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Tech Sheets: Rule 345

What is Rule 345?

1. Surface Prep & Cleaning - Wax & Grease Removers

  • Diamont RM-909, “Final Wipe”, has a VOC content of 1.31 lbs/gal and meets the requirement of 1.4 lbs/gal.

2. Strippable Booth Coatings

  • Maximum of 3.5 lbs/gal.

3. HVLP Spray Equipment

  • Undercoats and Topcoats
  • Suggestions - To maximize efficiency, use HVLP booth, hose and paint gun regulators and couplers to increase volume. Use swivels to ease operation.

4. Gun Washers

  • Enclosed, such as Herkules or Gun Butler
  • Safety Kleen

NOTE: All solvents are to be kept in closed containers.

5. Enclosed Waste Storage

  • This includes all paint cans, waste coatings, solvents and their residue, and rags.
  • Must be clearly marked.
  • Funnels with lids on drums.
  • Flammable Storage Cabinets.

6. Record Keeping

  • MSDS must be currently maintained and accessible.
  • Receipts of purchases of products that contain VOCs.
  • Records shall be maintained for 3 years.

MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III - CONTROL OF AIR CONTAMINANTS
Adopted 02/15/95
RULE 345

VEHICLE REFINISHINGSECTION 100 - GENERAL

101 PURPOSE: To limit emissions of volatile organic compounds (VOCs) from the surface preparation and coating of automotive vehicles.

102 APPLICABILITY: The provisions of this rule apply to body shops, collision repair shops and to any person or facility in Maricopa County recoating previously paint-finished vehicles or parts of vehicles. This includes cars, large and small trucks, recreational and off-road vehicles of all types including, but not limited to, self-propelled movers of earth and/or materials. the refinishing of any machinery or wheeled trailer that is designed to be able to move or be towed on a highway is also included.

SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definitions shall apply:

201 AUTOMATIC GUN-CLEANING MACHINE (GUN CLEANER) - A machine which after being loaded, cleans paint spray-guns without the assistance of a person.

202 COATING AS APPLIED - Refers to coating at the time immediately prior to its application including any final addition of solvent to the coating before such coating is applied.

203 CONVENTIONAL AIR ATOMIZED SPRAY (SYSTEM) - A spray which is atomized with air in a system designed to exceed 25 psig (1.7 Bar) at the center of the spray-gun tip and which is not used with an electrostatic transfer system.

204 DAY - A period of 24 consecutive hours beginning at midnight.

205 DEPARTMENT - The Maricopa County Environmental Service Department.

206 DETAILING GUNS AND TOUCH-UP GUNS - Small air spray devices, including air brushes, that operate at no greater than 6 cfm (170 liters per minute) air flow and no greater than 50 psig (3.4 Bar) air pressure and are used to coat small areas.

207 DILUENT - For the purposes of this rule, any fluid in or added to a coating such as thinner, retarder, reducer, solvent, or drying accelerator which solubilizes, adjusts concentration, viscosity, flow, or drying rates and which evaporates as the coating film solidifies and cures.

208 ELECTROSTATIC APPLICATION - A method of applying coating by electrically charging coating droplets or particles with an electrical device, causing their deposition onto a substrate by electrostatic attraction.

209 FACILITY - All the pollutant-emitting activities which belong to the same industrial grouping, located on one or more contiguous or adjacent properties, and under the control of the same person or persons under common control.

210 HIGH-VOLUME LOW PRESSURE (HVLP) APPLICATION - A type of coating spray system in which the final air pressure does not exceed 10 psig (67 kilopascals) and which depends on relatively large volumes of air to atomize the coating.

211 LOW PRESSURE GUN - An air atomized spray gun which by design functions best at tip pressures below 10 psig (0.7 bar) measured according to Section 502.3, and for which the manufacturer makes no written claims that the gun can be used effectively above 12 psig (0.8 bar).

212 NON-PRECURSOR ORGANIC COMPOUND - Any of the following organic compounds which have been designated by the EPA as having negligible photochemical reactivity: methane; ethane; methylene chloride (dichloromethane); 1,1,1-trichloroethane; trichlorofluoromethane (CFC-11); dichlorodifluoromethane (CFC-12); chlorodifluoromethane (HCFC-22); 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113); 1,2-dichlorotetrafluoroethane (CFC-114); chloropentafluoroethane (CFC-115); trifluoromethane (HFC-23); 2,2- dichloro-1,1,1-trifluoroethane (HCFC-123); 2-chloro-1,1,1,2- tetrafluoroethane (HFC-134); 1,1,1,2-tetrafluoroethane (HFC-134a); 1,1,1-trifluoroethane (HFC-143a); 1,1-difluoroethane (HFC-152a); parachlorobenzotrifluoride (PCBTF); all completely fluorinated, completely saturated: alkanes, ethers and tertiary amines; all perfluorinated sulfur compounds having no hydrogen, with sulfur bonds to carbon and hydrogen only; cyclic, branched, or linear completely methylated soloxanes.

213 PERSON - Any individual, public or private corporation, company, partnership, firm, association or society or persons, the Federal government and any of its departments or agencies, or the State and any of its agencies, departments or political subdivisions.

214 POUNDS OF VOC PER GALLON OF COATING LESS WATER AND LESS NON-PRECURSOR COMPOUNDS - The mass of VOC per combined volume of VOC-plus-coating-solids before coating application, which can be calculated by the following equation:

Pounds of VOC per Gallon of Coating = Ws-Ww-Wes
Less Water and Less Non-Precursor Compounds Vs-Vw-Ves
Where: Ws = weight of volatile material in pounds
Ww = weight of water in pounds
Wes = weight of non-precursors in pounds
Vs = volume of total material in pounds
Vw = volume of water in pounds
Ves = volume of non-precursor compounds in pounds

215 SURFACE COATING - Any liquid, fluid, or mastic composition which is converted to a solid (or semi-solid) protective, decorative, or adherent film or deposit after application as a thin layer.

216 SURFACE PREPARATION AND SURFACE CLEANING FLUIDS - Fluids that are used to prepare a surface for further operations by aiding the removal of grime, greases, waxes, unwanted deposits and embedded particles from the surface.

217 STRIPPERS - Powerful solvents used to dissolve permanent, cured coatings, usually to attain a bare substrate.

218 TOUCH UP COATING - A coating used to cover minor coating imperfections after the main coating operation.

219 VEHICLE REFINISHING OPERATION - For the purposes of this rule, any coating of vehicles or mobile equipment, their parts and components, including partial body collision repairs, for the purpose of protection, restoration or beautification, and which is subsequent to the original coating applied at a coating assembly line at on Original Equipment Manufacturing (OEM) plant.

220 VOLATILE ORGANIC COMPOUND (VOC) - Any organic compound except non-precursor organic compounds.

SECTION 300 - STANDARDS

301 LIMITATIONS - VOC CONTENT OF CLEANERS AND BOOTH COATINGS:

301.1 Vehicle Surface-Preparation and Surface-Cleaning Fluids:
a. Shall not be applied by means of motor-compressed air if applied in a mist (finely atomized) spray.
b. Shall contain no more than 1.4 pounds of VOC per gallon as determined by methods set forth in Subsections 502.1 and 502.2.
301.2 Strippable Booth Coatings: Strippable material that is applied as a coating shall contain less than 420 grams VOC per liter (3.5 lb. VOC/gal) of solids as applied, less water and non-precursor compounds.
302 MAINTENANCE - Any person subject to this rule shall operate and maintain in proper working order all production and cleaning equipment in which VOC-containing materials are used or stored.
303 PAINT GUN REQUIREMENTS AND LIMITS:
303.1 Evidence of Transfer-Efficient Equipment: Any person subject to this rule shall provide evidence of possession and use of: a low pressure gun, a principally airless system, or an electrostatic system.
303.2 Limitation of Conventional Air-Atomized Spray Guns: No person shall use a conventional air-atomized spray gun nor any air- atomized spray gun in excess of 12 psig (0.8 Bar) or which the manufacturer in writing specifies can be used effectively above 12 psig, except that conventional and other types of guns operating above 12 psig may be used:
a. For applying materials that have a VOC content not exceeding 3.0 lb. VOC/gal (360 g/l) as applied, less water and non-precursor compounds.
b. If such guns are designed and used solely for detailing and touch-up with a maximum reservoir capacity of 250 cc (8.8 fluid ounces).
c. If such guns are used to apply adhesives.

304 CLEANUP AND CLEANING SUPPLY AND APPLICATION EQUIPMENT:

304.1 All solvent used to manually clean spray guns shall be collected into a container which shall be immediately closed after all the solvent has been collected.
304.2 All solvent used for line cleaning shall be pumped or drained into a container kept closed when not in use.
304.3 Tanks used for stripping off coating or for cleaning objects shall be covered when not in use. Solvent-dragout shall be minimized by tilting or rotating the object to drain off any pools of solvent before removing the object from above the tank.

305 GUN CLEANING MACHINES:

305.1 Any person subject to this rule shall use a paint-gun cleaning machine to clean paint guns if the vehicle refinishing operation is not de minimis as defined by Section 200, 303.3, c.(a), Maricopa County Air Pollution Control Rules, and is therefore required to have an Air Pollution Permit. Manual cleaning outside of the cleaning machine is allowed if done as an adjunct to the cleaning machine function and if done without spraying cleaning solvent with the gun.
305.2 General Requirements For Gun Cleaning Machines: The gun- cleaning machine shall:
a. Be designed to clean paint-guns and be kept in proper repair and free from liquid leaks.
b. Have at least one pump which drives cleaning solvent through and over the gun, and a basin which permits containment of the cleaning solvent.
c. Have all covers and other surfaces that are exposed to gaseous or liquid VOC-solvent be impervious to both gaseous and liquid VOC-solvent.
305.3 Specific Requirements For Automatic Cleaning Machines And For Non-Automatic Remote Reservoir Cleaning Machines
a. Automatic Gun-Cleaning Machine:
1. Shall be self-covering or enclosing when not loading or unloading.
2. The machine shall have a self-closing cover or other self-enclosing feature which in the cover’s closed position allows no gaps exceeding 1/8 inch (3mm) width between the cover and the cabinet.
3. The machine shall be designed to prevent operation of its mechanical cleaning feature(s) unless it is completely covered or enclosed to the gap limits specified in the preceding Paragraph (2).
b. Non-Automatic Remote Reservoir Gun-Cleaning Machine:
1. The cleaning machine shall be designed such that cleaning solvent drains from the sink/work space quickly and completely into a remote reservoir when the work space is not in use.
2. The reservoir shall have the ability to contain VOC vapors and shall not have a cumulative total opening, including the drain opening(s), allowing VOC-escape to the atmosphere exceeding two square inches in area.
3. Machine designs are allowed in which the base of the sink/workspace functions as the reservoir’s top surface, as long as the fit/seal between sink base and reservoir container allows the reservoir to meet the opening limits specified in the preceding Paragraph (2).

306 STORAGE AND DISPOSAL OF VOC AND VOC-CONTAINING MATERIAL:
Any person subject to this rule shall store all VOC-containing materials, including but not limited to waste coatings, waste solvents and their residues, and rags in closed containers which are legibly labeled with their contents and which remain covered when not in use. Such person shall keep records of disposal/recovery of VOC-containing materials. Records kept in accordance with applicable federal and state hazardous waste disposal statutes and rules will suffice for this purpose. However, nothing in this provision shall relieve a person from complying wit the recordkeeping requirements of applicable federal, state, and local hazardous waste disposal statutes and rules.

307 EXEMPTIONS:

307.1 Exemptions from Other Rules: Maricopa county Air Pollution Rules and Regulations Rules 330 and 336 do not apply to any vehicle refinishing operation to which this Rule 345 is applicable.
307.2 Formal Vehicle Refinishing Training:
a. An accredited school is exempt from the recordkeeping and reporting provisions of Section 501.
b. A student in classes at an accredited school which teaches vehicle refinishing is exempt from this rule.

SECTION 400 - ADMINISTRATIVE REQUIREMENTS

401 COMPLIANCE SCHEDULE: This rule takes effect November 15, 1995.

402 THE RESPONSIBILITIES OF LARGE USERS:

402.1 The owner or operator of a facility which emits 10,000 pounds or more of VOC in any calendar year must submit a report of such emissions on a form supplied by the Department after the end of the calendar year.
402.2 An owner or operator of a facility which in a calendar year meets or exceeds any of the following quantities must notify the Control Officer of this fact in writing by February 8 (within two months) after the end of that calendar year:
a. Used a total of 1,000 gallons (3,793 l) of coating (with reducer and hardener); or
b. Received a total of 1,000 gallons of cleaning solvent, lacquer thinner and wash-thinner; or
c. Disposed of more than 1,000 gallons or 6,000 pounds (2,722 kg) to hazardous waste collection; or
d. Submitted a total exceeding 9,000 pounds of VOC in the facility’s most recently completed Maricopa County annual air-emission inventory form.
402.3 The Control Officer may require in writing a report of annual emissions from a facility which has given notification as required by the preceding Subsection 402.2, or from any other facility which in the Control Officer’s determination can have annually emitted 5 tons (4,536 kg) or more of VOC.

SECTION 500 - MONITORING AND RECORDS 501 RECORDKEEPING AND REPORTING: Any person subject to this rule shall keep the records required under this Section 501 in a consistent and complete manner and shall make them available to the Control Officer without delay during normal business hours.
501.1 Responsibility For Products In Use: An owner or operator shall maintain written records in the facility which give the name or code number of each VOC-containing product and its VOC content as received. VOC content shall be expressed in pounds of VOC per gallon (or grams/liter), less water and non-precursors, excepting waterborne cleaners which shall include the water.
a. Examples of what to include: All coating components as received from the supplier, before any in-house blending, such as coating base and tint base for topcoats, midcoats, primers, specialty coatings, sealers, and strippable booth coating; other coating components such as hardeners, catalysts, reducers, promoters, inhibitors and other coating additives; and stripper, wash-thinner, lacquer thinner, gun cleaning solvent, surface prep cleaners and other cleaners including waterborne cleaners which contain some VOC.
b. Sufficient documentation: Any combination of the following may be used to meet the requirements of Subsection
501.1 as long as all VOC-containing refinishing products are accounted for as directed by 501.1:
1. An up-to-date hardcopy (in writing) list prepared for that facility.
2. Current material safety data sheets (MSDS) showing the VOC content.
3. Purchase documentation that gives VOC content, such as invoices and/or receipts showing VOC content.
4. Current, dated manufacturers publications such as charts or lists which show VOC content, with the products used in the facility highlighted or otherwise clearly marked.
501.2 Documentation Of Purchases: Purchase records showing the volume of each VOC-containing refinishing-related product purchased shall be kept available for the current and the previous year. Actual invoices and receipts showing the volume of the material purchased will suffice in place of ledger-style records.
501.3 Record Retention: Records shall be retained for three years.

502 COMPLIANCE DETERMINATION - TEST METHODS:

502.1 Measurement of VOC content of materials subject to this rule, including the requirements of Section 301 shall be conducted and reported in accordance with EPA Test Method 24 (40 CFR 60, Appendix A).
502.2 Measurement of the VOC content of cleaning fluids, including those cleaners limited by Section 301.1b of this rule, shall put the entire volume of the sample in the denominator, e.g. including water, non-precursors, and all solutes, and be performed and reported in accordance with EPA Test Method 24 (40 CFR 60, Appendix A) and its applicable submethods.
502.3 With reference to Sections 303.1 and 303.2, measurement of air pressure at the tip of an air atomized paint spray gun that atomizes shall be performed using a device supplied by the gun’s manufacturer for that purpose. The measurement shall be made dynamically at the center of the air cap and at the air horns with the spray configured to a fan diameter of eight to ten inches on a flat surface being coated. The axis of the fan pattern shall be perpendicular to this surface.

 

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