Michigan Administrative Code
Department - Environmental Quality
Air Quality Division
Part 6 - EMISSION LIMITATIONS AND PROHIBITIONS-EXISTING SOURCES OF VOLATILE ORGANIC COMPOUND EMISSIONS
Section R. 336.1633 - Emission of volatile organic compounds from existing plastic parts and products surface coating; and pleasure craft coating operations in 2015 ozone nonattainment areas

Universal Citation: MI Admin Code R. 336.1633

Current through Vol. 24-04, March 15, 2024

Rule 633.

(1) As used in this rule:

(a) "Pleasure craft" means vessels that are manufactured or operated primarily for recreational purposes, or leased, rented, or chartered to a person for recreation purposes. The person responsible for the vessels is responsible for certifying that the intended use is for recreational purposes.

(b) "Pleasure craft surface coating" means any marine coating, except unsaturated polyester resin (fiberglass) coatings, applied by brush, spray, roller, or other means to a pleasure craft.

(2) A person shall not cause or allow the emission of any volatile organic compound from the surface coating of miscellaneous plastic parts and products, or pleasure craft coatings in excess of the limitations of this rule in miscellaneous plastic parts and products operations or pleasure craft operations from any existing source located within the 2015 ozone nonattainment area, in excess of the applicable emission rates provided in subrule (4) of this rule.

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

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

(b) The portion of a plastic parts and products surface coating and pleasure craft coating operations that is addressed in R 336.1610, R 336.1610a, R 336.1620, R 336.1620a, R 336.1635, R 336.1636, R 336.1637, R 336.1638, and R 336.1639.

(d) Body fillers and putties used to repair surface defects in fiberglass composite parts, or putties used to bond fiberglass composite parts together.

(e) The following plastic parts coatings processes are exempt from subrule (4) of this rule:

(i) Touch-up and repair coatings.

(ii) Stencil coatings applied on clear or transparent substrates.

(iii) Clear or translucent coatings.

(iv) Coatings applied at a paint manufacturing facility while conducting performance tests on the coatings.

(v) Any individual coating category used in volumes less than 50 gallons in any 1 year, if substitute compliant coatings are not available, if the total usage of all coatings does not exceed 200 gallons per year, per facility.

(vi) Reflective coating applied to highway cones.

(vii) Mask coatings that are less than 0.5 millimeter thick (dried) and the area coated is less than 25 square inches.

(viii) Electromagnetic interference/radio frequency interference shielding coatings.

(ix) Heparin-benzalkonium chloride containing coatings applied to medical devices, if the total usage of all such coatings does not exceed 100 gallons per year, per facility.

(4) A person shall not cause or allow the emission of any volatile organic compound from surface coatings from plastic parts and product operations or from surface coatings from pleasure craft operations, unless the following provisions are met:

(a) A person responsible for the coating line engaged in the surface coating of existing miscellaneous plastic parts and products, and surface coating of pleasure crafts in the 2015 ozone nonattainment areas shall limit volatile organic compound emissions from all volatile organic compound-containing materials, such as coatings, thinners, and other additives, used by each miscellaneous plastic parts and products, and pleasure craft surface coating line by complying with either subdivision (c), (d), or (e) of this subrule.

(b) A person subject to this rule shall not apply volatile organic compound-containing coatings to existing miscellaneous plastic parts and products, or pleasure craft surfaces subject to the provisions of this rule, unless the coating is applied with properly operating equipment according to an operating procedure specified by the equipment manufacturer, executive officer, or designee, and by the use of 1 of the following methods:

(i) Electrostatic attraction.

(ii) Flow coat.

(iii) Dip coat.

(iv) Roll coater.

(v) High-Volume, Low-Pressure (HVLP) Spray.

(vi) Airless spray.

(vii) Air-assisted airless spray.

(viii) A person subject to this rule may request, in writing to the department, and the department may approve, other coating application methods that demonstrate the capability of achieving a transfer efficiency equivalent to or better than that achieved by HVLP spraying.

(c) A miscellaneous plastic parts coating and pleasure craft coating operation must not cause or allow the emission of volatile organic compounds from the coating of metallic surfaces from any plastic parts or pleasure craft coating line in any of the 2015 ozone nonattainment areas in excess of the applicable content limits, expressed in terms of mass of volatile organic compound per volume of coating excluding water and exempt compounds, as applied, as specified in table 68 and table 68-a, or emission rates expressed in terms of mass of volatile organic compound per volume of solids as applied, as specified in table 68-b and table 68-c:

TABLE 68

Plastic Parts and Products Volatile Organic Compound Content Limits

Coating Category	lbs VOC/gal coating
General 1 Component	2.3
General Multi Component	3.5
Electric Dissipating Coatings and Shock-Free Coatings	6.7
Extreme Performance	3.5 (2-pack coatings)
Metallic	3.5
Military Specification	2.8 (1-pack) 3.5 (2-pack)
Mold-Seal	6.3
Multi-colored Coatings	5.7
Optical Coatings	6.7
Vacuum-Metalizing	6.7

TABLE 68-a

Pleasure Craft Surface Coating Volatile Organic Compound Content Limits

Coating Category	lbs VOC/gal coating Before January 1, 2026	lbs VOC/gal coating On or after January 1, 2026
Extreme High Gloss Topcoat	5.0	4.1
High Gloss Topcoat	3.5	3.5
Pretreatment Wash Primers	6.5	6.5
Finish Primer/Surfacer	5.0	3.5
High Build Primer Surfacer	2.8	2.8
Aluminum Substrate Antifoulant Coating	4.7	4.7
Other Substrate Antifoulant Coating	3.4	2.8
All other pleasure craft surface coatings for metal or plastic	3.5	3.5

TABLE 68-b

Plastic Parts and Products Volatile Organic Compound Emission Rate Limits

Coating Category	lbs VOC/gal solids
General 1 Component	3.35
General Multi Component	6.67
Electric Dissipating Coatings and Shock-Free Coatings	74.7
Extreme Performance	6.67 (2-pack coatings)
Metallic	6.67
Military Specification	4.52 (1-pack) 6.67 (2-pack)
Mold-Seal	43.7
Multi-colored Coatings	25.3
Optical Coatings	74.7
Vacuum-Metalizing	74.7

TABLE 68-c

Volatile organic compound emissions limitations for existing pleasure craft surface coating lines.

Coating Category	lbs VOC/gal solids Before January 01, 2026	lbs VOC/gal solids On or after January 01, 2026
Extreme high gloss topcoat	15.5	9.2
High gloss topcoat	6.7	6.7
Pretreatment wash primers	55.6	55.6
Finish primer/surfacer	15.5	6.7
High build primer surfacer	4.6	4.6
Aluminum substrate antifoulant coating	12.8	12.8
Other substrate antifoulant coating	6.3	4.4
All other pleasure craft surface coatings for metal or plastic	6.7	6.7

(d) A miscellaneous plastic parts coating and pleasure craft coating operation applicable to this rule can choose to use an equivalent volatile organic compound emission rate limit based on the use of a combination of low-volatile organic compound coatings specified in table 68 to table 68-c, specified methods of application specified under subdivision (b) of this subrule, and add-on controls. The overall emission reduction efficiency needed to demonstrate compliance is determined each day as follows:

(i) Obtain the emission limitation from table 68 to table 68-c. If using the pound of volatile organic compound per gallon of coating, excluding water, as applied limit from table 68 or table 68-b, then calculate the emission limitation in a solids basis according to the following equation:

S = C / [1 - (C/7.36 lb/gal)]

Where:

S = The volatile organic compound emission limitation in terms of pound of volatile organic compound per gallon of coating solids.

C = The volatile organic compound emission limitation in terms of pound of volatile organic compound per gallon of coating, (excluding water) as applied.

(ii) Calculate the required overall emission reduction efficiency of the control system for the day according to the following equation:

E = [(VOCa - S)/VOCa] x 100

Where:

E = The required overall emission reduction efficiency of the control system for the day.

VOCa = The maximum VOC content of the coatings, as applied, used each day on the subject coating line, in units of lb VOC/gal coating solids, as determined by the applicable test methods and procedures specified in subdivision (h) of this subrule.

S = The volatile organic compound emission limitation in terms of pound of volatile organic compound per gallon of coating solids.

(e) Should product performance requirements or other needs dictate the use of higher-volatile organic compound materials than those that would meet the recommended emission limits, a facility can choose to use add-on control equipment that must have an overall control efficiency of 90% or higher instead of using low-volatile organic compound coatings and specified application methods.

(f) For each coating line, compliance with the emission limits specified in this rule is based upon all of the following:

(i) The volume-weighted average of all coatings that belong to the same coating category, and are used during each calendar day averaging period. The department may specifically authorize compliance, under R 336.1602(2), to be based upon a longer averaging period, not to exceed more than 1 calendar month.

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

(iii) The information and records as required by subrule (6) of this rule.

(g) Compliance with the emission limits specified in subrule (4) of this rule, must be determined using 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.

(5) The following work practices are required for storage, mixing operations, and handling operations for coatings, thinners, cleaning, and coating-related waste materials. The person responsible for a miscellaneous plastic parts coating and pleasure craft coating operation shall develop written procedures for compliance with the following provisions:

(a) Store all volatile organic compound-containing coatings, thinners, coating-related waste, and cleaning materials in closed containers.

(b) Ensure that mixing and storage containers used for volatile organic compound-containing coatings, thinners, coating-related waste, and cleaning materials are kept closed at all times, except when depositing or removing these materials.

(c) Minimize spills of volatile organic compound-containing coatings, thinners, coating-related waste, and cleaning materials.

(d) Convey volatile organic compound-containing coatings, thinners, coating-related waste, and cleaning materials from 1 location to another in closed containers or pipes.

(e) Minimize volatile organic compound emissions from cleaning of application, storage, mixing, and conveying equipment by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers.

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

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