R 336.1634
R 336.1634 Emissions of volatile organic compounds from existing industrial solvent cleaning in 2015 ozone nonattainment areas.
Cite as Mich. Admin. Code R 336.1634
Rule 634. (1) As used in this rule, “composite partial vapor pressure” means the sum of the
partial pressures of the VOC compounds in a solvent.
(2) A person shall not cause or allow the emission of any volatile organic compound from the use
of solvent materials in excess of the limitations of this rule in solvent cleaning operations, which
are described as follows:
(a) Released during the production, repair, maintenance, or servicing of parts, products, tools,
machinery, equipment or in general work areas including storage or disposal of these solvent
materials.
(b) Located in the 2015 ozone nonattainment area.
(3) With the exception of subrule (6) of this rule, the provisions of this rule do not apply to the
following activities:
(a) Janitorial cleaning.
(b) Stripping of cured coatings, cured ink, or cured adhesives.
(c) Cleaning operations in printing pre-press or graphic areas including lithographic, letterpress,
flexographic, screen printing, and rotogravure printing operations.
(d) Cleaning operations associated with digital printing.
(e) Cleaning operations for which limits or work practice standards are contained within
R 336.1610, R 336.1610a, R 336.1620, R 336.1620a, R 336.1621,
R 336.1621a, R 336.1624, R 336.1624a, R 336.1632, R 336.1633, R 336.1635,
R 336.1636, R 336.1637, R 336.1638, and R 336.1639.
(f) Cleaning operations at a facility with emissions less than 3 tons per rolling 12-month period
for all cleaning activity, 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 the cleaning operations
at that facility.
(4) A person that generates volatile organic compound from the use of industrial cleaning solvent
shall meet the following provisions:
(a) The volatile organic compound emissions from the process must meet 1 of the following:
(i) The solvent or solvent solutions must have a volatile organic compound composite partial
vapor pressure of less than or equal to 8 mm of Hg at 20 degrees Celsius.
(ii) The process must have an emission rate of 0.42 pounds of volatile organic compounds per
gallon as applied, except as described for the solvent cleaning operations listed in table 68-d.
TABLE 68-d
Solvent Cleaning Operation
Pounds of volatile
organic compounds
allowed to be emitted
per gallon as applied
(i.) Product cleaning during manufacturing process or surface
preparation for coating, adhesive, or ink application:
1. Electrical apparatus components and electronic
components
2. Medical devices and pharmaceuticals
0.83
6.7
(ii.) Repair and maintenance cleaning:
1. Electrical apparatus components and electronic
components
2. Medical devices and pharmaceuticals:
(i.) Tools, equipment, and machinery
(ii.) General work surfaces
0.83
6.7
5.0
(iii.) Cleaning of ink application equipment:
1. Publication gravure printing
2. Screen printing
3. Ultraviolet ink and electron beam ink application
equipment, except screen printing
4. Specialty flexographic printing
0.83
4.2
5.4
0.83
(iv.) Exemptions from emissions limits in this subdivision:
1. Cleaning conducted as part of the following:
performance laboratory tests on coatings, adhesives, or
inks; research and development programs; and
laboratory tests in quality assurance laboratories.
2. Medical device and pharmaceutical facilities using up to
1.5 gallons per day of solvents.
3. Cleaning with aerosol products if the source uses 1.25
gallons or less per day
N/A
(b) A person subject to this rule shall utilize all of the following cleaning devices and methods
as applicable:
(i) Wipe cleaning.
(ii) Closed containers or hand-held spray bottles from which solvents are applied without a
propellant-induced force.
(iii) Cleaning equipment that has a solvent container that can be, and is closed during cleaning
operations, except when depositing and removing objects to be cleaned, and is closed during non-
operation with the exception of maintenance and repair to the cleaning equipment itself.
(iv) Remote reservoir cleaner if the operator of the cleaner complies with all of the following:
(A) Prevents solvent vapors from escaping from the solvent container by using such devices as
a cover or valve when the remote reservoir is not being used, cleaned, or repaired.
(B) Directs solvent flow in a manner that prevents liquid solvent from splashing outside of the
remote reservoir cleaner.
(C) Does not clean porous or absorbent materials, such as cloth, leather, wood, or rope.
(D) Uses only solvent containers and auxiliary equipment free of all liquid leaks. visible tears,
or cracks.
(v) Non-atomized solvent flow method where the cleaning solvent is collected in a container or
a collection system that is closed except for solvent collection openings and, if necessary, openings
to avoid excessive pressure build-up inside the container.
(vi) Solvent flushing method where the cleaning solvent is discharged into a container that is
closed except for solvent collection openings and, if necessary, openings to avoid excessive
pressure build-up inside the container. The discharged solvent from the equipment must be
collected into containers without atomizing into the open air.
(c) Instead of complying with subdivisions (a) and (b) of this subrule for a solvent cleaning
operation, a person that is subject to this rule may comply by installing and operating volatile
organic compound emission control equipment for the solvent cleaning operation. The volatile
organic compound emission control equipment must have an overall control efficiency of 85%.
(d) Instead of complying with subdivisions (a) and (b) of this subrule, a manufacturer of coatings,
inks, resins, or adhesives may comply with subdivision (e) of this subrule or the following:
(i) Clean portable tables or stationary mixing vats, high dispersion mills, grinding mills, tote
tanks, and roller mills by 1 or more of the following methods:
(A) Use a cleaning solvent that either contains less than 1.67 pounds per gallon of volatile
organic compound or has a composite vapor pressure no more than 8 mm of Hg at 20 degrees
Celsius.
(B) Comply with the following work practices:
(1) Equipment being cleaned must be maintained leak free.
(2) Volatile organic compound-containing cleaning materials must be drained from the cleaned
equipment upon completion of cleaning.
(3) Volatile organic compound-containing cleaning materials, including waste solvent, must
not be stored or disposed of in a manner that causes or allows evaporation into the atmosphere.
(4) Store all volatile organic compound-containing cleaning materials in closed containers.
(C) Collect and vent the emissions from equipment cleaning to a volatile organic compound
emission control system that has an overall capture and control efficiency of not less than 85%, by
weight, for the volatile organic compound emissions. If such a reduction is achieved by
incineration, not less than 90% of the organic carbon must be oxidized to carbon dioxide.
(D) Use organic solvents other than those allowed in subdivision (f)(i) of this subrule provided
no more than 60 gallons of fresh solvent must be used per month. Organic solvent that is reused
or recycled, either on-site or off-site, for further use in equipment cleaning or the manufacture of
coating, ink, or adhesive must not be included in this limit. Also, store all volatile organic
compound-containing cleaning materials in closed containers.
(ii) When using solvent for wipe cleaning, a person shall cover open containers used for the
storage or disposal of cloth or paper impregnated with organic compounds that have been used for
cleanup, or coating, ink, or adhesive removal.
(e) Work practices must be used to minimize volatile organic compound emissions from the use,
handling, storage, and disposal of cleaning solvents and shop towels. Work practices must include,
at a minimum, but not limited to, the following:
(i) All volatile organic compound-containing solvents used in solvent cleaning operations must
be stored in non-absorbent, non-leaking containers which must be kept closed at all times except
when filling or emptying.
(ii) Cloth and paper moistened with volatile organic compound-containing solvents must be
stored in closed, non-absorbent, non-leaking containers.
(iii) Air circulation around cleaning operations must be minimized.
(f) Except as allowed by this subrule, a person shall not atomize any solvent unless the emissions
are vented to volatile organic compound emission control equipment that meets subdivision (c) of
this subrule. The following activities are allowed to atomize solvent without use of a control:
(i) Cleaning of the nozzle tips of automated spray equipment systems, except for robotic
systems.
(ii) Cleaning with spray bottles or containers described in subdivision (b)(ii) of this subrule.
(iii) Printing operations where the roller or blanket wash is applied automatically.
(5) Compliance with this rule must be determined as follows:
(a) For limits specified in subrule (4)(a) of this rule, compliance must be based upon all volatile
organic containing compounds using manufacturers formulation data, United States
Environmental Protection Agency method 24 analysis, safety data sheets, an alternate method, or
combination of the methods stated within this subdivision, as approved by the department and in
sufficient detail to demonstrate compliance with the limitations described in subrule (4) of this
rule.
(b) If a person responsible for a solvent cleaning operation that is subject to this rule employs
volatile organic compound emission control equipment to comply with this rule, pursuant to
subrule (4)(c) of this rule:
(i) Compliance with required control efficiency limits must be determined by performing
emission tests in accordance with a stack testing protocol approved by the department.
(ii) Additional testing of the volatile organic compound emission control equipment for a solvent
cleaning operation in accordance with this rule may be required by the department to ensure
continued compliance.
(c) As appropriate, the composite partial vapor pressure of solvents must be determined by using
generally acceptable methods including, but not limited to, ASTM standards, commonly published
materials and references, or standard chemical laws and calculations.
(6) A person operating a solvent cleaning operation shall obtain current information and maintain
records for all requirements in sufficient detail to determine compliance and make the records
available to the department upon request. The following methods must be used:
(a) The person operating a solvent cleaning operation that is subject to 1 or more of the volatile
organic compound-content limitations or exemptions specified in subrule (4) of this rule shall
collect and record the following information for each cleaning material subject to a volatile organic
compound-content limitation as necessary to determine compliance with that limitation:
(i) The name and identification of each cleaning material and the associated solvent cleaning
activity.
(ii) The volatile organic compound content, of each cleaning material, as determined in subrule (5)
of this rule, in pounds per gallon of material, as employed or the volatile organic compound
composite partial vapor pressures of the solvents or solvent solutions used in the industrial cleaning
operations.
(iii) The volume, in gallons, of each solvent employed in the solvent cleaning operation.
(iv) The total volume, in gallons, of all the solvents employed in the solvent cleaning operation.
(b) If a person operating a solvent cleaning operation employs a control device to achieve and
maintain compliance, that person shall create and submit an approvable preventative maintenance
and monitoring plan to the department which includes details about all appropriate parameters to
be monitored and recordkeeping sufficient to determine compliance.
(c) A person exempting their solvent cleaning operations as allowed by subrule (3) of this rule
shall maintain all information necessary to demonstrate, in sufficient detail, the applicability of
those exemptions and must provide that information to the department upon request.