Mich. Admin. Code R. 336.1637

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

Section R. 336.1637 - Emissions of volatile organic compounds from existing fiberglass boat manufacturing in 2015 ozone nonattainment areas

Rule 637.

(1) As used in this rule, "fiberglass boat manufacturing" means the manufacturing of hulls or decks of boats from fiberglass or build molds to make fiberglass boat hulls or decks.

(2) A person shall not cause or allow the emission of any volatile organic compound from an existing fiberglass boat manufacturing facility located in the 2015 ozone nonattainment areas unless all of the provisions of the following subrules are met.

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

(a) Except as provided in subrule (6) of this rule, any fiberglass boat manufacturing operations that have an actual emission rate of volatile organic compounds less than 2.7 tons per 12-month rolling period, before consideration of control equipment. If the combined actual emission rate equals or is more than 2.7 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 fiberglass boat manufacturing operations at that facility.

(b) Miscellaneous industrial adhesives used in the assembly of fiberglass boats. Polyester resin putties used to assemble fiberglass parts are not considered industrial adhesives for the purposes of this exclusion and apply to this part.

(c) Surface coatings applied to fiberglass boats.

(d) Surface coating for fiberglass and metal recreational boats, for example, pleasure craft, addressed under R 336.1633.

(e) Facilities that manufacture solely parts of boats or boat trailers, but do not manufacture hulls or decks of boats from fiberglass or build molds to make fiberglass boat hulls or decks.

(f) Closed molding operations.

(g) Except as provided in subrule (6) of this rule, all of the following:

(i) Production resins that must meet specifications for use in military vessels or must be approved by the United States Coast Guard for use in the construction of lifeboats, rescue boats, and other life-saving appliances approved under 46 CFR subchapter Q, or the construction of small passenger vessels regulated by 46 CFR subchapter T.

(ii) Production and tooling resins, and pigmented, clear, and tooling gel coat used for part or mold repair and touch up. The total resin and gel coat materials that meet these criteria must not exceed 1% by weight of all resin and gel coat used at a facility on a 12-month rolling average basis.

(iii) Pure, 100% vinylester resin used for skin coats.

(4) A person shall not cause or allow the emission of any volatile organic compound from fiberglass boat manufacturing 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 subdivisions (b), (c), or (d) of this subrule. For sources complying pursuant to subdivision (b) or (c) of this subrule, if the non-monomer volatile organic compound content of a resin or gel coat exceeds 5%, by weight, the excess non-monomer volatile organic compound must be added to the monomer volatile organic compound of the resin or gel coat. The excess non-monomer volatile organic compound must be calculated in accordance with the following equation:

Excess Non-Monomer VOC = Non-monomer VOC Content - 5%, by weight

(b) A person shall not cause or allow the emission of volatile organic compounds from resin or gel coat from any existing source applicable to this rule in any of the 2015 ozone nonattainment areas as defined in R 336.1601, in excess of the applicable monomer requirements in table 69-a of this subrule.

TABLE 69-a

Alternative volatile organic compound content requirements for molding resin and gel coat operations.

Operation	Application Method	Weighted-Average Monomer VOC Content (weight percent)
Production resin	Atomized	28.0
Production resin	Nonatomized	35.0
Pigment gel coat	Any method	33.0
Clear gel coat	Any method	48.0
Tooling resin	Atomized	30.0
Tooling resin	Nonatomized	39.0
Tooling gel coat	Any method	40.0

(c) A person subject to the requirements of this rule may elect to include some or all of the subject resin and gel coat operations at the source in the emissions averaging alternative. All subject resin and gel coat operations that do not utilize the emissions averaging alternative must comply with the requirements in subdivision (b) or (d) of this subrule, as well as with all other applicable requirements in this rule. Resin and gel coat operations utilizing the emissions averaging alternative must comply with a source-specific monomer volatile organic compound mass emission limit on a 12-month rolling average basis, calculated at the end of each calendar month using the following equations:

(i) A person subject to subdivision (c) of this subrule shall use equation 6-1 to determine the source-specific monomer volatile organic compound mass emission limit for resin and gel coats included in the emissions average:

Equation 6-1:

Monomer VOC Limit = 46(M_R)+159(M_PG)+291(M_CG)+54(M_TR)+214(M_TG)

Where:

Monomer = Total allowable monomer volatile organic compound that can VOC be emitted from the open molding operations included in the limit average, expressed in kilograms per 12-month period.

M_R = Mass of production resin used in the past 12 months, excluding any materials that are exempt, expressed in megagrams (Mg).

M_PG = Mass of pigmented gel coat used in the past 12 months, excluding any materials that are exempt, expressed in Mg.

M_CG = Mass of clear gel coat used in the past 12 months, excluding any materials that are exempt, expressed in Mg.

M_TR = Mass of tooling resin used in the past 12 months, excluding any materials that are exempt, expressed in Mg.

M_TG = Mass of tooling gel coat used in the past 12 months, excluding any materials that are exempt, expressed in Mg.

The numerical coefficients associated with each term on the righthand side of equation 6-1 are the allowable monomer volatile organic compound emission rates for that particular material in units of kg VOC/Mg of material used.

(ii) At the end of the first 12-month averaging period, and at the end of each subsequent month, the person with a source subject to this subdivision (c) shall use equation 6-2 to calculate the monomer volatile organic compound emissions from the resin and gel coat operations included in the emissions average. The monomer volatile organic compound emissions calculated using equation 6-2 must not exceed the monomer volatile organic compound limit calculated using equation 6-1.

EQUATION 6-2:

Monomer VOC Emissions = (PV_R)(M_R) + (PV_PG)(M_PG) + (PV_CG)(M_CG) + (PV_TR)(M_TR) + (PV_TG)(M_TG)

Where:

Monomer VOC Emissions= Monomer volatile organic compound emissions calculated using the monomer volatile organic compound emission equations for each operation included in the average, expressed in kilograms.

PV_R = Weighted-average monomer volatile organic compound emission rate for production resin used in the past 12 months, expressed in kg/Mg, calculated in accordance with equation 6-3 in subdivision (c)(iii) of this subrule.

M_R = Mass of production resin used in the past 12 months, expressed in Mg.

PV_PG = Weighted-average monomer volatile organic compound emission rate for pigmented gel coat used in the past 12 months, expressed in kg/Mg, calculated pursuant to equation 6-3.

M_PG = Mass of pigmented gel coat used in the past 12 months, expressed in Mg.

PV_CG = Weighted-average monomer volatile organic compound emission rate for clear gel coat used in the past 12 months, expressed in kg/Mg, calculated pursuant to equation 6-3.

M_cg = Mass of clear gel coat used in the past 12 months, expressed in Mg.

PV_TR = Weighted-average monomer volatile organic compound emission rate for tooling resin used in the past 12 months, expressed in kg/Mg, calculated pursuant to equation 6-3.

M_TR = Mass of tooling resin used in the past 12 months, expressed in Mg.

PV_TG = Weighted-average monomer volatile organic compound emission rate for tooling gel coat used in the past 12 months, expressed in kg/Mg, calculated pursuant to equation 6-3.

M_TG = Mass of tooling gel coat used in the past 12 months, expressed in Mg.

(iii) For purposes of equation 6-2, the person with a source subject to this subdivision shall use equation 6-3 to calculate the weighted-average monomer volatile organic compound emission rate for the previous 12 months for each resin and gel coat operation included in the emissions average, except as provided in subdivision (f) of this subrule.

EQUATION 6-3:

Click Here To View Image

Where:

PV_op = Weighted-average monomer volatile organic compound emission rate for each open molding operation (PVR, PVPG, PVCG, PVTR, and PVTG) included in the average, expressed in kg of monomer volatile organic compound per Mg of material applied.

M_i = Mass of resin or gel coat (i) used within an operation in the past 12 months, expressed in Mg.

n = Number of different open molding resins and gel coats used within an operation in the past 12 months.

PV_i = The monomer volatile organic compound emission rate for resin or gel coat (i) used within an operation in the past 12 months, expressed in kg of monomer volatile organic compound per Mg of material applied. The monomer volatile organic compound emission rate formulas in paragraph (iv) of this subdivision must be used to compute PVi. If a source includes filled resins in the emissions average, the source must use the value of PVF, calculated using equation 6-4 in subdivision (f)(iii) of this subrule as the value of Pvi for those resins.

_i = Subscript denoting a specific open molding resin or gel coat applied.

(iv) For purposes of equation 6-3 and subdivision (f)(iii) of this subrule, the following monomer volatile organic compound emission rate formulas applies. The formulas calculate monomer volatile organic compound emission rates in terms of kg of monomer volatile organic compound per Mg of resin or gel coat applied. "VOC%" means the monomer volatile organic compound content as supplied, expressed as a weight percent value between 0 and 100%.

TABLE 69-b

Monomer volatile organic compound emission rate formulas for molding operations.

Operation	Application Method	Formula to calculate the monomer VOC emission rate.
Production resin, tooling resin	Atomized	0.014 x (Resin VOC%)^2.425
Production resin, tooling resin	Atomized, plus vacuum bagging with roll-out	0.01185 x (Resin VOC%)^2.425
Production resin, tooling resin	Atomized, plus vacuum bagging without roll-out	0.00945 x (Resin VOC%)^2.425
Production resin, tooling resin	Nonatomized	0.014 x (Resin VOC%)^2.275
Production resin, tooling resin	Nonatomized, plus vacuum bagging with roll-out	0.0110 x (Resin VOC%)^2.275
Production resin, tooling resin	Nonatomized, plus vacuum bagging without roll-out	0.0076 x (Resin VOC%)^2.275
Pigmented gel coat, clear gel coat, tooling gel coat	All methods	0.445 x (Gel coat VOC%)^1.675

(d) A person subject to the requirements of this rule may elect to employ an add-on control device with a minimum overall control efficiency that meets the monomer volatile organic compound emission limitations specified in table 69-a of this rule. All subject resin and gel coat operations that do not utilize the add-on control alternative must comply with the requirements in subdivision (b) or (c) of this subrule, as well as with all other applicable requirements in this rule.

(e) A person subject to subdivision (d) of this subrule shall meet the volatile organic compound emission limit determined using equation 6-1 in subdivision (c)(i) of this subrule. In equation 6-1, however, instead of using the mass of each material used over the past 12 months to determine the emission limitation, the person shall use the mass of each material used during the applicable control device performance test. If the measured emissions at the outlet of the control device are less than the emission limit, then the facility is considered to have achieved compliance with the emission limit.

(f) For all filled production and tooling resins, the person subject to this subrule shall adjust the monomer volatile organic compound emission rates determined pursuant to subdivisions (b) and (c) of this subrule using equation 6-4 in paragraph (iii) of this subdivision. If complying pursuant to subdivision (c) of this subrule, the value of PVf, calculated using equation 6-4, must be used as the value of PVi in equation 6-3, as set forth in subdivision (c)(iii) of this subrule. If the non-monomer volatile organic compound content of a filled resin exceeds 5%, by weight, based on the unfilled resin, the excess non-monomer VOC must be added to the monomer volatile organic compound content in accordance with the equation set forth in subdivision (a) of this subrule. If complying pursuant to subdivision (b) of this subrule, the emission rate determined by equation 6-4 must not exceed any of the following limitations:

(i) Tooling Resin: 119.1 lbs monomer VOC/Mg filled resin applied.

(ii) Production Resin: 101.4 lbs monomer VOC/Mg filled resin applied.

(iii) Equation 6-4.

PVF = (PVU)(100 - percent filler) / 100

Where:

PVF = The as-applied monomer volatile organic compound emission rate for a filled production resin or tooling resin, pounds of monomer volatile organic compound per ton of filled material.

PVU = The monomer volatile organic compound emission rate for the neat (unfilled) resin, before filler is added, as calculated using the formulas in table 69-b of this rule.

Percent filler = The weight-percent of filler in the as-applied filled resin system.

(5) A person subject to this rule, shall develop written procedures for compliance with the following work practices for each fiberglass boating manufacturing operation at the source:

(a) All resin or gel coat mixing containers with a capacity equal or greater than 55 gallons, including those used for on-site mixing of putties and polyputties, must have a cover with no visible gaps in place at all times. This subdivision does not apply when material is being manually added to or removed from a container, or when mixing or pumping equipment is being placed in or removed from a container.

(b) No person subject to this rule shall use volatile organic compound-containing cleaning solutions to remove cured resins and gel coats from fiberglass boat manufacturing application equipment. Additionally, a person shall not use volatile organic compound-containing solutions for routine cleaning of application equipment unless 1 of the following applies:

(i) The volatile organic compound content of the cleaning solution is less than or equal to 5%, by weight.

(ii) The composite vapor pressure of the cleaning solution is less than or equal to 0.50 mmHg at 68 degrees Fahrenheit.

(6) A person that is responsible for the operation of a fiberglass boat manufacturing facility that is subject to this rule shall obtain current information, and keep records necessary, for a determination of compliance with this rule, including, but not limited to, all of the following:

(a) The total amounts, in pounds, of atomized molding production operations listed in table 69-a and table 69-b used per month and the weighted-average volatile organic compound contents for each operation, expressed as weight percent.

(b) All calculations performed pursuant to this rule.

(c) The volatile organic compound content of each non-monomer resin and gel coat employed.

(d) For each cleaning material employed for routine application equipment cleaning, either the volatile organic compound content, by weight percent or the composite vapor pressure, in mmHg, whichever is the applicable requirement selected to comply with the cleaning solvent requirements of subrule (5)(b) of this rule.

Mich. Admin. Code R. 336.1637

2023 MR 8, Eff. 4/18/2023