Mich. Admin. Code R. 336.1636

Current through Vol. 24-21, December 1, 2024

Section R. 336.1636 - Emission of volatile organic compounds from existing miscellaneous industrial adhesives operations in 2015 ozone nonattainment areas

Rule 636.

(1) As used in this rule:

(a) "Electrodeposition" means a water-borne dip coating process in which opposite electrical charges are applied to the substrate and the coating. The coating is attracted to the substrate due to the electrochemical potential difference that is created.

(b) "Flow coating" means a non-atomized technique of applying coating to a substrate with a fluid nozzle with no air supplied to the nozzle.

(2) A person shall not cause or allow the emission of any volatile organic compound from the use of adhesives in excess of the limitations of this rule in miscellaneous industrial adhesive 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) Except as provided in subrule (7) of this rule, any miscellaneous industrial adhesive operations at a stationary source that has a total combined actual emission rate of volatile organic compounds equal to or less than 3 tons per 12-month rolling period, before consideration of control equipment. 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 applicable operations at that facility.

(b) The portion of an adhesive process that is addressed in R 336.1610, R 336.1610a, R 336.1620, R 336.1620a, R 336.1624, R 336.1624a, R 336.1635, or R 336.1637.

(c) The provisions of subrule (4) of this rule do not apply to the following:

(i) Adhesive or adhesive primers being tested or evaluated in any research and development operation or quality assurance or analytical laboratory.

(ii) Adhesives or adhesive primers used in the assembly, repair, or manufacture of aerospace or undersea-based weapon systems.

(iii) Adhesives or adhesives primers used in medical equipment manufacturing operations.

(iv) Aerosol adhesive and aerosol adhesive primer application operations.

(v) Operations using adhesives and adhesive primers that are supplied to the manufacturer in containers with a net volume of 16 ounces, or a net weight of 1 pound or less.

(vi) Cyanoacrylate adhesive application operations.

(vii) Operations using polyester bonding putties to assemble fiberglass parts at fiberglass boat manufacturing facilities and at other reinforced plastic composite manufacturing facilities.

(viii) Digital printing operations.

(4) A person shall not cause or allow the emission of volatile organic compounds from miscellaneous industrial adhesive application operations, unless the following provisions are met:

(a) A person with a source subject to the requirements of this rule shall comply with the limitations in subdivision (b) or (c) of this subrule unless a demonstration is made to the satisfaction of the department under R 336.1602(2).

(b) A person with adhesive application operations listed in table 69 shall comply with the following volatile organic compound emission limitations, minus water and exempt compounds, as applied, using 1 or more of the application methods listed within this subdivision. If an adhesive is used to bond dissimilar substrates together, the substrate category with the highest volatile organic compound emission limitation applies:

(i) Electrostatic spray.

(ii) High volume low pressure (HVLP) spray.

(iii) Flow coating.

(iv) Roll coating or hand application, including non-spray application methods similar to hand or mechanically powered caulking gun, brush, or direct hand application.

(v) Dip coating, including electrodeposition.

(vi) Airless spray.

(vii) Air-assisted airless spray.

(viii) An equivalent adhesive application method approved in writing by the department.

TABLE 69

Volatile organic compound emission limitations for existing general and specialty adhesive application operations.

Substrate Category	Pounds of volatile organic compounds allowed to be emitted per gallon of coating (minus water) as applied.
General Adhesive Application Operations
Reinforced plastic composite	1.7
Flexible vinyl	2.1
Metal	0.3
Porous material (except wood)	1.0
Rubber	2.1
Wood	0.3
Other substrates	2.1
Specialty Adhesive Application Operations
Ceramic tile installation	1.1
Contact adhesive	2.1
Cover base installation	1.3
Floor covering installation (indoor)	1.3
Floor covering installation (outdoor)	2.1
Floor covering installation (perimeter bonded sheet vinyl)	5.5
Metal to urethane/rubber molding or casting	7.1
Motor vehicle adhesive	2.1
Motor vehicle weatherstrip adhesive	6.3
Multipurpose construction	1.7
Plastic solvent welding (ABS)	3.3
Plastic solvent welding (except ABS)	4.2
Sheet rubber lining installation	7.1
Single-ply roof membrane installation/repair (except EPDM)	2.1
Structural glazing	0.8
Thin metal laminating	6.5
Tire repair	0.8
Waterproof resorcinol glue	1.4
Adhesive primer application operations
Motor vehicle glass bonding primer	7.5
Plastic solvent welding adhesive primer	5.4
Single-ply roof membrane adhesive primer	2.1
Other adhesive primer	2.1

(c) As an alternative to meeting subdivisions (a) and (b) of this subrule, a person with a source subject to this rule shall employ a capture system and control device that provides not less than 85% reduction in the overall emissions of volatile organic compound from the application operation. The adhesive operation would not have to limit the volatile organic compound content of the adhesive materials and would not need to use any particular adhesive application method.

(5) A person subject to this rule shall develop written procedures for compliance with the following work practices for each miscellaneous adhesive application operation at the source:

(a) Store all volatile organic matter-containing adhesives, adhesive primers, process-related waste materials, cleaning materials, and used shop towels in closed containers.

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

(c) Minimize spills of volatile organic compound-containing adhesives, adhesive primers, process-related waste materials, and cleaning materials.

(d) Convey volatile organic compound-containing adhesives, adhesive primers, process-related waste materials, and cleaning materials from 1 location to another in closed containers or pipes.

(e) Minimize volatile organic compound emissions from the 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) Compliance with this rule is determined as follows:

(a) For the emission limits specified in this rule, use the following methods:

(i) For the emission limits specified in subrules (4)(b) of this rule, the method described in either R 336.2040(12)(a) if the adhesive line does not have an add-on emissions control device or R 336.2040(12)(b) if the adhesive line has 1 or more add-on emissions control devices.

(ii) For the overall control efficiency specified in subrule (4)(c) of this rule, the method described in R 336.2040(11).

(b) For each adhesive line, all of the following:

(i) The volume-weighted average of all adhesives that belong to the same adhesive 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 adhesives that belong to more than 1 adhesive category are used on the same adhesive line during the specified averaging period, then compliance must be determined separately for each coating category.

(iii) The information and records required by subrule (7) of this rule.

(c) The manufacturer's specifications for volatile organic compound content for adhesives may be used if the specifications are based on results of tests of the volatile organic compound content conducted in accordance with methods specified in subdivisions (a) or (b) of this subrule, as applicable.

(d) For reactive adhesives, an acceptable compliance procedure is described in "Determination of Weight Volatile Matter Content and Weight Solids Content of Reactive Adhesives," 40 CFR, part 63 , subpart PPPP, appendix A, adopted by reference in R 336.1902.

(7) A person that is responsible for the operation of a miscellaneous industrial adhesive application operation that is subject to this rule shall obtain current information and keep records necessary for the determination of compliance with this rule, as required in R 336.2041.

Mich. Admin. Code R. 336.1636

2023 MR 8, Eff. 4/18/2023