Section R. 336.1621a - Emission of volatile organic compounds from existing metal parts, metal products, and motor vehicle material surface coating lines in 2015 ozone nonattainment areasRule 621a.
(1) A person shall not cause or allow the emission of any volatile organic compound from an existing metallic surface coating line at a facility located in the 2015 ozone nonattainment areas in excess of the applicable emission rates provided in subrule (3) of this rule.(2) This rule does not apply to the following:(a) Except as provided in subrule (5) of this rule, metallic surface coating lines that are within a stationary source and 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.(b) Metallic surface coating lines that meet any of the following processes:(i) The portion of a metallic surface coating process 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.(ii) Coating of a part consisting of both metallic and nonmetallic components if a demonstration is made to the satisfaction of the department, under R 336.1602(2), that the limits of this rule cannot be met due to the presence of the nonmetallic component. In this case, and if the nonmetallic component of the part is plastic and used as an automobile, truck, or business machine plastic part, R 336.1632 applies to the coating of the part, as applicable. (iv) Architectural coatings, and automobile refinish coatings that are used for architectural coating or automobile refinish coating purposes as defined by their respective national volatile organic compound rules.(v) Coatings that are applied to test panels and coupons as part of research and development, quality control, or performance testing activities at paint research or manufacturing facilities.(vi) Customized top coating of less than 35 automobiles or trucks, or both, per calendar day.(vii) Coating of the exterior of airplanes when the part to be coated has already been assembled on the airplane.(viii) Coating of the exterior of marine vessels when the part to be coated has already been assembled on the marine vessel.(ix) Coatings used on a non-production basis.(x) Rubber to metal bonding.(c) The following metal parts coating processes are exempt from subrule (3) of this rule:(ii) Safety-indicating coatings.(iii) Solid-film lubricants.(iv) Electric-insulating and thermal-conducting coatings.(v) Magnetic data storage disk coatings.(vi) Plastic extruded onto metal parts to form a coating.(d) The coating of bodies or body parts for new heavier vehicles at an automobile and light-duty truck assembly facility or a heavier vehicle assembly facility where the person responsible elects to comply with the provisions of R 336.1610a under the classification of automobile and light-duty truck coating lines.(e) The application methods required by subrule (3)(b) of this rule do not apply to airbrush operations using 5 gallons or less per year of coating.(f) A person subject to this rule may exclude low-use coatings that have a combined total less than 55 gallons per rolling 12-month period at a stationary source from the provisions of this rule, except for subrule (5) of this rule.(3) A person shall not cause or allow the emission of volatile organic compounds from metallic surface coating operations, unless the following provisions are met: (a) A person responsible for a coating line engaged in the surface coating of metallic surfaces, with the exception of motor vehicle materials as listed in table 64-g, shall limit volatile organic compounds emissions from all volatile organic compound-containing materials, such as coatings, thinners, and other additives, used by each metallic surface coating line by complying with either subdivision (c), (d), or (e) of this subrule, as applicable.(b) A person subject to this rule shall not apply volatile organic compound-containing coatings to metal parts and products 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 or the executive officer, or designee, and by the use of 1 of the following methods:(i) Electrostatic application.(iii) Dip coat (including electrodeposition).(v) High-volume, low-pressure (HVLP) spray.(vii) Air-assisted airless spray.(viii) Alternative coating application methods that demonstrate equal or better transfer efficiency capability than HVLP spraying. Written departmental approval is required for alternative coating application methods.(c) A metallic surface coating operation must not cause or allow the emission of volatile organic compounds from the coating of metallic surfaces from any existing metal parts 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 compounds per volume of coating excluding water and exempt compounds, as applied, as specified in table 64-e, or emission rates expressed in terms of mass of volatile organic compounds per volume of solids as applied, as specified in table 64-f, unless a demonstration is made to the satisfaction of the department, under R 336.1602(2). TABLE 64-e
Metal Parts and Products low-VOC Coating Content Limits
Coating Category | Air Dried | Baked |
lb VOC/gal | lb VOC/gal |
| coating (excluding water), as applied | coating (excluding water), as applied |
General 1 Component | 2.8 | 2.3 |
General Multi Component | 2.8 | 2.3 |
Camouflage | 3.5 | 3.5 |
Electric-Insulating Varnish | 3.5 | 3.5 |
Etching Filler | 3.5 | 3.5 |
Extreme High-Gloss | 3.5 | 3.0 |
Extreme Performance | 3.5 | 3.0 |
Heat-Resistant | 3.5 | 3.0 |
High Performance Architectural | 3.5 | 3.5 |
High Temperature | 3.5 | 3.5 |
Metallic | 3.5 | 3.0 |
Military Specification | 2.8 | 2.3 |
Mold-Seal | 3.5 | 3.0 |
Pan Backing | 3.5 | 3.5 |
Prefabricated Architectural Multi-Component | 3.5 | 2.3 |
Prefabricated Architectural One-Component | 3.5 | 2.3 |
Pretreatment Coatings | 3.5 | 3.5 |
Repair and Touch Up | 3.5 | 3.0 |
Silicone Release | 3.5 | 3.5 |
Solar-Absorbent | 3.5 | 3.0 |
Vacuum-Metalizing | 3.5 | 3.0 |
Drum Coating, New, Exterior | 2.8 | 2.8 |
Drum Coating, New, Interior | 3.5 | 3.5 |
Drum Coating, Reconditioned, Exterior | 3.5 | 3.5 |
Drum Coating, Reconditioned, Interior | 4.2 | 4.2 |
TABLE 64-f
Metal Parts and Products VOC Emission Rate Limits (VOC per Volume Solids)
Coating Category | Air Dried | Baked |
lb VOC/gal solids, as applied | lb VOC/gal solids, as applied |
General 1 Component | 4.52 | 3.35 |
General Multi Component | 4.52 | 3.35 |
Camouflage | 6.67 | 6.67 |
Electric-Insulating Varnish | 6.67 | 6.67 |
Etching Filler | 6.67 | 6.67 |
Extreme High-Gloss | 6.67 | 5.06 |
Extreme Performance | 6.67 | 5.06 |
Heat-Resistant | 6.67 | 5.06 |
High Performance Architectural | 6.67 | 6.67 |
High Temperature | 6.67 | 6.67 |
Metallic | 6.67 | 5.06 |
Military Specification | 4.52 | 3.35 |
Mold-Seal | 6.67 | 5.06 |
Pan Backing | 6.67 | 6.67 |
Prefabricated Architectural Multi-Component | 6.67 | 3.35 |
Prefabricated Architectural One-Component | 6.67 | 3.35 |
Pretreatment Coatings | 6.67 | 6.67 |
Silicone Release | 6.67 | 6.67 |
Solar-Absorbent | 6.67 | 5.06 |
Vacuum-Metalizing | 6.67 | 5.06 |
Drum Coating, New, Exterior | 4.52 | 4.52 |
Drum Coating, New, Interior | 6.67 | 6.67 |
Drum Coating, Reconditioned, Exterior | 6.67 | 6.67 |
Drum Coating, Reconditioned, Interior | 9.78 | 9.78 |
(d) A metallic surface coating operation applicable to this rule, except for motor vehicle materials, may 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 tables 64-e and table 64-f, 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 64-e or table 64-f. If using the lb volatile organic compounds/gal coating, excluding water, as applied limit from table 64-e, 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 lb volatile organic compounds/gal of coating solids.
C = The volatile organic compound emission limitation in terms of lb volatile organic compounds/gal 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 volatile organic compound content of the coatings, as applied, used each day on the subject coating line, in units of lb volatile organic compounds/gal of 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 lb volatile organic compounds/gal of coating solids.
S = The volatile organic compound emission limitation in terms of lb volatile organic compounds/gal of coating solids.
(e) A metallic surface coating operation applicable to this rule, with the exception of motor vehicle materials, can choose to use add-on control equipment that must have an overall control efficiency of 90% or higher. The coating operation would not have to limit the volatile organic compound content of the coating materials and would not need to use any particular coating application method.(f) A person subject to this rule shall not cause or allow the emissions of volatile organic compounds from existing motor vehicle material coating operations in any of the 2015 ozone nonattainment areas in excess of the emission rates as specified in table 64-g, as applicable. TABLE 64-g
Volatile organic compound emission limitation for existing motor vehicle materials
Coating category | lb VOC/gal coating (excluding water), as applied |
Motor vehicle cavity wax | 3.5 |
Motor vehicle sealer | 3.0 |
Motor vehicle deadener | 3.0 |
Motor vehicle gasket/gasket sealing material | 1.7 |
Motor vehicle underbody coating | 3.5 |
Motor vehicle trunk interior coating | 3.0 |
Motor vehicle bedliner | 1.7 |
Motor vehicle lubricating wax/compound | 3.5 |
(g) If the provisions of more than 1 coating category of this subrule are applicable for a specific coating, then the least stringent provision may be applied.(h) For each coating line, compliance with the emission limits specified in this rule must be 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. Under R 336.1602(2), the department may specifically authorize compliance to be based upon 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 must be determined separately for each coating category.(iii) The information and records required by subrule (5) of this rule.(i) Compliance with the emission limits specified in this rule must be determined using the applicable method described in the following subdivisions:(i) For coating lines that are subject to the emission limits specified in subdivision (c) of this subrule, the method described in either R 336.2040(12)(a) if the coating line has no 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 coating lines that are subject to the emission limits specified in subrule (3)(d) of this rule, the method described in either R 336.2040(12)(c) if the coating line has no add-on emissions control device or R 336.2040(12)(d) if the coating line has 1 or more add-on emissions control devices.(4) 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 metallic parts surface coating operation shall develop written procedures to comply 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 emission 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.(5) A person who is responsible for the operation of a coating line that is subject to this rule shall obtain current information, and keep daily records necessary for the determination of compliance with the provisions of this rule, and as required in R 336.2041.Mich. Admin. Code R. 336.1621a
2023 MR 8, Eff. 4/18/2023