R 336.1638
R 336.1638 Emissions of volatile organic compounds from existing wood furniture manufacturing in 2015 ozone nonattainment areas.
Cite as Mich. Admin. Code R 336.1638
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:
0.9 (Σi=1→N(0.8)(TCi)) ≥ Σi=1→N ERTCi (TCi)
Equation 6-6:
0.9 (Σi=1→N(1.8)(TCi) + (1.9)(SEi) + (9.0)(WCi) + (1.2)(Bci) + (0.791) (STi)) ≥ Σi=1→N
ERTCi(TCi) + ERSEi(SEi) + ERWCi(WCi) +
ERBCi(BCi) + ERSTi(STi)
Where:
N = number of finishing materials participating in averaging.
TCi = kilograms of solids of topcoat “i” used.
SEi = kilograms of solids of sealer “i” used.
WCi = kilograms of solids of washcoat “i” used.
BCi = kilograms of solids of basecoat “i” used.
STi = liters of stain “i” used.
ERTCi = VOC content of topcoat “i” in kg VOC/kg solids, as-applied.
ERSEi = VOC content of sealer “i” in kg VOC/kg solids, as-applied.
ERWCi = VOC content of washcoat “i” in kg VOC/kg solids, as-applied.
ERBCi = VOC content of basecoat “i” in kg VOC/kg solids, as-applied.
ERSTi = 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.