Maricopa County Air Quality Department

1. Maricopa County Air Quality Department 1001 North Central Avenue Phoenix, Arizona 85004 Surface Coating A Compliance Perspective Li Sa Kon Source Compliance Division

2. 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 85004

3. Rules Associated with Surface Coating • Rule 335 Architectural Coatings • Rule 336 Surface Coating Operations • Rule 337 Graphic Arts • Rule 342 Coating Wood Furniture and Fixtures • Rule 345 Vehicle and Mobile Equipment Coating • Rule 346 Coating Wood Millwork • Rule 348 Aerospace Manufacturing & Rework Operations • Rule 315 Spray Coating Operations • applicable to any facility who conducts spray coating operation – enclosures and spray directions • 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 85004

4. 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 Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona 85004

5. Chart 1: Common Denominators

6. Chart 2: Common Denominators

7. 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 85004

8. 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 85004

9. 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 85004

10. Low Usage CoatingVersusSmall 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 85004

11. The coating as mixed & applied must meet the applicable VOC limit VOC CONTENT OF MATERIAL: Ws – Ww – Wes Vm 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 compounds in pounds or grams Vm = volume of total material in gallons (liters) Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona 85004

12. PER Rule 345. VOC Limits For Refinishing Coatings As Applied Minus Exempt Compounds Coating Category Pounds VOC per gallon Primers/Primer Surfacers 4.8 My vendor is great. They always supply me with compliant material Per M.S.D.S from XYZ Primer VOC lbs/gal:= 3.43 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 85004

13. 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=6.64 3.43 + 6.64 2 =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) + 3.41 lbs/gal + 4.00 lbs/gal =18.56 + 3.41 + 4.00 6 = 25.97 6 = 4.33lbs/gal OUT of Compliance Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona 85004

14. Contact Information • Li Sa Kon, presenter • County Website: http://www.maricopa.gov • County Complaint Hotline: 602-372-2703 • http://www.maricopa.gov/aq/divisions/planning_analysis • Rule Number and Title • Date Adopted • Rule Description • Technical Guidance • Stationary Source Compliance Supervisors: • Janet Darcey • 602-506-3617 • Afam Ugbor • 602-506-6740 • Business Resource Division: • Dale Lieb • 602-506-6738 • Jess Lotwala • 602-506-6735 Maricopa County Air Quality Department 1001 North Central Avenue, Phoenix, Arizona 85004