Mich. Admin. Code R. 336.1634

Current through Vol. 24-19, November 1, 2024

Section R. 336.1634 - Emissions of volatile organic compounds from existing industrial solvent cleaning in 2015 ozone nonattainment areas

Rule 634.

(1) As used in this rule, "composite partial vapor pressure" means the sum of the partial pressures of the VOC compounds in a solvent.

(2) A person shall not cause or allow the emission of any volatile organic compound from the use of solvent materials in excess of the limitations of this rule in solvent cleaning operations, which are described as follows:

(a) Released during the production, repair, maintenance, or servicing of parts, products, tools, machinery, equipment or in general work areas including storage or disposal of these solvent materials.

(b) Located in the 2015 ozone nonattainment area.

(3) With the exception of subrule (6) of this rule, the provisions of this rule do not apply to the following activities:

(a) Janitorial cleaning.

(b) Stripping of cured coatings, cured ink, or cured adhesives.

(c) Cleaning operations in printing pre-press or graphic areas including lithographic, letterpress, flexographic, screen printing, and rotogravure printing operations.

(d) Cleaning operations associated with digital printing.

(e) Cleaning operations for which limits or work practice standards are contained within R 336.1610, R 336.1610a, R 336.1620, R 336.1620a, R 336.1621, R 336.1621a, R 336.1624, R 336.1624a, R 336.1632, R 336.1633, R 336.1635, R 336.1636, R 336.1637, R 336.1638, and R 336.1639.

(f) Cleaning operations at a facility with emissions less than 3 tons per rolling 12-month period for all cleaning activity, before consideration of controls. If the combined actual emission rate equals or is more than 3 tons per year on a 12-month rolling basis before consideration of controls, as determined in a subsequent month, then this rule permanently applies to the cleaning operations at that facility.

(4) A person that generates volatile organic compound from the use of industrial cleaning solvent shall meet the following provisions:

(a) The volatile organic compound emissions from the process must meet 1 of the following:

(i) The solvent or solvent solutions must have a volatile organic compound composite partial vapor pressure of less than or equal to 8 mm of Hg at 20 degrees Celsius.

(ii) The process must have an emission rate of 0.42 pounds of volatile organic compounds per gallon as applied, except as described for the solvent cleaning operations listed in table 68-d.

TABLE 68-d

Solvent Cleaning Operation	Pounds of volatile organic compounds allowed to be emitted per gallon as applied
Product cleaning during manufacturing process or surface preparation for coating, adhesive, or ink application: Electrical apparatus components and electronic components Medical devices and pharmaceuticals	0.83 6.7
Repair and maintenance cleaning: Electrical apparatus components and electronic components Medical devices and pharmaceuticals: Tools, equipment, and machinery General work surfaces	0.83 6.7 5.0
(iii.) Cleaning of ink application equipment: Publication gravure printing Screen printing Ultraviolet ink and electron beam ink application equipment, except screen printing Specialty flexographic printing	0.83 4.2 5.4 0.83
(iv.) Exemptions from emissions limits in this subdivision: Cleaning conducted as part of the following: performance laboratory tests on coatings, adhesives, or inks; research and development programs; and laboratory tests in quality assurance laboratories. Medical device and pharmaceutical facilities using up to 1.5 gallons per day of solvents. Cleaning with aerosol products if the source uses 1.25 gallons or less per day	N/A

(b) A person subject to this rule shall utilize all of the following cleaning devices and methods as applicable:

(i) Wipe cleaning.

(ii) Closed containers or hand-held spray bottles from which solvents are applied without a propellant-induced force.

(iii) Cleaning equipment that has a solvent container that can be, and is closed during cleaning operations, except when depositing and removing objects to be cleaned, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself.

(iv) Remote reservoir cleaner if the operator of the cleaner complies with all of the following:

(A) Prevents solvent vapors from escaping from the solvent container by using such devices as a cover or valve when the remote reservoir is not being used, cleaned, or repaired.

(B) Directs solvent flow in a manner that prevents liquid solvent from splashing outside of the remote reservoir cleaner.

(C) Does not clean porous or absorbent materials, such as cloth, leather, wood, or rope.

(D) Uses only solvent containers and auxiliary equipment free of all liquid leaks. visible tears, or cracks.

(v) Non-atomized solvent flow method where the cleaning solvent is collected in a container or a collection system that is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container.

(vi) Solvent flushing method where the cleaning solvent is discharged into a container that is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container. The discharged solvent from the equipment must be collected into containers without atomizing into the open air.

(c) Instead of complying with subdivisions (a) and (b) of this subrule for a solvent cleaning operation, a person that is subject to this rule may comply by installing and operating volatile organic compound emission control equipment for the solvent cleaning operation. The volatile organic compound emission control equipment must have an overall control efficiency of 85%.

(d) Instead of complying with subdivisions (a) and (b) of this subrule, a manufacturer of coatings, inks, resins, or adhesives may comply with subdivision (e) of this subrule or the following:

(i) Clean portable tables or stationary mixing vats, high dispersion mills, grinding mills, tote tanks, and roller mills by 1 or more of the following methods:

(A) Use a cleaning solvent that either contains less than 1.67 pounds per gallon of volatile organic compound or has a composite vapor pressure no more than 8 mm of Hg at 20 degrees Celsius.

(B) Comply with the following work practices:

(1) Equipment being cleaned must be maintained leak free.

(2) Volatile organic compound-containing cleaning materials must be drained from the cleaned equipment upon completion of cleaning.

(3) Volatile organic compound-containing cleaning materials, including waste solvent, must not be stored or disposed of in a manner that causes or allows evaporation into the atmosphere.

(4) Store all volatile organic compound-containing cleaning materials in closed containers.

(C) Collect and vent the emissions from equipment cleaning to a volatile organic compound emission control system that has an overall capture and control efficiency of not less than 85%, by weight, for the volatile organic compound emissions. If such a reduction is achieved by incineration, not less than 90% of the organic carbon must be oxidized to carbon dioxide.

(D) Use organic solvents other than those allowed in subdivision (f)(i) of this subrule provided no more than 60 gallons of fresh solvent must be used per month. Organic solvent that is reused or recycled, either on-site or off-site, for further use in equipment cleaning or the manufacture of coating, ink, or adhesive must not be included in this limit. Also, store all volatile organic compound-containing cleaning materials in closed containers.

(ii) When using solvent for wipe cleaning, a person shall cover open containers used for the storage or disposal of cloth or paper impregnated with organic compounds that have been used for cleanup, or coating, ink, or adhesive removal.

(e) Work practices must be used to minimize volatile organic compound emissions from the use, handling, storage, and disposal of cleaning solvents and shop towels. Work practices must include, at a minimum, but not limited to, the following:

(i) All volatile organic compound-containing solvents used in solvent cleaning operations must be stored in non-absorbent, non-leaking containers which must be kept closed at all times except when filling or emptying.

(ii) Cloth and paper moistened with volatile organic compound-containing solvents must be stored in closed, non-absorbent, non-leaking containers.

(iii) Air circulation around cleaning operations must be minimized.

(f) Except as allowed by this subrule, a person shall not atomize any solvent unless the emissions are vented to volatile organic compound emission control equipment that meets subdivision (c) of this subrule. The following activities are allowed to atomize solvent without use of a control:

(i) Cleaning of the nozzle tips of automated spray equipment systems, except for robotic systems.

(ii) Cleaning with spray bottles or containers described in subdivision (b)(ii) of this subrule.

(iii) Printing operations where the roller or blanket wash is applied automatically.

(5) Compliance with this rule must be determined as follows:

(a) For limits specified in subrule (4)(a) of this rule, compliance must be based upon all volatile organic containing compounds using manufacturers formulation data, United States Environmental Protection Agency method 24 analysis, safety data sheets, an alternate method, or combination of the methods stated within this subdivision, as approved by the department and in sufficient detail to demonstrate compliance with the limitations described in subrule (4) of this rule.

(b) If a person responsible for a solvent cleaning operation that is subject to this rule employs volatile organic compound emission control equipment to comply with this rule, pursuant to subrule (4)(c) of this rule:

(i) Compliance with required control efficiency limits must be determined by performing emission tests in accordance with a stack testing protocol approved by the department.

(ii) Additional testing of the volatile organic compound emission control equipment for a solvent cleaning operation in accordance with this rule may be required by the department to ensure continued compliance.

(c) As appropriate, the composite partial vapor pressure of solvents must be determined by using generally acceptable methods including, but not limited to, ASTM standards, commonly published materials and references, or standard chemical laws and calculations.

(6) A person operating a solvent cleaning operation shall obtain current information and maintain records for all requirements in sufficient detail to determine compliance and make the records available to the department upon request. The following methods must be used:

(a) The person operating a solvent cleaning operation that is subject to 1 or more of the volatile organic compound-content limitations or exemptions specified in subrule (4) of this rule shall collect and record the following information for each cleaning material subject to a volatile organic compound-content limitation as necessary to determine compliance with that limitation:

(i) The name and identification of each cleaning material and the associated solvent cleaning activity.

(ii) The volatile organic compound content, of each cleaning material, as determined in subrule (5) of this rule, in pounds per gallon of material, as employed or the volatile organic compound composite partial vapor pressures of the solvents or solvent solutions used in the industrial cleaning operations.

(iii) The volume, in gallons, of each solvent employed in the solvent cleaning operation.

(iv) The total volume, in gallons, of all the solvents employed in the solvent cleaning operation.

(b) If a person operating a solvent cleaning operation employs a control device to achieve and maintain compliance, that person shall create and submit an approvable preventative maintenance and monitoring plan to the department which includes details about all appropriate parameters to be monitored and recordkeeping sufficient to determine compliance.

(c) A person exempting their solvent cleaning operations as allowed by subrule (3) of this rule shall maintain all information necessary to demonstrate, in sufficient detail, the applicability of those exemptions and must provide that information to the department upon request.

Mich. Admin. Code R. 336.1634

2023 MR 8, Eff. 4/18/2023