Mich. Admin. Code R. 336.1638

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

Section R. 336.1638 - Emissions of volatile organic compounds from existing wood furniture manufacturing in 2015 ozone nonattainment areas

Rule 638.

(1) As used in this rule:

(a) "Wood furniture" means any product made of wood, a wood product such as rattan or wicker, or an engineered wood product, such as particleboard.

(b) "Wood furniture component" means any part that is used in the manufacture of wood furniture, including, but not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops. Wood furniture component does not include foam seat cushions manufactured and fabricated at a facility that does not engage in other wood furniture or wood furniture component manufacturing operations.

(c) "Wood furniture manufacturing operations" means the finishing, gluing, cleaning, and washoff operations associated with the production of wood furniture or wood furniture components.

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

(3) Except as provided in subrule (6) of this rule, the provisions of this rule do not apply to any wood furniture manufacturing operations that have a potential to emit for volatile organic compounds from all wood furniture finishing operations at the facility, including any related cleaning activities, of less than 25 tons per year. If the potential to emit equals or is more than 25 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 wood furniture finishing operations at that facility.

(4) A person shall not cause or allow the emission of any volatile organic compound from wood furniture 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 subdivision (b), (c), (d), or (e) of this subrule.

(b) A person shall not cause or allow the emission of volatile organic compounds from any existing source applicable to this rule in any of the 2015 ozone nonattainment areas, in excess of the applicable requirements in table 69-c of this subrule.

TABLE 69-c

Volatile organic compound emission limitations for existing wood furniture manufacturing coating operations.

Coating Category	lb of VOC per lb of solids, as applied
Topcoat only	0.8
Topcoat (in combination with sealer)	1.8
Sealer (in combination with topcoat)	1.9
Acid-cured alkyd amino vinyl sealer	2.3
Acid-cured alkyd amino conversion varnish topcoat	2.0
Strippable spray booth coatings	0.8

(c) Using finishing materials where actual emissions are less than or equal to allowable emissions using 1 of the following averaging equations:

Equation 6-5:

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Equation 6-6:

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Where:

N = number of finishing materials participating in averaging.

TC_i = kilograms of solids of topcoat "i" used.

SE_i = kilograms of solids of sealer "i" used.

WC_i = kilograms of solids of washcoat "i" used.

BC_i = kilograms of solids of basecoat "i" used.

ST_i = liters of stain "i" used.

ER_TCi = VOC content of topcoat "i" in kg VOC/kg solids, as-applied.

ER_SEi = VOC content of sealer "i" in kg VOC/kg solids, as-applied.

ER_WCi = VOC content of washcoat "i" in kg VOC/kg solids, as-applied.

ER_BCi = VOC content of basecoat "i" in kg VOC/kg solids, as-applied.

ER_STi = VOC content of stain "i" in kg VOC/liter (kg/l), as-applied.

(d) Using a control system that achieves an equivalent reduction in emissions as the requirements of table 69-c, according to the following provisions:

(i) Determine the overall control efficiency needed to demonstrate compliance using the following equation:

O = ((V - E)/V)(100)

Where:

O = overall control efficiency of the capture system and control device as percentage.

V = actual volatile organic compound content of the finishing system material as-applied to the substrate in pounds of volatile organic compound per pound of solids (lbs VOC/lb solids), or, if multiple finishing materials are used, the daily weighted average.

E = equivalent volatile organic compound emission limits in lbs VOC/lb solids.

(ii) Document that the value of "V" in the equation under paragraph (i) of this subdivision is obtained from the volatile organic compounds and solids content of the as-applied finishing material.

(iii) Calculate the overall efficiency of the capture system and control device, using the procedures in R 336.2040.

(e) Using a combination of the methods presented in subdivisions (b), (c), and (d) of this subrule.

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

(a) Use cleaning materials containing no more than 8.0% by weight volatile organic compound for cleaning spray booth components other than conveyors, continuous coaters and their enclosures, or metal or plastic filters.

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

(c) Collect all volatile organic compound-containing cleaning material used to clean spray guns and spray gun lines in a container and keep the container covered except when adding or removing material.

(d) Control emissions of volatile organic compound-containing cleaning material from washoff operations by doing both of the following:

(i) Equipping the tank used for washoff operations with a cover and keeping the cover closed when the tank is not being used.

(ii) Minimizing dripping by tilting or rotating the part to drain as much cleaning material as possible into the tank.

(e) Use strippable spray booth materials containing no more than 0.8 pound of volatile organic compound per pound of solids, as applied.

(f) Use of conventional air spray to apply finishing materials only under any of the following conditions:

(i) When applying finishing materials that have an as applied volatile organic compound content no greater than 1.0 pound per pound of solids.

(ii) When applying final touch-up and repair finishing materials.

(iii) When using a control device to meet the applicable requirements of this rule.

(6) For the purpose of this rule, recordkeeping for all requirements and applicability demonstrations must be maintained in sufficient detail to demonstrate compliance with all applicable standards of the rule. Records must include, but are not limited, to the following:

(a) All calculations performed pursuant to this rule.

(b) Monthly volatile organic compound emissions and materials usage as needed to meet thresholds described in subrule (3) of this rule.

(c) 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)(a) of this rule.

Mich. Admin. Code R. 336.1638

2023 MR 8, Eff. 4/18/2023