R 336.1610
R 336.1610 Existing coating lines; emission of volatile organic compounds from existing automobile, light-duty truck, and other product and material coating lines.
Cite as Mich. Admin. Code R 336.1610
Rule 610. (1) A person shall not cause or allow the emission of volatile organic compounds from
the coating of automobiles and light-duty trucks, from any existing coating line, in excess of the
applicable emission rates shown in table 62.
(2) A person shall not cause or allow the emission of volatile organic compounds from the coating
of any of the following, from an existing coating line, in excess of the applicable emission rates
shown in column A of table 63 or the equivalent emission rates in column B of table 63:
(a) Cans.
(b) Coils.
(c) Large appliances.
(d) Metal furniture.
(e) Magnet wire.
(f) The nonmetallic surfaces of fabrics, vinyl, or paper.
(3) Subrule (2) of this rule notwithstanding, and as an alternative to the allowable emission rate
established by table 63, the existing paper coating lines at Fletcher Paper Company of Alpena may
comply with subrule (2) of this rule by not exceeding a volatile organic compound emission rate
of 180 tons per calendar year and 30 tons per calendar month.
(4) A person who is responsible for the operation of a coating line 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.
(5) For each coating line, compliance with the emission limits specified in table 62 and table 63
must be based upon all of the following provisions:
(a) For prime coat operations that utilize an electrodeposition process in automobile and light-
duty truck coating lines that are regulated under table 62, compliance must be based upon all
coatings that belong to the same coating category that is used during each calendar month
averaging period. For all other coatings, compliance must be based upon the volume-weighted
average of all coatings that belong to the same coating category and are used during each calendar
day averaging period. The department may specifically authorize compliance to be based upon a
longer averaging period, which must not be more than 1 calendar month.
(b) If coatings that belong to more than 1 coating category are used on the same coating line
during the specified averaging period, then compliance must be determined separately for each
coating category.
(c) The information and records as required by subrule (4) of this rule.
(6) Compliance with the emission limits specified in this rule must be determined using 1 of the
following methods, as applicable:
(a) For the prime-electrodeposition process and for the final repair emission limits specified in
table 62, the method described in either R 336.2040(12)(a) if the coating line does not have an
add-on emissions control device or R 336.2040(12)(b) if the coating line has 1 or more add-on
emissions control devices.
(b) For the primer surfacer and topcoat emission limits specified in table 62, compliance must
be determined by the methodology described in the publication entitled "Protocol for Determining
the Daily Volatile Organic Compound Emission Rate of Automobile and Light-duty Truck
Topcoat Operations", EPA-453/R-08-002, adopted by reference in R 336.1902. References to
topcoat operations in this publication also apply to primer surfacer lines, with the following added
provisions:
(i) Unless specifically included in the adopted publication, if an anti-chip, color-in-prime,
blackout, or spot primer coating is applied as part of either a primer surfacer or topcoat coating
operation, then the anti-chip, color-in-prime, blackout, or spot primer coating must be included in
the transfer efficiency tests for that coating operation, conducted according to section 18 or 19 of
the adopted publication, and the transfer efficiency values in section 20 of the adopted publication
must not be used.
(ii) If spot primer is applied as part of a primer surfacer coating operation, then the daily usage
of spot primer, as calculated in section 8 of the adopted publication, may be derived from monthly
usage of spot primer based upon the number of vehicles processed in the primer surfacer operation
each day. If an add-on emissions control device is used on the coating line application area to
achieve compliance with the primer surfacer or topcoat emission limits specified in table 62, then
the capture efficiency must be determined in accordance with R 336.2040(10).
(c) For the emission limits specified in column B of table 63, the method described in either R
336.2040(12)(e) if the coating line does not have an add-on emissions control device or R
336.2040(12)(f) if the coating line has 1 or more add-on emissions control devices.
(d) For the emission limits specified in column A of table 63, the method described in either R
336.2040(12)(a) if the coating line does not have an add-on emissions control device or R
336.2040(12)(b) if the coating line has 1 or more add-on emissions control devices.
(7) The provisions of this rule, except for the provisions in subrule (4) of this rule, do not apply
to coating lines that are within a stationary source and that have a combined actual emission rate
of volatile organic compounds of less than 100 pounds per day or 2,000 pounds per month as of
November 4, 1999. If the combined actual emission rate equals or is more than 100 pounds per
day for a subsequent day or 2,000 pounds per month for a subsequent month, then this rule
permanently applies to the coating lines.
(8) A person may exclude low-use coatings that total 55 gallons or less per rolling 12-month
period at a stationary source from the provisions of this rule, except for subrule (4) of this rule.
(9) Between November 1 and March 31, a person may discontinue the operation of a natural gas-
fired afterburner that is used to achieve compliance with the emission limits in this rule, unless the
afterburner is used to achieve compliance with, or is required by, any of the following:
(a) Another provision of these rules.
(b) A permit to install.
(c) A permit to operate.
(d) A voluntary agreement.
(e) A performance contract.
(f) A stipulation.
(g) An order of the department.
(10) If the operation of a natural gas-fired afterburner is discontinued between November 1 and
March 31 under subrule (9) of this rule, then both of the following provisions apply between
November 1 and March 31:
(a) All other provisions of this rule, except for the emission limits, remain in effect.
(b) All other measures that are used to comply with the emission limits in this rule between April
1 and October 31 must continue to be used.
(11) Tables 62 and 63 read as follows:
TABLE 62
Volatile organic compound emission limits for existing automobile and light-duty truck coating
lines
Coating Category
Emission Limit
Prime-electrodeposition process
1.21
Primer surfacer3
14.92
Topcoat
14.92
Final repair
4.821
1Pounds of volatile organic compounds per gallon of coating, minus water, as applied.
2Pounds of volatile organic compounds per gallon of applied coating solids.
3The primer surfacer or topcoat coating category would include an anti-chip, blackout, or spot primer coating if
this coating is applied as part of the primer surfacer or topcoat coating operation.
TABLE 63
Volatile organic compound emission limits for existing coating lines
Coating Category
Column A1
Column B2
Metallic surfaces
Coating of cans
Sheet basecoat (exterior and interior and overvarnish;
2-piece
Can exterior (basecoat and overvarnish)
2.8
2- and 3-piece can interior body spray; 2-piece can
interior end (spray or roll coat)
4.2
3-piece can side-seam
5.5
End sealing compound
3.7
Coating of coils
2.6
Coating of large appliances3
2.8
7.5
Coating of metal furniture3
3.0
8.4
Insulation of magnet wire
1.7
Nonmetallic surfaces
Coating of fabric
2.9
Coating of vinyl
3.8
Coating of paper
2.9
1Pounds of volatile organic compounds emitted per gallon of coating, minus water, as applied.
2Pounds of volatile organic compounds emitted per gallon of applied coating solids. The purpose of column B
emission limits is to allow credit for transfer efficiencies greater than the baseline transfer efficiency. Note: department
approval of the transfer efficiency test method is required.
3The allowable emission rate does not apply to coatings that are used for the repair of scratches and nicks.
(12) A coating line subject to R 336.1610a does not need to meet the provisions of R 336.1610.