The Michigan Department of Environmental Quality (MDEQ) has proposed to revise volatile organic compound (VOC) emission restrictions for various types of coating lines and graphic arts lines. The rule revisions would apply throughout Michigan exemptions from VOC limitations for certain coating and graphic arts processes that emit less than 100 pounds of VOCs per day or 2,000 pounds of VOCs per month. Under the current rules, processes in Kent, Livingston, Macomb, Monroe, Muskegon, Oakland, Ottawa, St. Clair, Washtenaw, and Wayne counties are exempt only if they emit 15 pounds of VOCs per day, or less. For metallic surface coating lines, the exemption applies to lines that emit less than 2,000 pounds of VOCs per month or 10 tons of VOCs per year at facilities with total VOC emissions from all metallic surface coating lines of less than 30 tons per year.
The proposal also includes a new limitation of 4.3 pounds of VOCs per gallon of coating, minus water, as applied, for steel pail and drum interior coatings. The proposal would also make it easier for graphics arts lines to use more than one of the currently available options for complying with the VOC limitations for inks and other coatings during the same calendar day. Finally, the proposal would eliminate obsolete requirements with deadlines that have already passed.
This article was prepared by S. Lee Johnson, a partner in our Environmental Department, and previously appeared in the July, 1998 edition of the Michigan Environmental Compliance Update, a monthly newsletter prepared by the Environmental Department and published by M. Lee Smith Publishers.