would gladly provide any additional information your staff may need. 
Sincerely, 
Rita M. Loof 
Director, Environmental Affairs 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
66 of 106

1
From:
Gregory Verkamp (AQD)
Sent:
Wednesday, August 2, 2023 2:00 PM
To:
Hannah Luke (AQD)
Subject:
FW: Public Comments Maricopa County Rule 330-- Oppose
Attachments:
RadTech Public Comments Rule 330 072423.pdf
FYI 
Greg Verkamp 
Planning Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-7141 C: 602-206-0564
E: Gregory.Verkamp@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Philip McNeely (AQD) <PHILIP.McNEELY@Maricopa.gov>  
Sent: Wednesday, August 2, 2023 1:43 PM 
To: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: FW: Public Comments Maricopa County Rule 330-- Oppose 
FYI 
Philip McNeely 
Director 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003 
O: 602-506-6701 C: 602-341-9026 
E: Philip.Mcneely@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: COB Agenda Comments <Agenda.Comments@maricopa.gov>  
Sent: Wednesday, August 2, 2023 1:14 PM 
To: Philip McNeely (AQD) <PHILIP.McNEELY@Maricopa.gov> 
Subject: FW: Public Comments Maricopa County Rule 330-- Oppose 
Good afternoon Phil, 
FYI, the Clerk’s Office received this email with attachment and I am forwarding it to you for your information. I have let 
the author know that I forwarded this information to Maricopa County Department of Air Quality. 
With Regards, 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
67 of 106

2
Kelly Gardiner 
Management Analyst 
Clerk of the Board 
301 W Jefferson St 10th Floor Phoenix, AZ 85003 
O: 602-372-1522 
E: Kelly.Gardiner@maricopa.gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: Rita Loof <rml93@verizon.net>  
Sent: Wednesday, August 2, 2023 12:33 PM 
To: COB Agenda Comments <Agenda.Comments@maricopa.gov>; Jack Sellers (BOS) <Jack.Sellers@Maricopa.Gov>; Clint 
Hickman (BOS) <Clint.Hickman@Maricopa.Gov>; District 2 <District2@maricopa.gov>; District 3 
<District3@maricopa.gov>; District 5 <District5@maricopa.gov> 
Subject: Public Comments Maricopa County Rule 330-- Oppose 
Dear Maricopa Board of Supervisors,  please see attached public comments regarding Rule 330.  We would be happy to 
discuss further.  Thank you, 
Rita M. Loof 
Director, Environmental Affairs 
RadTech International 
rita@radtech.org 
rml93@verizon.net 
909-981-5974
909-240-0866 cell/text
www.radtech.org
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
68 of 106

The Honorable Board of Health 
Maricopa County  
July 24th, 2023 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 330—Volatile Organic 
Compounds—OPPOSE unless Amended  
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 330 –
Volatile Organic Compounds. RadTech International is the trade association for the Ultraviolet/ 
Electron Beam/Light Emitting Diode (UV/EB/LED) industry.  The organization represents over 
800 members nationwide involved in a myriad of markets ranging from solar panel 
manufacturing to finger nail polish.  
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, they are 
specifically formulated to react to energy (light or a beam of electrons).  The nature of the 
process is such that virtually no Volatile Organic Compounds (VOCs) are generated. The 
materials are generally high viscosity and thus there are no regulatory concerns with generation 
of particulate matter from spraying.  Additionally, UV/EB/LED processes are electric and thus 
do not produce combustion contaminants such as NOx, SOx and Greenhouse Gases. 
The South Coast Air Quality Management District has some of the most stringent air quality 
regulations in the nation. In many of its rulemakings, the agency has recognized the 
sustainability advantages, including energy efficiency, of ultraviolet and electron beam curing 
technology.  SCAQMD provides incentives to companies who convert to UV/EB through 
exemptions from permitting and recordkeeping. The agency recognized UV/EB as Best 
Available Control Technology for many industry sectors and the technology has recently been 
included in the Statewide BACT Clearinghouse for the California Air Resources Board. 
UV/EB technology meets the regulatory definition of “super-compliant” in the SCAQMD which 
applies to coatings with a Volatile Organic Compound (VOC) content of less than 50 grams per 
liter.  RadTech holds a seat on the South Coast Air Quality Management Plan Advisory 
Committee.  Our Association provides input to the agency on how to achieve clean air goals and 
implementation of UV/EB is one strategy which has been included in the Air Quality 
Management Plan. The most recent AQMP now includes UV/EB as control strategy. According 
to SCAQMD findings: “These programs may also provide manufacturers with incentives to 
accelerate the deployment of cleaner technologies.  Such an example is the use of energy-curing 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
69 of 106

technologies which includes ultraviolet light (UV), electron beam (EB), heat and light emitting 
diode (LED) cured coatings. 
The California State Senate has adopted a resolution recognizing the many benefits of ultraviolet 
(UV) and electron beam (EB) technologies and the contributions of RadTech. The proclamation 
acknowledges the “invaluable” contributions made by RadTech to the State of California and 
beyond, and cites the Association’s ideals of community service. It commends RadTech for its 
“outstanding commitment to improving the environment and economy through its programs.” 
The Environmental Protection Agency has classified UV/EB technology as Lowest Achievable 
Emission Rate. The EPA Control Techniques Guidelines documents state: “This technology is 
gaining greater acceptance and, where applicable, achieves a near 100 percent reduction of VOC 
emissions”. 
With UV/EB technology, facilities can achieve emission reductions above and beyond those 
required by even the most stringent of regulations. There is no need to install air pollution 
control devices which may emit combustion contaminants such as Nitrogen Oxides or Sulfur 
Oxides. The products do not contain Toxic Air Contaminants and have no secondary adverse 
impacts such as emissions of greenhouse gases.  
Requested Rule Language Changes 
According to the staff report, “the last significant revision to the rule occurred in 1996” and the 
Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 330 to clarify, 
update, and restructure the rule. RadTech believes that Rule 330 presents an opportunity for 
Maricopa County to achieve voluntary emission reductions above and beyond those presently 
required in the rule, through regulatory flexibility that will encourage conversion to 
UV/EB/LED.  In its current form, Rule 330 seems to focus on Emission Control Systems (ECS) 
as the only means of compliance.  The one sided approach, unfairly excludes pollution 
prevention technologies such as UV/EB/LED and puts our businesses at disadvantage as 
compared to systems using conventional solvents with ECS.  Thus, our organization cannot 
support the rule in its current form. 
Section 103-- Exemptions-- Request for Exemption 
Our materials are typically well below 50 grams/liter in VOC content which is minimal 
compared to the proposed limits.  We respectfully request that UV/EB/LED materials be 
exempted from the rule requirements.  An exemption would be an incentive for businesses to 
voluntarily choose UV/EB/LED technology resulting in additional emission reductions for 
Maricopa County.  We respectfully request an exemption. 
Section 200-- Definitions  
The rule narrowly focuses the definitions section on ECS.  This approach does not take into 
consideration other technologies and may have the unintended consequence of giving a certain 
process an unfair competitive advantage.  The rule should be technology neutral and include 
definitions for all available technologies. We would very much appreciate the inclusion of a 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
70 of 106

definition for energy curable materials in the rule.  We propose a definition like the one in 
SCAQMD rules: 
ENERGY CURABLE MATERIALS are single component reactive products that cure upon 
exposure to visible-light, ultraviolet light, or to an electron beam.  
Section 500—Monitoring & Records 
Recordkeeping requirements are burdensome on businesses and in the case of UV/EB/LED 
operations, are not crucial because the materials are well below the rule limits.  Exempting 
energy curable materials from overly prescriptive recordkeeping requirements (Section 500-
Monitoring &Records) will alleviate regulatory burdens on the Maricopa County business 
community and benefit air quality.  
Section 504--Test Methods 
The Environmental Protection Agency and the SCAQMD have long recognized that EPA 
Method 24 is not suitable for thin film UV/EB/LED Materials.  Thus, RadTech urges Maricopa 
County to include ASTM D7767-11 as suitable test method for UV/EB/LED products subject to 
Rule 336.  We propose the following language:  
The VOC content of thin film Energy Curable Adhesives and Sealants may be determined by 
manufacturers using ASTM Test Method 7767 Standard Test Method to Measure Volatiles from 
Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from 
Them. 
The RadTech Association looks forward to working with Maricopa County on this rulemaking 
and would gladly provide any additional information your staff may need. 
Sincerely, 
Rita M. Loof 
Director, Environmental Affairs 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
71 of 106

1
Subject:
FW: Rule 330 Oppose
Attachments:
08-06-23 SCS Public Comments Maricopa County Rule 330 Oppose.pdf
From: Philip McNeely (AQD) <PHILIP.McNEELY@Maricopa.gov>  
Sent: Monday, August 7, 2023 8:45 AM 
To: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: FW: Rule 330 Oppose 
FYI 
Philip McNeely 
Director 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003 
O: 602-506-6701 C: 602-341-9026 
E: Philip.Mcneely@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: COB Agenda Comments <Agenda.Comments@maricopa.gov>  
Sent: Monday, August 7, 2023 8:30 AM 
To: Philip McNeely (AQD) <PHILIP.McNEELY@Maricopa.gov> 
Subject: FW: Rule 330 Oppose 
Good morning Phil, 
FYI: I am forwarding this email, with aƩachment, that was received in the Clerk’s Office regarding Rule 330. Each District 
office was copied on it. 
With Regards, 
Kelly Gardiner 
Management Analyst 
Clerk of the Board 
301 W Jefferson St 10th Floor Phoenix, AZ 85003 
O: 602-372-1522 
E: Kelly.Gardiner@maricopa.gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: Mike Bonner <mbonner@viscosity.com>  
Sent: Sunday, August 6, 2023 10:57 AM 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
72 of 106

2
To: COB Agenda Comments <Agenda.Comments@maricopa.gov>; Jack Sellers (BOS) <Jack.Sellers@Maricopa.Gov>; Clint 
Hickman (BOS) <Clint.Hickman@Maricopa.Gov>; District 2 <District2@maricopa.gov>; District 3 
<District3@maricopa.gov>; District 5 <District5@maricopa.gov>; COB Agenda Comments 
<Agenda.Comments@maricopa.gov> 
Subject: Rule 330 Oppose 
Honorable Board Members, 
Please see the aƩached leƩer expressing the reasons we are in opposiƟon to Rule 330 and suggesƟons for the minor 
modificaƟons that would allow us to support the rule. 
Please feel free to reach out to me if I can be of assistance in any way. 
Best Regards, 
Michael R. Bonner | Vice President – Engineering & Technology 
586.255.2889 
mbonner@viscosity.com
www.viscosity.com  
12427 31 Mile Road | Washington, MI  48095   USA 
Visit our Blog @ The Business of Viscosity 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
73 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
August 6, 2023 
Honorable Members Board of Health 
Maricopa County 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 330—Volatile Or-
ganic Compounds—OPPOSE unless Amended 
Dear Board Members: 
Saint Clair Systems is the leader in temperature and viscosity control systems for fluid dis-
pensing applications. This includes the application of both solvent based and UV/EB 
cure paints and coatings, sealers and adhesives, pottings and encapsulants, and print-
ing inks just to name a few.  Many of our customers are involved in industrial/automotive 
finishing, coil coating, battery, pharmaceutical, and printing sectors.  Most have in-
stalled our systems both to improve their quality and to reduce their use of VOCs.   
Because one of our primary business objectives is to reduce our customers’ environ-
mental impact, we welcome the opportunity to comment on the proposed amend-
ments to Rule 330 – Volatile Organic Compounds.   
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, 
they are specifically formulated to react to energy (light or a beam of electrons).  The 
nature of the curing process is such that virtually no Volatile Organic Compounds 
(VOCs) are generated. The materials are generally high viscosity and thus there are no 
regulatory concerns with generation of particulate matter from spraying.  Additionally, 
UV/EB/LED processes are powered by electricity and thus do not produce those com-
bustion contaminants such as NOx, SOx and Greenhouse Gases normally associated 
with high temperature curing (baking). 
With UV/EB technology, facilities can achieve emission reductions above and beyond 
those required by even the most stringent of regulations.  There is no need to install air 
pollution control devices which may emit combustion contaminants such as Nitrogen 
Oxides or Sulfur Oxides.  The products do not contain Toxic Air Contaminants and have 
no secondary adverse impacts such as emissions of greenhouse gases. 
Requested Rule Language Changes 
According to the staff report, “the last significant revision to the rule occurred in 1996” 
and the Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 
330 to clarify, update, and restructure the rule.  Rule 330 presents an opportunity for 
Maricopa County to achieve voluntary emission reductions above and beyond those 
presently required in the rule, through regulatory flexibility that will encourage conver-
sion to UV/EB/LED.  In its current form, Rule 330 seems to focus on Emission Control 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
74 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
Systems (ECS) as the only means of compliance.  The one-sided approach unfairly ex-
cludes pollution prevention technologies such as UV/EB/LED which puts our businesses 
at a disadvantage as compared to systems using conventional solvents with ECS.  Thus, 
our organization cannot support the rule in its current form. 
Section 103-- Exemptions-- Request for Exemption 
UV/EB/LED materials are typically well below 50 grams/liter in VOC content which is min-
imal compared to the proposed limits.  We respectfully request that UV/EB/LED materi-
als be exempted from the rule requirements.  This exemption would be an incentive for 
businesses to voluntarily choose UV/EB/LED technology resulting in additional emission 
reductions for Maricopa County.  We respectfully request the inclusion of this exemp-
tion. 
Section 200-- Definitions 
The rule narrowly focuses the definitions section on ECS.  This approach does not take 
into consideration other technologies and may have the unintended consequence of 
giving high VOC producing processes an unfair competitive advantage.  The rule 
should be technology neutral and include definitions for all available technologies.  We 
would very much appreciate the inclusion of a definition for energy curable materials in 
the rule.  We propose the following definition: 
ENERGY CURABLE MATERIALS are single component reactive products that cure upon 
exposure to visible-light, ultraviolet light, or to an electron beam. 
Section 500—Monitoring & Records 
Recordkeeping requirements are burdensome on businesses and in the case of 
UV/EB/LED operations, are not necessary because the materials are well below the rule 
limits.  Exempting energy curable materials from overly prescriptive recordkeeping re-
quirements (Section 500-Monitoring & Records) will alleviate regulatory burdens on the 
Maricopa County business community and simultaneously benefit the air quality of the 
region. 
Section 504--Test Methods 
The Environmental Protection Agency and the SCAQMD have long recognized that 
EPA Method 24 is not suitable for thin film UV/EB/LED Materials.  We urge Maricopa 
County to include ASTM D7767-11 as a suitable test method for UV/EB/LED products sub-
ject to Rule 330.  We propose the following language:  
The VOC content of thin film Energy Curable Coatings, Adhesives and Sealants may be 
determined by manufacturers using ASTM Test Method 7767 Standard Test Method to 
Measure Volatiles from Radiation Curable Acrylate Monomers, Oligomers, and the 
Blends and Thin Film Coatings Made from Them. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
75 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
Our organization looks forward to working with Maricopa County on this rulemaking and 
would gladly provide any additional information your staff may need to add language 
that would remedy the harm being done to businesses in the County who are looking to 
convert to UV/EB/LED processes to reduce their environmental impact. 
Sincerely, 
Saint Clair Systems, Inc. 
Michael R. Bonner 
Vice President – Engineering & Technology 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
76 of 106

1
From:
Gregory Verkamp (AQD)
Sent:
Monday, August 7, 2023 9:15 AM
To:
Hannah Luke (AQD)
Subject:
FW: Online Form Submittal: Citizen Comments
Attachments:
08-06-23 SCS Public Comments Maricopa County Rule 330 Oppose.pdf
Greg Verkamp 
Planning Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-7141 C: 602-206-0564
E: Gregory.Verkamp@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Michele Ross (COA) <Michele.Ross@maricopa.gov>  
Sent: Monday, August 7, 2023 9:06 AM 
To: Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Will Adrian (AQD) <William.Adrian@maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: FW: Online Form Submittal: Citizen Comments 
Good morning,  
Please see citizen comment below and attachment. 
Thank you, 
Michele Ross 
Program Manager 
County Manager’s Office 
O: 602-506-0583 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: noreply@civicplus.com <noreply@civicplus.com>  
Sent: Sunday, August 6, 2023 10:53 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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
77 of 106

2
Citizen Comments 
Each Regulatory Department is committed to providing opportunities for 
stakeholder input regarding the adoption and amendment of all regulatory 
requirements. Your input will be collected and forwarded to the appropriate 
department. You will receive a written response from the applicable department 
within two business days. We appreciate your comments and your time. 
Case Number/Rule 
AQ-2022-004-Rule 330 (Volatile Organic Compounds) 
Department 
Air Quality 
I would like to  
Express opposition 
First Name 
Michael 
Last Name 
Bonner 
Organization 
Saint Clair Systems, Inc. 
City 
Washington 
Zip 
48095 
Email 
mbonner@stclairsystems.com 
Phone Number 
15862552889 
Phone Type 
Mobile 
Would you like someone to 
contact you? 
Yes 
Comments 
Please see the attached letter expressing the reasons we are 
in opposition to Rule 330 and suggestions for the minor 
modifications that would allow us to support the rule. 
If applicable, attach 
supporting documentation 
associated with your 
comment. The only file 
types supported are MS 
Office and Adobe Acrobat. 
08-06-23 SCS Public Comments Maricopa County Rule 330
Oppose.pdf
Email not displaying correctly? View it in your browser.  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
78 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
August 6, 2023 
Honorable Members Board of Health 
Maricopa County 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 330—Volatile Or-
ganic Compounds—OPPOSE unless Amended 
Dear Board Members: 
Saint Clair Systems is the leader in temperature and viscosity control systems for fluid dis-
pensing applications. This includes the application of both solvent based and UV/EB 
cure paints and coatings, sealers and adhesives, pottings and encapsulants, and print-
ing inks just to name a few.  Many of our customers are involved in industrial/automotive 
finishing, coil coating, battery, pharmaceutical, and printing sectors.  Most have in-
stalled our systems both to improve their quality and to reduce their use of VOCs.   
Because one of our primary business objectives is to reduce our customers’ environ-
mental impact, we welcome the opportunity to comment on the proposed amend-
ments to Rule 330 – Volatile Organic Compounds.   
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, 
they are specifically formulated to react to energy (light or a beam of electrons).  The 
nature of the curing process is such that virtually no Volatile Organic Compounds 
(VOCs) are generated. The materials are generally high viscosity and thus there are no 
regulatory concerns with generation of particulate matter from spraying.  Additionally, 
UV/EB/LED processes are powered by electricity and thus do not produce those com-
bustion contaminants such as NOx, SOx and Greenhouse Gases normally associated 
with high temperature curing (baking). 
With UV/EB technology, facilities can achieve emission reductions above and beyond 
those required by even the most stringent of regulations.  There is no need to install air 
pollution control devices which may emit combustion contaminants such as Nitrogen 
Oxides or Sulfur Oxides.  The products do not contain Toxic Air Contaminants and have 
no secondary adverse impacts such as emissions of greenhouse gases. 
Requested Rule Language Changes 
According to the staff report, “the last significant revision to the rule occurred in 1996” 
and the Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 
330 to clarify, update, and restructure the rule.  Rule 330 presents an opportunity for 
Maricopa County to achieve voluntary emission reductions above and beyond those 
presently required in the rule, through regulatory flexibility that will encourage conver-
sion to UV/EB/LED.  In its current form, Rule 330 seems to focus on Emission Control 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
79 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
Systems (ECS) as the only means of compliance.  The one-sided approach unfairly ex-
cludes pollution prevention technologies such as UV/EB/LED which puts our businesses 
at a disadvantage as compared to systems using conventional solvents with ECS.  Thus, 
our organization cannot support the rule in its current form. 
Section 103-- Exemptions-- Request for Exemption 
UV/EB/LED materials are typically well below 50 grams/liter in VOC content which is min-
imal compared to the proposed limits.  We respectfully request that UV/EB/LED materi-
als be exempted from the rule requirements.  This exemption would be an incentive for 
businesses to voluntarily choose UV/EB/LED technology resulting in additional emission 
reductions for Maricopa County.  We respectfully request the inclusion of this exemp-
tion. 
Section 200-- Definitions 
The rule narrowly focuses the definitions section on ECS.  This approach does not take 
into consideration other technologies and may have the unintended consequence of 
giving high VOC producing processes an unfair competitive advantage.  The rule 
should be technology neutral and include definitions for all available technologies.  We 
would very much appreciate the inclusion of a definition for energy curable materials in 
the rule.  We propose the following definition: 
ENERGY CURABLE MATERIALS are single component reactive products that cure upon 
exposure to visible-light, ultraviolet light, or to an electron beam. 
Section 500—Monitoring & Records 
Recordkeeping requirements are burdensome on businesses and in the case of 
UV/EB/LED operations, are not necessary because the materials are well below the rule 
limits.  Exempting energy curable materials from overly prescriptive recordkeeping re-
quirements (Section 500-Monitoring & Records) will alleviate regulatory burdens on the 
Maricopa County business community and simultaneously benefit the air quality of the 
region. 
Section 504--Test Methods 
The Environmental Protection Agency and the SCAQMD have long recognized that 
EPA Method 24 is not suitable for thin film UV/EB/LED Materials.  We urge Maricopa 
County to include ASTM D7767-11 as a suitable test method for UV/EB/LED products sub-
ject to Rule 330.  We propose the following language:  
The VOC content of thin film Energy Curable Coatings, Adhesives and Sealants may be 
determined by manufacturers using ASTM Test Method 7767 Standard Test Method to 
Measure Volatiles from Radiation Curable Acrylate Monomers, Oligomers, and the 
Blends and Thin Film Coatings Made from Them. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
80 of 106

12427 31 Mile Road • Washington Township, Michigan • 48095 
586.336.0700 • www.saintclairsystems.com 
Our organization looks forward to working with Maricopa County on this rulemaking and 
would gladly provide any additional information your staff may need to add language 
that would remedy the harm being done to businesses in the County who are looking to 
convert to UV/EB/LED processes to reduce their environmental impact. 
Sincerely, 
Saint Clair Systems, Inc. 
Michael R. Bonner 
Vice President – Engineering & Technology 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
81 of 106

1
From:
Gregory Verkamp (AQD)
Sent:
Tuesday, October 24, 2023 3:21 PM
To:
Mike Sherer; Hannah Luke (AQD)
Cc:
Mike Sherer
Subject:
RE: Draft Rule 330
Hi Mike, 
Please give me a call and we discuss this further. Thanks. 
Greg Verkamp 
Planning Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-7141 C: 602-206-0564
E: Gregory.Verkamp@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Monday, October 23, 2023 5:06 PM 
To: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Mike Sherer <msherereng@aol.com> 
Subject: RE: Draft Rule 330 
Thanks Greg! I looked at website before emailing you both and could not find the next 
stakeholder meeƟng. Have a quesƟon on Rule 330 as this rule change will affect faciliƟes in 
different ways. It states “The owner or operator shall not discharge more than 25 tons of VOCs prior 
to control into the atmosphere per year from any equipment, materials, and/or substances that emit 
VOCs unless the entire amount of such discharge has been reduced in accordance with Section 302 
of this rule.” We are having some discussion on what does the yellow highlighted wording means. For 
example, an actual facility has VOC control on processes above 15 lbs/day but does not have control 
on another separate process that is 9 lbs/day as emissions are below the current Rule 330 for heated 
process of 15 lbs/day. However, with the draft Rule 330 (1)  do we look at after control emissions for 
current process and before control for uncontrolled process, or (2) do we look as both processes 
before control? The latter would mean VOC control needing to be added for relatively small emissions 
process at 9 lbs/day?  
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
82 of 106

2
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>  
Sent: Monday, October 23, 2023 3:38 PM 
To: Mike Sherer <msherer@trinityconsultants.com>; Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Subject: RE: Draft Rule 330 
Hi Mike, 
We are tentaƟvely planning a 2nd stakeholder workshop for Rule 330, along with Rule 331, for late November/early 
December. We will post draŌs of both draŌ rules to the Enhanced Regulatory Outreach Program website at least two 
weeks before the workshop. 
Greg Verkamp 
Planning Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-7141 C: 602-206-0564
E: Gregory.Verkamp@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Monday, October 23, 2023 3:32 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: Draft Rule 330 
Hi Hannah and Greg. What is the status please fo draŌ Rule 330 since August? Thanks! Mike. 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
83 of 106

3
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
84 of 106

1
From:
Mike Sherer <msherer@trinityconsultants.com>
Sent:
Monday, November 6, 2023 8:32 AM
To:
Hannah Luke (AQD); Gregory Verkamp (AQD)
Subject:
RE: 300-Level Rule and Cooling Towers VOC Emissions
Thanks! 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Sent: Monday, November 6, 2023 6:27 AM 
To: Mike Sherer <msherer@trinityconsultants.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Hi Mike, 
We have been working on language to address your concern; however, we’ve had internal staff out of office who need 
to review before sending out any draŌ language.  
I should be able to send you some draŌ language by tomorrow. 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
85 of 106

2
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Friday, November 3, 2023 12:55 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
When you can please let me know – no hurry 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, November 1, 2023 7:19 AM 
To: Mike Sherer <msherer@trinityconsultants.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Hi Mike, 
Greg and I will discuss this internally and then get back to you about seƫng up a meeƟng to discuss Rule 330. I should be 
able to get back to you by tomorrow.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
86 of 106

3
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, October 31, 2023 4:44 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: FW: 300-Level Rule and Cooling Towers VOC Emissions 
Hi Hannah and Greg. Sorry another quesƟon on draŌ Rule 330. I have been emailing with Todd 
MarƟn on possible scenario below (please see email chain) for VOC emissions from cooling 
towers. The example below is similar to the two faciliƟes I am working with, so real. Please let 
me know if you would like to have call. Thanks very much. Mike. 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
From: Todd Martin (AQD) <Todd.Martin@maricopa.gov>  
Sent: Tuesday, October 31, 2023 3:41 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
I’d suggest bringing it up with them. 
Todd Martin 
Permitting Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix 
O: 602-506-7248 C: 602-448-9182 
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, October 31, 2023 3:24 PM 
To: Todd Martin (AQD) <Todd.Martin@maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
87 of 106

4
Thanks Todd. Cooling towers VOC emissions would be considered fugiƟves and not subject to 
Rule 330? Is there a way to determine this for conversaƟons with Rules SecƟon or should I ask 
them? 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
From: Todd Martin (AQD) <Todd.Martin@maricopa.gov>  
Sent: Tuesday, October 31, 2023 2:41 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Ok, that makes sense. 
Currently we just have faciliƟes track VOCs emiƩed through the cooling towers to make sure the emissions don’t push 
them over any regulatory thresholds. I don’t see that changing.  
Off the top of my head I think the disƟncƟon is that cooling tower VOC emissions would likely be considered fugiƟve and 
thus could not be pracƟcally captured and controlled.  
I’m not sure of the current wording in the draŌ of Rule 330 but control requirements in county rules typically only apply 
to non-fugiƟves.  
Todd Martin 
Permitting Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix 
O: 602-506-7248 C: 602-448-9182 
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, October 31, 2023 2:04 PM 
To: Todd Martin (AQD) <Todd.Martin@maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
88 of 106

5
No t just cooling towers. The draŌ revised Rule 330 has all combined sources at facility before 
control added up to see if above 25 tons per year (talked with Greg and Hannah to confirm this 
applicability) but did not ask about cooling towers yet. Wanted to ask you. So, for example: 
1. Rule 330 process abated now with 20 tpy VOCs before control
2. Second process at 6 tpy before control and aŌer control
3. Cooling towers at 0.5 tpy
Since total before control is above 25 tpy then control would be needed for everything (two 
processes and cooling towers). Does this make sense with revised draŌ Rule 330?  
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
From: Todd Martin (AQD) <Todd.Martin@maricopa.gov>  
Sent: Tuesday, October 31, 2023 1:58 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 300-Level Rule and Cooling Towers VOC Emissions 
Hi Mike, 
A facility is emiƫng more than 25 tpy VOCs from cooling towers?!? Which one?  
Todd Martin 
Permitting Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix 
O: 602-506-7248 C: 602-448-9182 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
89 of 106

6
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, October 31, 2023 1:10 PM 
To: Todd Martin (AQD) <Todd.Martin@maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: 300-Level Rule and Cooling Towers VOC Emissions 
Hi Todd. Sounds like things are sƟll busy there. Since I have been working on air permiƫng 
cooling towers for VOCs and HAPs, I have been geƫng asked what 300-level rule does cooling 
towers go under, if at all. I know Rule 330 is the general “catch-all” rule but have not seen it 
that way in permits. The other issue is, if it is Rule 330, with the revised draŌ Rule 330 looking 
like 25 tons per year before control as threshold, how would a source abate VOC emissions for 
cooling towers that meets this threshold? There are some sources that look like would be in 
that situaƟon. Thanks 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
Starting November 23rd, we are moving to a new address : 702 East Osborn Road, Ste 160, Phoenix, 
Arizona 85014 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
90 of 106

1
From:
Mike Sherer <msherer@trinityconsultants.com>
Sent:
Monday, January 8, 2024 3:30 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Mike Sherer
Subject:
RE: 330/331 Workshop Follow Up
This Message Is From an External Sender  
This message came from outside your organization. Please use caution when corresponding outside the county.  
Hi Hannah. It is very possible that Rule 330 has been used for cooling towers for permit 
conditions in past. I have not generally seen Rule 330 quoted for cooling towers until recently 
so that is why I asked. Thanks 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014 
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, January 8, 2024 3:20 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 330/331 Workshop Follow Up 
Hi Mike, 
The proposed revision to Rule 330 are not anticipated to change the way cooling towers are regulated. Without knowing 
more specifics about the facility in question, it is difficult to provide the impact of the rule revisions.  
Thank you, 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
91 of 106

2
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Friday, January 5, 2024 12:39 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 330/331 Workshop Follow Up 
Hi Hannah. Does below mean that cooling towers are “officially” regulated by MCAQD Rule 330? Thanks Mike Sherer Principal Consultant Trinity Consultants 702 East Osborn Road, Suite 160 | Phoenix, Arizona 85014 Cell: 480-773-5548 Email: msherer@ trinityconsultants. com  
 
Hi Hannah. Does below mean that cooling towers are “officially” regulated by MCAQD Rule 
330? Thanks 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014 
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, January 4, 2024 3:35 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 330/331 Workshop Follow Up 
Hello Mike, 
We have discussed your inquiry regarding cooling towers with PTE >25 tons per year. Although they may have the 
potential to trigger the requirement in Section 301, the proposed language is applicable to actual emissions, prior to 
emission controls, rather than potential emissions. Should the cooling towers meet or exceed the 25 tons per year in 
conjunction with other VOC-emitting activities, the emissions would need to be reduced in accordance with Section 302. 
We added proposed Section 302.4 regarding RACT level controls to allow for the consideration of emission control 
methods and measures other than those listed in Sections 302.1 through 302.3 for unique activities. 
If you would like to discuss further, please let me know and we can set up a time to discuss over Teams. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
92 of 106

3
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, January 2, 2024 12:53 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 330/331 Workshop Follow Up 
Thanks! Mike Sherer Principal Consultant Trinity Consultants 702 East Osborn Road, Suite 160 | Phoenix, Arizona 85014 Cell: 480-773-5548 Email: msherer@ trinityconsultants. com Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants. com  
 
Thanks! 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014 
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, January 2, 2024 12:21 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 330/331 Workshop Follow Up 
Hi Mike, 
Same to you!  
We are still working internally and should have some answers by the end of the week. We got slowed down with the 
holidays and people taking time off. I will email you by end of day Thursday to provide you with an update.  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
93 of 106

4
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, January 2, 2024 12:19 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 330/331 Workshop Follow Up 
Happy New Year! Hope you both had time off. Checking in on below status? Thanks Mike Sherer Principal Consultant Trinity Consultants 702 East Osborn Road, Suite 160 | Phoenix, Arizona 85014 Cell: 480-773-5548 Email: msherer@ trinityconsultants. com  
 
Happy New Year! Hope you both had time off. Checking in on below status? Thanks 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014 
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, December 14, 2023 4:28 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: 330/331 Workshop Follow Up 
Okay thank you for the clarification. We are going to do some further research and get back to you on this. 
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
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
94 of 106

5
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Thursday, December 14, 2023 3:36 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: 330/331 Workshop Follow Up 
Hi Hannah. The cooling towers in question are not considered insignificant activities per Rule 100 Section 200. 63. These are permitted cooling towers and on permit equipment list. Some cooling towers in total in a facility could have PTE VOC  
 
Hi Hannah. The cooling towers in quesƟon are not considered insignificant acƟviƟes per Rule 
100 SecƟon 200.63. These are permiƩed cooling towers and on permit equipment list. Some 
cooling towers in total in a facility could have PTE VOC emissions above 25 tons per year by 
themselves. Thanks for your help! Mike. 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014 
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, December 14, 2023 7:51 AM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: 330/331 Workshop Follow Up 
Good morning Mike, 
I wanted to touch base with you aŌer our discussion at the workshop yesterday. Regarding your comment on cooling 
towers and Rule 330 applicability, would the equipment in quesƟon be considered an insignificant acƟvity per Rule 100 
SecƟon 200.63(s) and/or (t)?  
If there were any other topics you would like to discuss with us, please let me know and we can schedule a virtual 
meeƟng.  
Thank you for your aƩendance yesterday and your conƟnued efforts in the rulemaking process!  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
95 of 106

6
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 
96 of 106

1
From:
Hannah Luke (AQD)
Sent:
Monday, February 26, 2024 8:04 AM
To:
D'Oria, Gary R
Cc:
Kabiri-badr, Leila; Zambrano, Oscar; Gregory Verkamp (AQD)
Subject:
RE: Intel Comments to MCAQD proposed Rule 330, 331, 338 20240223.pdf
Hi Gary, 
Thank you for providing Intel’s comments on Rules 330, 331, and 338. We will begin reviewing internally and get back to 
you shortly with suggested dates/times to meet and discuss further. Please let me know if you have any questions.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: D'Oria, Gary R <gary.r.doria@intel.com>  
Sent: Monday, February 26, 2024 7:49 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Zambrano, Oscar <oscar.zambrano@intel.com> 
Subject: Intel Comments to MCAQD proposed Rule 330, 331, 338 20240223.pdf 
Hannah. Regretfully, I just now realized this didn’t get emailed Friday. . . Please let us know when you’d like to discuss our comments later this week, and perhaps suggest several times that may work on our calendars. Regards, Gary  
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,  
Gary D’Oria 
TD Environmental Engineer 
Intel Corporation | Chandler Campus 
(480) 241-4917
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
97 of 106

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 
98 of 106

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 
99 of 106

1
From:
D'Oria, Gary R <gary.r.doria@intel.com>
Sent:
Tuesday, March 26, 2024 9:40 AM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Kabiri-badr, Leila; Zambrano, Oscar
Subject:
RE: MCAQD Rule 338 Comment 
This Message Is From an External Sender  
This message came from outside your organization. Please use caution when corresponding outside the county.  
Hi Hannah,…after review we’ve found that some of these tools would not comply. We can discuss further when we meet 
today. 
THANKS 
Gary 
From: D'Oria, Gary R  
Sent: Thursday, March 21, 2024 5:06 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  
Hi Hannah, … see below. 
THANKS 
Gary 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, March 21, 2024 3:55 PM 
To: D'Oria, Gary R <gary.r.doria@intel.com> 
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  
Hi Gary,  
Just a couple of questions for you in response to your 3/19/2024 letter: 

Are all the non-solvent cleaning wet plating (aqueous) tools used for R&D operations? YES, Substrates
Packaging Technology Development (SPTD)

Are your batch cleaning machines remote or internal reservoir? Internal Reservoir

Are your batch and in-line cleaning machines able to comply with the equipment requirements in Rule 331?
We’ll review these new 331 requirements for our tool list and reply to early next week.
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
100 of 106

2
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: 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,  
 
Hannah. 
See aƩached second round of comments on the AQD Proposed Rules changes. Looking forward to discussions this 
Thursday. 
Thanks  
Gary 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, March 7, 2024 3:01 PM 
To: D'Oria, Gary R <gary.r.doria@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Rule 338 Comment  
Hi Gary, 
We met with the EPA and were able to discuss Intel’s comment on Rule 338 SecƟon 401.3. The EPA would like addiƟonal 
jusƟficaƟon on the requested Ɵmeframe increase. If possible, please provide supporƟng informaƟon that would 
demonstrate the need for the Ɵmeframe related to modificaƟons to an ECS.  
Would you be able to provide this informaƟon by next Friday 3/15, in addiƟon to the solvent cleaning machine 
equipment details? 
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
101 of 106

3
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
102 of 106

1 
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 
103 of 106

2 
Specifically, Intel’s current estimates from these tools is ~1,300 lbs./year VOCs requiring an 
additional ~10,000 cfm of exhaust connected to an ECS, which could potentially result in an 
additional ~8600 lbs. of NOx per year.  We would like your comments of our analysis showing 
the expansion of the Rule 338 applicability beyond photoresist operations that may now regulate 
many wet plating tools.  These wet plating tools have water content slightly under 95% with 
relatively low VOC emissions but high NOx releases when connected to an ECS.  
Intel utilizes a number of “batch” cleaning machines, some of which use non-conforming 
solvents and are not small enough to be considered small cleaners.  However, it is our 
understanding that rule 331 would not require such machines to be connected to an ECS as 
section 302.c(4) states that a non-conforming solvent may be used if one of conditions “a” 
through “c” are met.  Part “c” of this section exempts certain SIC codes described in section 
103.3 including electronics manufacturing, which is the category Intel fits in.  Based on this it is 
our conclusion that batch cleaning systems would not be required to be connected to an ECS. We 
would appreciate your thoughts on if we’re interpreting this correctly. The Proposed Rule 331 
could appear to require that some in-line cleaning systems be connected to an ECS as section 
302.3 does not include the section 103.3 SIC Code exemption for in-line cleaning machines.  Our 
review of the semiconductor solvent cleaning equipment that use IPA and EtOH and covered by 
this Rule has identified requirements to connect to an ECS. Our estimates show that this could 
result in an additional 5000 cfm of exhaust connected to an ECS, which could potentially result 
in an additional ~2200 lbs. of NOx per year.  Intel’s current estimates of VOCs from these tools 
is < ~10,000 lbs./year, so this rule would result in generating 2200 lbs. NOx to remove this 
quantity of VOCs. 
In a follow-up email from our meeting, it was requested that we provide additional detail on our 
concerns with proposed Rule 338 401.3 timeframes. Our suggested language for 401.3 b. with 
rational follows. 
Within 12 months after the facility becomes subject to the requirements in section 301.1 
of this rule, the owner or operator shall be complete with ECS modifications for any 
existing ECS with existing infrastructure and existing capacity and perform “start-up” 
in accordance with Rule 270. Submittal to the Control Officer of a complete source test 
report indicating compliance shall be provided in the timeframes defined by Rule 270.   
Within 36 months after the facility becomes subject to the requirements in section 301.1 
of this rule, the owner or operator shall be complete with ECS modifications for any new 
ECS requiring new infrastructure and new capacity and perform “start-up” in 
accordance with Rule 270. Submittal to the Control Officer of a complete source test 
report indicating compliance shall be provided in the timeframes defined by Rule 270. 
Any “reconstructing or adding on equipment” is in our experience considered new infrastructure 
and new capacity and would requires 36 months for construction completion. Intel Chandler has 
recently installed VOC Abatement units that can be used as an example of construction 
schedules for reconstruction or addition of equipment. There was a need to expand the VOC 
abatement capacity due to new tools supporting technology development. Intel semiconductor 
construction schedules are some of the most aggressive in the industry due to the time-to-market 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
104 of 106

3 
strategy driving product technology advancements. In this example assume that a “plan of 
record” (POR) ECS is selected. This POR means that ECS supplier selection with contracts in 
place with performance specifications, master design standards, operating specifications and any 
treatability studies needed. Otherwise, this can take an additional 6-9 months to develop an Intel 
POR ECS. A brief example of construction schedules follows. 
•
3-6 Months for Design Positioning / Programing, this may include ductwork design and
layout within the cleanroom.
•
18-30 Months for Design Construction – this may include ductwork design and layout
within the cleanroom and staging of construction to avoid impacts to manufacturing
operations.
We appreciate the opportunity to provide comments to these proposed rules and welcome future 
meetings for guidance and to discuss our concerns and considerations.  
TD Environmental Engineering, Environmental Health & Safety 
Intel Corporation | 5000 W Chandler Blvd  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
105 of 106

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