Maricopa County Air Quality Department 1001 North Central Avenue Phoenix, Arizona Surface Coating A Compliance Perspective Li Sa Kon Source Compliance Division

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Outline Various Rules Common Denominators Record Keeping Common Violations Common Complaints Low Usage Coating vs Small Surface Coating Source Formula – As Applied, Mix Ratio Contact Information

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Rules Associated with Surface Coating 1.Rule 335 Architectural Coatings 2.Rule 336 Surface Coating Operations 3.Rule 337 Graphic Arts 4.Rule 342 Coating Wood Furniture and Fixtures 5.Rule 345 Vehicle and Mobile Equipment Coating 6.Rule 346 Coating Wood Millwork 7.Rule 348 Aerospace Manufacturing & Rework Operations A)Rule 315 Spray Coating Operations applicable to any facility who conducts spray coating operation – enclosures and spray directions B)Rule 330 Volatile Organic Compounds applicable to any facility that does not fit into any of the 7 listed operations

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Common Denominators. See Chart 1 VOC Content Limits Application Method Cleanup of Application Equipment Handling and Disposal of VOC Filter Capture Efficiency Monitoring and Records Schedule for Recording Material Usage ECS as an alternative control to meet applicable provisions to rule when VOC content exceeds applicable VOC limits

Rule 335Rule 337Rule 342Rule 345Rule 346Rule 348 Architectural CoatingGraphic ArtsCoating Wood Furniture & Fixtures Vehicle &Mobile Refinishing Coating Wood MillworkAerospace VOC Content Limits for Coatings Refer to Sections 303, 304, 305 (Flat, Non-Flat, Specialty) Ink, adhesives, varnishes,coatings VOC</=2.5#/gal See Section 306 for exemption Refer to Table 1 in Rule; appendices, A, B, or C where applicable Table I, 2 3 in Rule- depending on types of vehicle +surf types. Refer to applicable sections for VOC limits Refer to applicable sections for VOC limits. Application MethodNot Applicable N/A Depending on printing process-lithographic, flexographic, screen printing etc. Coatings >/=1#/gal? If Yes, HVLP spray syst or Electrostatic or Airless or proof of transfer efficiency >/=64% Coatings >/=3#VOC/gal? If Yes Choice of: HVLP spray syst Electrostatic Airless, Air Assisted Tagged Spray gun when necessary, depending on types of sealer or coating used. Use of restricted guns- record keeping necessary Transfer efficiency - at least 65%. Cleanup of Application Equipment See Rule if conducted at facility All solvent used for cleaning must be drained into non leaking containers, + to be kept closed except when in use. Auto or manual, lids must be kept covered when not in use, reservoir must be leak free, & maintained per mfgr’s requirement. Solvent to be contained in non leaked containers, closed at all times except when in use VOC Handling &Disposal of VOC See Rule 330 To be covered in legible labeled + leak free containers at all times To be covered in legible labeled + leak free containers at all times. Disposal/Recovery of all VOC containing material. To be covered in legible labeled + leak free containers at all times To be covered in legible labeled + leak free containers at all times except when in use. Rec. on disposal + recovery of all VOC containing material. Transfer process in place for transfer + disposal.. To be covered in legible labeled + leak free containers at all times except when in use. Rec. on disposal + recovery of all VOC containing material Spray Booth Requirement N/A See Rule w. force air exhaust- filtration system >/=92% capture efficiency or in a 3 sided, min 8 ft ht enclosure Monitoring & Records If no permit is required, refer to Rules. Always refer to permit conditions first. {filter capture efficiency, maintain list of VOC containing material, suppliers’ mix/blend ratio, purchase record, annual usage, temperature of fountain solution, vapor pressure, monthly inspection of leak on spray gun cleaner enclosure. Schedule for Recording Material Usage If no permit is required, refer to Rules. Always refer to permit conditions first. Monthly update records of each coating used per Rule’s respective Table/s. Daily update usage of each coating that exceeds limits in Table. Daily updates for non compliant material; VOC content shall be entered for each such material. Emission Control System An alternative control to meet applicable provisions to Rule when VOC content exceeds applicable VOC limits Chart 1: Common Denominators

Rule 336Rule 330 Surface CoatingVolatile Organic Compounds VOC Content Limits for Coatings Refer to Table 1 in RuleComplying versus Non-Complying Solvents. Refer to Section Application MethodCoatings >2#VOC/gal? If Yes Choice of HVLP spray system, Electrostatic, Airless, Non spraying or Proof of transfer efficiency of >/=65% Not Applicable Cleanup of Application Equipment Commercial cleaning machine or disassemble and clean See Section 305 VOC Handling & Disposal of VOC To be covered in legible labeled + leak free containers at all times Spray Booth requirementSee Rule 315 Monitoring &RecordsIf no permit is required, refer to Rules. Always refer to permit conditions first. {filter capture efficiency, maintain list of VOC containing material, suppliers’ mix/blend ratio, purchase record, annual usage, temperature of fountain solution, vapor pressure, monthly inspection of leak on spray gun cleaner enclosure. Schedule for Recording Material If no permit is required, refer to Rules. Always refer to permit conditions first. Monthly update records of each coating used per Rule’s respective Table/s. Daily update usage of each coating that exceeds limits in Table. Daily updates for non compliant material; VOC content shall be entered for each such material. Emission Control SystemAn alternative control to meet applicable provisions to Rule when VOC content exceeds applicable VOC limits Chart 2: Common Denominators

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Diligent Record keeping – a compliance issue Establish, and maintain records on usage amount, VOC content & manufacturer’s recommended mix ratio of : Coating Catalyst Hardener Solvent Reducer Drying accelerator Thinner Diluents and its effect! “As Applied”

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Common Violations On Site 1. Uncovered VOC containing material *Open virgin coatings and solvents *Open waste coating and solvents *Used rags *Others: stir sticks, spent paper filters, spatulas (find VOC containing material mixed in with garbage) 2. Permit not on site 3. Insufficient/Poor Record keeping *Usage records-daily, monthly, semi annual *Absence of Product Data Sheets various coatings and solvents on site *Records on mix ratios; types of reducers use on site, season dependent *Filter capture efficiency 4. Exceed VOC limits as applied Safety concern- spontaneous combustion

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Common claims/Misinterpretation : “ I don’t use too much” What is too much? “Hardly use more than a gallon a day” Hardly? I need proof Gallon? NOT just paint! “I was told if I use less than a gallon a day, I don’t need a permit” One may not need a permit, but one is still required to operate by the Rules “I am a Low Usage Facility” “I am a Small Source” Commonly used interchangeably

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Low Usage Coating Versus Small Surface Coating Source {Exception to Rules} Low Usage Coating Aggregate of all formulations which do not exceed 55 gallons per year facility wide if operator updates usage record of these coatings on each day of their use, and records of coatings use shall be updated by the end of the following month. Small Surface Coating Source Total VOC emissions for all surface coating operations that are subject to surface coating rule without or prior to any emission control, is less than 15#/day or less than 2 tons per year. …..as demonstrated by both adequate records of coatings and diluent use and a separate tally of the number of days each month that such coating operation occur.

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona The coating as mixed & applied must meet the applicable VOC limit VOC CONTENT OF MATERIAL: W s – W w – W es V m W s = weight of all volatile material in pounds or grams including VOC, water, non- precursor organic compounds and dissolved vapors W w = weight of water in pounds or grams W es = weight of all non precursor compounds in pounds or grams V m = volume of total material in gallons (liters)

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona PER Rule 345. VOC Limits For Refinishing Coatings As Applied Minus Exempt Compounds Coating CategoryPounds VOC per gallon Primers/Primer Surfacers 4.8 Per M.S.D.S from XYZ Primer VOC lbs/gal:= 3.43 My vendor is great. They always supply me with compliant material Is the primer going to be mixed with some type of reducer before it gets sprayed onto the surface? Did the supplier provide you with a suggested mix ratio? What is the VOC content of the reducer? VOC content changes each time a VOC containing material is added to the primer, basecoat, clear coat, etc

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Use of Mix ratio to Determine Allowable VOC Spot jobs 4:1(Basecoat:reducer) 4:1:1(clearcoat:hardener:reducer) Ex: 1. Primer: Reducer (1:1 ratio) Per MSDS, Primer VOC lbs/gal:=3.43; Per MSDS, Reducer VOC lbs/gal= =5.03lbs/gal Ex: 2. Clearcoat:Hardener:Reducer (4:1:1) Per MSDS, Clearcoat VOC lbs/gal=4.64; Per MSDS, Hardener VOC lbs/gal=3.41 Per MSDS, Reducer VOC lbs/gal=4.00 Note total of gallons: 6 4 (4.64lbs/gal) lbs/gal lbs/gal = = = 4.33lbs/gal OUT of Compliance

Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona Contact Information Li Sa Kon, presenter County Website: County Complaint Hotline: Rule Number and Title Date Adopted Rule Description Technical Guidance Stationary Source Compliance Supervisors: Janet Darcey Afam Ugbor Business Resource Division: Dale Lieb Jess Lotwala