R 336.1624a
R 336.1624a Emission of volatile organic compounds from existing flexographic printing lines located in the 2015 ozone nonattainment areas.
Cite as Mich. Admin. Code R 336.1624a
Rule 624a. (1) As used in this rule:
(a) “Flexible packaging” means packaging that is not rigid and whose shapes can be readily
changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps
utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination
of these materials.
(b) “Flexible packaging printing” means the subset of graphic arts lines used in the printing of
packages or parts of packages.
(c) “Graphic arts” means rotogravure and flexographic printing operations only.
(2) A person shall not cause or allow the emission of any volatile organic compound from inks,
coatings, adhesives, and cleaning material from an existing flexible package printing line located
in the 2015 ozone nonattainment areas, unless all of the applicable provisions of this rule are met.
(3) Except as provided in subrule (8) of this rule, the provisions of this rule do not apply to flexible
package printing lines that are within a stationary source and have a combined actual emission rate
of volatile organic compounds, including related cleaning activities, of less than 3 tons per year on
a 12-month rolling basis before consideration of controls. 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 these printing lines.
(4) Each printing press line with a potential to emit less than 25 tons per year of volatile organic
compounds must meet the overall reduction of volatile organic compound emissions in R
336.1624(3), as applicable.
(5) Each printing press line with a potential to emit of 25 tons per year or more of volatile organic
compounds must meet the overall reduction of volatile organic compound emissions in
subdivisions (a), (b) or (c) of this subrule, as applicable:
(a) The volatile fraction of all inks, coatings, and adhesives used on a flexible package printing
line as applied to the substrate must contain a maximum of 0.8 pounds volatile organic compounds
per pound of solids applied.
(b) The volatile fraction of all inks, coatings, and adhesives used on a flexible package printing
line as applied to the substrate must contain a maximum of 0.16 pounds volatile organic
compounds per pound of materials applied per line.
(c) The overall reduction in volatile organic compound emissions, based on pounds of volatile
organic compounds from a flexible package printing line for which compliance is to be achieved
through the use of 1 or more add-on emissions control devices, must be 1 of the following, based
upon a monthly averaging period:
(i) A minimum of 65% control efficiency if the press was first installed before March 14, 1995,
and control installed before March 1, 2023.
(ii) A minimum of 70% control efficiency if the press was first installed before March 14, 1995,
and control installed on or after March 1, 2023.
(iii) A minimum of 75% control if the press was installed on or after March 14, 1995, and control
installed before March 1, 2023.
(iv) A minimum of 80% control if the press was installed on or after March 14, 1995, and control
installed on or after March 1, 2023.
(d) An overall reduction in volatile organic compound emissions equivalent to the reductions in
subdivision (c) of this subrule, using a combination of control efficiency and low volatile organic
compound content materials.
(6) Facilities must conduct the following work practice standards for cleaning materials:
(a) Keep cleaning materials and used shop towels in closed containers.
(b) Convey cleaning materials from 1 location to another in closed containers or pipes.
(7) Compliance with the emission limits specified in this rule must be based upon all of the
following provisions, as applicable:
(a) Compliance with the emission limit specified in subrule (5)(a) or (b) of this rule must be
based upon all inks, coatings, and adhesives that are used during each calendar month by using
manufactures formulation data for pounds of material, pounds of solids, and volatile organic
compounds in each product.
(b) Compliance with the overall reduction specified in subrule (5)(c) of this rule must be based
upon all inks, coatings, and adhesives that are used during each month, calculated using methods
described in R 336.2040(11).
(c) Compliance with the emission limit specified in subrule (4) of this rule must be determined
as described in R 336.1624(5), (6) and (11).
(d) Sources demonstrating compliance with a control efficiency as required in subrule (5)(c) of
this rule shall submit a stack testing protocol for approval by the department.
(e) If more than 1 control option or limit listed in subrule (5) of this rule is used on a graphic arts
line during a monthly averaging period, compliance must be determined separately for each option
used and be based upon all inks, coatings, and adhesives used for each option during each monthly
averaging period.
(8) A person that is responsible for the operation of a graphic arts line shall obtain current
information and keep records necessary for a determination of compliance with this rule, as
follows:
(a) For lines subject to subrule (5)(a) of this rule:
(i) The volume fraction of volatile organic compounds in each ink, coating, and adhesive as
applied, each month.
(ii) The pounds of solids as applied, each month.
(b) For lines subject to subrule (5)(b) of this rule:
(i) The volume fraction of volatile organic compounds in each ink, coating, or adhesive, as
applied, each month.
(ii) The pounds of materials as applied, each month.
(c) For lines subject to subrule (5)(c) of this rule, follow requirements as described in R
336.2041(10)(d) and (e).
(d) For lines subject to subrule (4) of this rule, follow requirements as described in R 336.1624(4)
and (12).
(e) For cleaning operations, maintain a record of all cleaning materials utilized and their volume
fraction of volatile organic compounds on a monthly basis. When shop towels are properly stored
and conveyed as required by subrule (6) of this rule, the affected source may use a retention factor
from cleaning solutions of up to 50% for VOCs with a composite vapor pressure of no more than
10 mmHg at 20 degrees Celsius.
(f) For flexible package printing lines that are exempt as allowed by subrule (3) of this rule, keep
adequate records of actual emission rates on a 12-month rolling average basis.