Mich. Admin. Code R. 336.1639

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

Section R. 336.1639 - Emission of volatile organic compounds from existing aerospace manufacturing and rework operations in 2015 ozone nonattainment areas

Rule 639.

(1) As used in this rule:

(a) "Aerospace vehicle or component" means any fabricated part, processed part, assembly of parts, or completed unit, with the exception of electronic components, of any aircraft including but not limited to airplanes, helicopters, missiles, rockets, and space vehicles.

(b) "Aqueous cleaning solvents" means a solvent in which water is not less than 80% of the solvent as applied.

(2) A person shall not cause or allow the emission of any volatile organic compounds from any existing aerospace manufacturing or reworking sources located within the 2015 ozone nonattainment areas, in excess of the applicable emission rates provided in subrule (4) of this rule.

(3) With the exception of subrule (6) of this rule, any of the following aerospace manufacturing or reworking operations at a stationary source where aerospace components and vehicles are cleaned or coated is exempt from the limits established in this rule:

(a) Facilities with total potential to emit volatile organic compound of less than 25 tons per year for all operations combined.

(b) Facilities that use separate formulations in volumes of less than 50 gallons per year up to a maximum of 200 gallons total for formulations applied annually.

(c) Research and development operations.

(d) Quality control operations.

(e) Laboratory testing facilities.

(f) Electronic parts and assembly processes, except for cleaning and coating of completed assemblies.

(g) Rework operations performed on space vehicles or antique aerospace vehicles and components.

(h) Touchup, aerosol, and United States Department of Defense classified coating applications.

(4) A person shall not cause or allow the emission of volatile organic compounds from aerospace manufacture and rework operations, unless the following provisions are met:

(a) Except as allowed by subdivision (b) of this subrule, a person that applies specialty coatings to aerospace vehicles or components, including any volatile organic compound-containing materials added to the original coating supplied by the manufacturer, shall comply with the following volatile organic compound emission limitations, minus water and exempt compounds, as applied using1 or more of the coating types listed within table 69-d.

TABLE 69-d

Volatile organic compound content limits for aerospace manufacturing and rework (lbs of VOC/gallon coating)

Coating Type	Limit	Coating Type	Limit
Ablative coating	5.0	Flight-test coatings:
Adhesion promoter	7.4	Missile or single use aircraft	3.5
Adhesive bonding primers:		All other	7.0
Cured at 250 degrees Fahrenheit or below	7.1	Fuel-tank coating	6.0
Cured above 250 degrees	8.6	High-temperature coating	7.1
Adhesives:		Insulation covering	6.2
Commercial interior adhesive	6.3	Intermediate release coating	6.3
Cyanoacrylate adhesive	8.5	Lacquer	6.9
Fuel tank adhesive	5.2	Maskants:
Nonstructural adhesive	3	Bonding maskant	10.3
Rocket motor bonding adhesive	7.4	Critical use and line sealer maskant	8.5
Rubber-based adhesive	7.1	Seal coat maskant	10.3
Structural autoclavable adhesive	0.5	Metallized epoxy coating	6.2
Structural nonautoclavable	7.1	Mold release	6.5
Antichafe coating	5.5	Optical anti-reflective coating	6.3
Bearing coating	5.2	Part marking coating	7.1
Caulking and smoothing compounds	7.1	Pretreatment coating	6.5
Chemical agent-resistant coating	4.6	Primer	2.9
Chemical milling maskant, type I	5.2	Primer for general aviation rework facility	4.5
Chemical milling maskant, type II	1.3	Rain erosion-resistant coating	7.1
Clear coating	6.0	Rocket motor nozzle coating	5.5
Commercial exterior aerodynamic structure primer	5.4	Scale inhibitor	7.3
		Screen print ink	7.0
Compatible substrate primer	6.5	Sealants:
Corrosion prevention compound	5.9	Extrudable/rollable/brushable	2.3
Cryogenic flexible primer	5.4	Sprayable sealant	5.0
Dry lubricative material	7.3	Silicone insulation material	7.1
Cryoprotective coating	5.0	Solid film lubricant	7.3
Electric or radiation-effect coating	6.7	Specialized function coating	7.4
Electrostatic discharge and electromagnetic	6.7	Temporary protective coating	2.7
		Thermal control coating	6.7
Elevated-temperature skydrol-resistant commercial primer	6.2	Topcoat (incl self priming)	3.5
		Topcoat for general aviation rework facility (incl self priming)	4.5
Epoxy polyamide topcoat	5.5	Wet fastener installation coating	5.6
Exterior primer for large commercial aircraft (components or assembled)	5.4	Wing coating	7.1
Fire-resistant (interior) coating	6.7
Flexible primer	5.3

(b) The content limits described in table 69-d can be met by using approved air pollution control equipment if the control system has combined volatile organic compound emissions capture and control equipment efficiency of not less than 81% by weight.

(c) A person shall use 1 or more of the following application techniques in applying any primer or topcoat to aerospace vehicles or components, except as allowed by subdivision (d) of this subrule:

(i) Flow/curtain coat.

(ii) Dip coat.

(iii) Roll coating.

(iv) Brush coating.

(v) Cotton-tipped swab applications.

(vi) Electrodeposition coating.

(vii) High volume low pressure (HVLP) spraying.

(viii) Electrostatic spray.

(ix) Other coating application methods equivalent to HVLP or electrostatic spray applications that are equivalent to HVLP.

(d) A person is not required to meet application techniques listed in subdivision (c) of this subrule in the following situations:

(i) Airbrush or extension on the spray gun to properly reach limited access spaces.

(ii) Application of specialty coatings.

(iii) Application of coating that contain fillers that adversely affect atomization with HVLP spray guns and cannot be applied by other means required in subdivision (c) of this subrule.

(iv) Application of coatings that normally have a dried film thickness of less than 0.0013 centimeters and cannot be applied by other means required in subdivision (c) of this subrule.

(v) Airbrush methods for stenciling, lettering, and other identification markings.

(vi) Hand-held spray can application methods.

(vii) Touch-up and repair operations.

(e) Cleaning using hand wiping must use an aqueous cleaning solvent or have a volatile organic compound composite vapor pressure less than or equal to 45 millimeters of mercury at 20 degrees Celsius except in the following situations:

(i) Cleaning during the manufacture, assembly, installation, maintenance, or testing of components of breathing oxygen systems that are exposed to breathing oxygen.

(ii) Cleaning during the manufacture. assembly, installation, maintenance, or testing of parts, subassemblies, or assemblies that are exposed to strong oxidizers or reducers.

(iii) Cleaning and surface activation before adhesive bonding.

(iv) Cleaning of electronics parts and assemblies containing electronics parts.

(v) Cleaning of aircraft and ground support equipment fluid systems that are exposed to the fluid, including air-to-air exchangers and hydraulic fluid systems.

(vi) Cleaning of fuel cells, fuel tanks, and confined spaces.

(vii) Surface cleaning of solar cells, coated optics, and thermal control surfaces.

(viii) Cleaning during fabrication, assembly, installation, and maintenance of upholstery, curtains, carpet, and other textile materials used on the interior of aircraft.

(ix) Cleaning of metallic and nonmetallic materials used in honeycomb cores during the manufacture or maintenance of these cores, and cleaning of the completed cores used in the manufacture of aerospace vehicles or components.

(x) Cleaning of aircraft transparencies, polycarbonate, or glass substrates.

(xi) Cleaning and solvent usage associated with research and development, quality control, or laboratory testing.

(xii) Cleaning operations, using nonflammable liquids, conducted within 5 feet of energized electrical systems.

(xiii) Cleaning operations identified as essential under the Montreal Protocol for which the administrator has allocated essential use allowances or exemptions in 40 CFR section 82.4.

(f) For cleaning solvents used in the flush cleaning of parts, assemblies, and coating unit components, the used cleaning solvent, except for semiaqueous cleaning solvents, must be emptied into an enclosed container or collection system that is kept closed when not in use or captured with wipers, provided they comply with the housekeeping requirements of subdivision (g) of this subrule. Aqueous cleaning solvents are exempt from these requirements.

(g) All spray guns must be cleaned by 1 or more of the following methods:

(i) Enclosed spray gun cleaning system if it is kept closed when not in use and leaks are repaired within 14 days after the leak is first discovered, or the enclosed cleaner must be shut down until the leak is repaired.

(ii) Unatomized discharge of solvent into a waste container that is kept closed when not in use.

(iii) Disassembly of the spray gun and cleaning in a vat that is kept closed when not in use.

(iv) Atomized spray into a waste container that is fitted with a device designed to capture atomized solvent emissions.

(h) All fresh and used cleaning solvents, except aqueous and semiaqueous cleaning solvents, used in solvent cleaning operations must be stored in containers that are kept closed at all times except when filling or emptying. This includes cloth and paper, or other absorbent applicators, moistened with cleaning solvents except for cotton-tipped swabs used for very small cleaning operations.

(i) A person shall implement handling and transfer procedures to minimize spills during filling and transferring the cleaning solvent to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or used cleaning solvents. Aqueous cleaning solvents are exempt from these requirements.

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

(a) Each person operating a control device for compliance with this rule shall submit a monitoring plan that specifies the applicable operating parameter value, or range of values, to ensure ongoing compliance with subrule (4)(b) of this rule. The monitoring device must be installed, calibrated, operated, and maintained in accordance with the manufacturer's specifications, or an equivalent plan approvable by the department.

(b) Each person using an enclosed spray gun cleaner shall visually inspect the seals and all other potential sources of leaks at least once per month in any calendar year in which it is used. Each inspection must occur while the spray gun cleaner is in operation.

(c) For coatings and cleaning solvents that are not waterborne or water-reducible, the volatile organic compound content of each formulation must be determined, less water and less exempt solvents, as applied using manufacturer's supplied data or method 24 of 40 CFR part 60 , appendix A. If there is a discrepancy between the manufacturer's formulation data and the results of the method 24 analysis, compliance must be based on the results from the method 24 analysis. For water-borne, or water-reducible, coatings, and aqueous and semiaqueous cleaning solvents, manufacturer's supplied data alone can be used to determine the volatile organic compound content of each formulation.

(d) For hand-wipe cleaning solvents required in subrule (4)(e) of this rule, manufacturers' supplied data or standard engineering reference texts or other equivalent methods must be used to determine the vapor pressure or volatile organic compound composite vapor pressure for blended cleaning solvents.

(6) A person subject to this rule shall obtain current information and maintain records for all requirements in sufficient detail to determine compliance, and must be made available to the department upon request. These records must include the following, as applicable:

(a) A list of coatings and usages as described in table 69-d must be maintained with category and volatile organic compound content as applied on a monthly basis.

(b) Each owner or operator using cleaning solvents as described in this rule shall maintain on a monthly basis a list of the following:

(i) For aqueous and semi aqueous hand-wipe cleaning solvents, materials used with corresponding water contents.

(ii) For vapor pressure compliant hand-wipe cleaning solvents, cleaning solvents with their respective vapor pressures or, for blended solvents, volatile organic compound composite vapor pressures.

(iii) For cleaning solvents with a vapor pressure greater than 45 mm Hg, a list of exempt hand-wipe cleaning processes.

(c) Each owner or operator using control equipment under subrule (4)(b) of this rule shall record monitoring parameters as specified in the monitoring plan required under subrule (5)(a) of this rule.

(d) Except for specialty coatings, any source that complies with the recordkeeping requirements of the Aerospace NESHAP, 40 CFR 63.752, complies with the requirements of this subrule.

Mich. Admin. Code R. 336.1639

2023 MR 8, Eff. 4/18/2023