Mich. Admin. Code R. 336.1610a

Current through Vol. 24-09, June 1, 2024

Section R. 336.1610a - Existing coating lines; emission of volatile organic compounds from existing automobile, light-duty truck; and paper, film, and foil; cans, coils, and fabrics; insulation of magnet wire; metal furniture coating lines in 2015 ozone nonattainment areas

Rule 610a.

(1) As used in this rule:

(a) "Automobile" means a motor vehicle designed to carry up to 8 passengers. Automobile does not include vans, sport utility vehicles, or motor vehicles designed primarily to transport light loads of property.

(b) "Coatings of paper, film, and foil" means materials applied onto or impregnated into a substrate for decorative, protective, or functional purposes, including, but not limited to, solvent-borne coatings, water-borne coatings, adhesives, wax coatings, wax laminations, extrusion laminations, 100% solid adhesives, UV cured coatings, electron beam cured coatings, hot melt coatings, and cold seal coatings.

(c) "Occurrence" means the application of the combination of coatings that constitute a final repair coat for a single automobile or light-duty truck.

(2) Except as provided in subrule (3) of this rule, the provisions of this rule apply to a person causing or allowing the emission of any volatile organic compound from the following existing coating lines at a facility located in the 2015 ozone nonattainment areas:

(a) Automobile and light-duty truck assembly coatings product category, as defined in R 336.1103.

(b) The coating of bodies or body parts, or both, for new heavier vehicles at an automobile and light-duty truck assembly facility or a heavier vehicle assembly facility, that meets the applicability requirements of R 336.1621a and has elected to comply with the requirements of this rule instead of the requirements of R 336.1621a.

(c) Metal furniture coating operations.

(d) Paper, film, and foil surface coating operations.

(3) The provisions of this rule, as specified, do not apply to the following:

(a) With the exception of the requirements in subrule (6) of this rule, the following coating lines at a stationary source that have a combined actual emission rate of volatile organic compounds, including related cleaning activities, of less than 15 pounds per calendar day before consideration of controls. If the combined actual emission rate equals or is more than 15 pounds per calendar day for a subsequent day, then this rule permanently applies to these coating lines:

(i) Automobile and light-duty truck assembly coating lines that are within an automobile and light-duty truck assembly facility.

(ii) Metal furniture coating lines at a stationary source.

(iii) Cans, coils, fabrics, and insulation of magnet wire coating lines at a stationary source.

(b) With the exception of the requirements in subrule (6) of this rule, low-use coatings that have a combined total of less than 55 gallons per rolling 12-month period at a stationary source.

(c) Automobile and light-duty truck coatings used at plastic or composites molding facilities.

(d) The limits in table 64-a of this rule do not apply to automobile and light-duty truck coating materials that are supplied in containers with a net volume of 16 ounces or less, or a net weight of 1 pound or less.

(e) The coating of metallic surfaces that are subject to R 336.1621 or R 336.1621a.

(f) With the exception of the requirements in subrules (5) and (6) of this rule, paper, film, and foil surface coating lines within a stationary source that have a potential to emit less than 25 tons per year of volatile organic compounds before controls. If the potential to emit equals or is more than 25 tons per year of volatile organic compounds from paper, film, and foil coatings for a subsequent year, then this rule permanently applies to the paper, film, and foil surface coating lines.

(g) Facilities subject to R 336.1624 or R 336.1635.

(h) Coatings performed on, in, or off-line with any screen or digital printing press.

(i) Size presses and on-machine coaters on paper making machines applying sizing or water-based clays.

(j) Paper, film, or foil materials used to form unsupported substrates, such as calendaring of vinyl, blown film, cast film, extruded film, and co-extruded film.

(k) Coatings performed at research and development or prototype facilities.

(4) A person subject to this rule shall not cause or allow the emission of any volatile organic compound, unless the following provisions are met:

(a) An automobile and light-duty truck coating facility must not cause or allow the emission of volatile organic compounds from the coating of automobiles and light-duty trucks or miscellaneous materials, as outlined within table 64-a, from any existing coating line as defined in R 336.1103, in excess of the applicable emission rates shown in table 64-a.

(b) A person subject to this rule shall not cause or allow the emission of volatile organic compounds from the coating of metal furniture, from an existing coating line, in excess of the applicable emission rate as shown in column A of table 64-b or the equivalent emission rates in column B of table 64-b.

(c) A person subject to this rule shall meet an overall volatile organic compound control efficiency of 90% for each existing coating line at a paper, film, and foil stationary source. Alternatively, a person shall not cause or allow the emission of volatile organic compounds from the coating of paper, film, and foil, from an existing coating line, in excess of the applicable emission rate as shown in column A of table 64-d or the equivalent emission rates in column B of table 64-d.

(d) For each coating line, compliance with the emission limits specified in table 64-a, table 64-b, and table 64-d is based upon all of the following provisions:

(i) For prime coat operations that utilize an electrodeposition process in automobile and light-duty truck coating lines that are regulated under table 64-a, compliance is based on all coatings that belong to the same coating category that is used during each calendar month averaging period. For all other coatings, compliance is based on the volume-weighted average of all coatings that belong to the same coating category and are used during each calendar day averaging period. Under R 336.1602(2), the department may specifically authorize compliance to be based on a longer averaging period, not to exceed more than 1 calendar month.

(ii) If coatings that belong to more than 1 coating category are used on the same coating line during the specified averaging period, then compliance is determined separately for each coating category.

(iii) The information and records as required by subrule (5) of this rule.

(e) Compliance with the emission limits specified in this rule must be determined using the applicable method described in the following paragraphs:

(i) For the prime-electrodeposition process emission limit specified in table 64-a, the method described in either R 336.2040(12)(a) if the coating line does not have an add-on emissions control device or R 336.2040(12)(b) if the coating line has 1 or more add-on emissions control devices.

(ii) For the primer surfacer, topcoat, and combined primer surfacer and topcoat coating category emission limits specified in table 64-a, compliance must be determined by the methodology described in the publication entitled "Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-duty Truck Topcoat Operations," EPA-453/R-08-002, adopted by reference in R 336.1902. References to topcoat operations in this publication also apply to primer surfacer lines, with the following added provisions:

(A) Unless specifically included in the adopted publication, if an anti-chip, color-in-prime, blackout, or spot primer coating is applied as part of either a primer surfacer or topcoat coating operation, then the anti-chip, color-in-prime, blackout, or spot primer coating is included in the transfer efficiency tests for that coating operation, conducted according to section 18 or 19 of the adopted publication, and the transfer efficiency values in section 20 of the adopted publication must not be used.

(B) When spot primer is applied as part of a primer surfacer coating operation, then the daily usage of spot primer, as calculated in section 8 of the adopted publication, may be derived from monthly usage of spot primer based upon the number of vehicles processed in the primer surfacer operation each day. If an add-on emissions control device is used on the coating line application area to achieve compliance with the primer surfacer or topcoat emission limits specified in table 64-a, then the capture efficiency must be determined in accordance with R 336.2040(10).

(iii) For the final repair coating category emission limit specified in table 64-a, compliance must be on an occurrence weighted average basis, calculated in accordance with the following equation, in which clear coatings have a weighting factor of 2 and all other coatings have a weighting factor of 1:

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Where:

VOC_tot = Total volatile organic compound content of all coating, as applied, on an occurrence weighted average basis, and used to determine compliance with this paragraph.

i = subscript denoting a specific coating applied.

n = Total number of coatings applied in the final repair operation, other than clear coatings

VOC_cc = The volatile organic compound content, as applied, of the clear coat used in the final repair operation.

VOC_i = The volatile organic compound content of each coating used in the final repair operation, as applied, other than clear coatings.

(iv) For determining the volatile organic compounds content of coatings, other than reactive adhesives, used at automobile and light-duty truck coating assembly facilities specified in table 64-a, compliance must be determined in accordance with R 336.2040(5).

(v) For determining the volatile organic compounds content of reactive adhesives used at automobile and light-duty truck coating assembly facilities, specified in table 64-a, compliance must be determined by the procedure described in appendix A of 40 CFR part 63 , subpart PPPP, adopted by reference in R 336.1902.

(vi) As an alternative for the compliance methods in paragraphs (iv) and (v) of this subdivision, automobile and light-duty truck coating assembly facilities may use the manufacturer's formulation data. If there is a disagreement between the manufacturer's formulation data and the results of a subsequent test, the department shall use the test method results unless the facility can make a determination approved by the department that the manufacturer's formulation data are correct.

(vii) For the emission limits specified in column A of table 64-b, table 64-c, and table 64-d, the method described in either R 336.2040(12)(a) if the coating line does not have an add-on emissions control device or R 336.2040(12)(b) if the coating line has 1 or more add-on emissions control devices, or an alternative method as approved by the department under R 336.1602(2).

(viii) For the emission limits specified in column B of table 64-b and table 64-d, the method described in either R 336.2040(12)(e) if the coating line does not have an add-on emissions control device or R 336.2040(12)(f) if the coating line has 1 or more add-on emissions control devices.

(f) A person responsible for the following coating lines shall make a determination of compliance with these emission limits using the method specified in subrule (3)(e) of this rule and submit a copy of this determination and supporting data to the department by the following specified date, as applicable:

(i) For primer surfacer and topcoat coating lines, no later than 6 months after the effective date of this rule.

(ii) Metal furniture coating lines that are subject to the equivalent emission rates in column B of table 64-b, no later than 6 months after the effective date of this rule.

TABLE 64-a

Volatile organic compound emission limits for existing automobile and light-duty truck coating lines and miscellaneous materials used at automobile and light-duty truck assembly coating facilities.

Coating Category	VOC Emission Limit
Prime-electrodeposition process (EDP) (including application area, spray/rinse stations, and curing oven)	When solids turnover ratio (R_T)>=0.16:	When 0.040<=R_T<=0.160:	When R_T<=0.040:
	0.7¹	(0.084 x 350^0.160-RT x 8.34)¹	No VOC emission limit.
Primer surfacer⁴ (including application area, flash-off area, and oven)	12.0²
Topcoat (including application area, flash-off area, and oven)	12.0²
Final repair operations	4.8³
Combined primer-surfacer and topcoat	12.0²
Miscellaneous Materials Used at Automobile and Light-Duty Truck Assembly Coating Facilities
Coating Category	lb VOC/gal coating (minus water, as applied)		g VOC/L of coating (minus water and exempt compounds, as applied)
Glass Bonding Primer⁵	7.5³		900
Adhesive⁵	2.1³		250
Cavity Wax⁵	5.4³		650
Sealer⁵	5.4³		650
Deadener⁵	5.4³		650
Gasket/Gasket sealing material⁵	1.7³		200
Underbody Coating⁵	5.4³		650
Trunk interior coating⁵	5.4³		650
Bedliner⁵	1.7³		200
Weatherstrip adhesive⁵	6.3³		750
Lubricating wax/compound⁵	5.8³		700

¹ Pounds of volatile organic compounds per gallon of applied coating solids.

² Pounds of volatile organic compounds per gallon of applied coating solids on a daily weighted average basis as determined by following the procedures in the "Protocol for determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Topcoat Operations" (EPA-453/R-08-002).

³ Pounds of volatile organic compounds per gallon of coating, minus water, as applied.

⁴ The primer surfacer or topcoat coating category would include an anti-chip, blackout, or spot primer coating if this coating is applied as part of the primer surfacer or topcoat coating operation.

⁵ VOC emission limits must not be applied to materials supplied in containers with a net volume of 16 ounces or less, or a net weight of 1 pound or less.

TABLE 64-b

Volatile organic compound emission limits for existing metal furniture coating lines.

Coating Type	Column A¹		Column B²
Coating Type	Bake d	Air Dried	Baked	Air Dried
General, 1 Component	2.3	2.3	3.3	3.3
General, Multi-Component	2.3	2.8	3.3.	4.5
Extreme High Gloss	3.0	2.8	5.1	4.5
Extreme Performance	3.0	3.5	5.1	6.7
Heat Resistant	3.0	3.5	5.1	6.7
Metallic	3.5	3.5	6.7	6.7
Pretreatment Coatings	3.5	3.5	6.7	6.7
Solar Absorbent	3.0	3.5	5.1	6.7

¹ Pounds of volatile organic compounds emitted per gallon of coating, minus water, as applied.

² Pounds of volatile organic compounds emitted per gallon of applied coating solids. The purpose of column B emission limits is to allow credit for transfer efficiencies greater than the baseline transfer efficiency. Note: department approval under R 336.1602(2) of the transfer efficiency test method is required.

TABLE 64-c

Volatile organic compound emission limits for existing cans, coils, fabrics, and insulation of magnet wire coating lines.

Coating Category	Column A¹
Coating of cans
Sheet basecoat (exterior and interior) and overvarnish; 2-piece Can exterior (basecoat and overvarnish)	2.8
2- and 3-piece can interior body spray; 2-piece can interior end (spray or roll coat)	4.2
3-piece can side-seam	5.5
End sealing compound	3.7
Coating of coils	2.6
Coating of fabric	2.9
Insulation of magnet wire	1.7

¹ Pounds of volatile organic compounds emitted per gallon of coating, minus water, as applied.

TABLE 64-d

Volatile organic compound emission limits for paper, film, and foil surface coating and pressure sensitive tape and label surface coating.

Coating Category	Column A¹	Column B²
Paper, Film, and Foils Surface Coating (not including pressure sensitive type and label)	0.08	0.40
Pressure Sensitive Tape and Label Surface Coating	0.067	0.20

¹ Pounds of volatile organic compounds emitted per gallon of coating, minus water, as applied.

² Pounds of volatile organic compounds emitted per gallon of applied coating solids. The purpose of column B emission limits is to allow credit for transfer efficiencies greater than the baseline transfer efficiency. Note: department approval of the transfer efficiency test method is required.

(5) A person subject to this rule shall comply with the following work practices for each coating line subject to this rule, unless the source has an equivalent work practice plan established for coatings in a post-1990 federal standard found in 40 CFR part 63 with an equivalent subpart approved by the department. The person responsible for a surface coating operation subject to this rule shall develop written procedures for compliance with the following provisions:

(a) Store all volatile organic compound-containing coatings, thinners, and cleaning materials, including used shop towels, in closed containers.

(b) Minimize spills of volatile organic compound-containing coatings, thinners, and cleaning materials.

(c) Clean up spills immediately.

(d) Convey any coatings, thinners, and cleaning materials in closed containers or pipes.

(e) Close mixing vessels that contain volatile organic compound coatings and other materials except when specifically in use.

(f) Minimize usage of solvents during cleaning of storage, mixing, and conveying of equipment.

(6) A person responsible for the operation of a coating line that is subject to this rule shall obtain current information and keep records that are necessary for the determination of compliance with the provisions of this rule, as required in R 336.2041.

Mich. Admin. Code R. 336.1610a

2023 MR 8, Eff. 4/18/2023