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The Air Quality Division (AQD) regulates complex industrial processes emitting air pollutants. With regulations for these industries being equally complex, having access to compliance assistance resources is important. This page contains links to a variety of resources designed to help the regulated community. For links to AQD programs, visit our AQD home page.
Electronic Documents Submission
The Air Quality Division (AQD) continues to review, tailor, and amend processes to assist companies in submitting information in an easy and timely manner. We will continue to require the submittal of signed hard copies of documents, but we will accept electronic submittals as the official receipt date. Facilities may continue to submit information electronically and mail the signed hard copies to the appropriate unit or district office. Those choosing to submit electronically, should follow the guidance linked below.
Facilities of Public Interest
The Air Quality Division posts information about facilities regulated by state and federal air quality regulations in the State of Michigan. This information includes, but is not limited to, Permits to Install (PTI), Renewable Operating Permits (ROP), inspection reports, stack test report executive summaries, enforcement documents, annual emissions reports, and air quality actions open for comment.
Air Pollution Control Tax Exemptions
An introduction for agribusiness and farmers of the state and federal regulations regarding the storage and handling of anhydrous ammonia fertilizers.
Are You In Compliance?
Anhydrous Ammonia Fertilizer
- Air Permit
- Emergency and/or Risk Management Plan
- Safety Standards
- Tank Security
Anhydrous ammonia is a valuable, low cost form of nitrogen fertilizer used in Michigan agriculture. It is stored as a liquid in high-pressure tanks at agricultural retailers and on farms. Unintended releases, whether from theft or farm operations can be dangerous to human health. By being proactive and maintaining compliance with your local, state, and federal regulations, anhydrous ammonia can be used safely and securely for its intended agricultural purposes.
How much do you store?
If You Store You Need 500 lbs. (approx. 91 gallons) to notify your Local Emergency Planning Committee (LEPC) and the MI SARA Title III Program 500 gallons
- an air permit
- an emergency response plan
- to comply with MIOSHA safety standards
10,000 lbs. (approx. 1,820 gallons)
- a risk management plan
- to comply with federal chemical facility security standards
Notifying Your LEPC and the MI SARA Title III Program
Your LEPC and the Michigan SARA Title III Program must be notified if you have 500 pounds or more of anhydrous ammonia on site, even if the anhydrous ammonia is on site only during applications. Your LEPC is required to write an offsite emergency response plan for your facility or farm. Contact your LEPC or the Michigan SARA Title III Program at 517-292-7272 for more information.
Notification cards are available on the back of the Michigan State University Extension Bulletin E-2575, "Emergency Planning for the Farm."
This bulletin is available from your county extension office and can also be found at the Michigan Agriculture Environmental Assurance Program web site. The emergency farm plan in this bulletin is used by the LEPC to fulfill their planning responsibilities for farms.
Getting an Air Permit
If you have a stationary anhydrous ammonia tank that holds 500 gallons or more, you must have an Air Permit to Install.
You may apply for a General Permit to Install if your tank capacity does not exceed 30,000 gallons. If your tank capacity is greater than 30,000 gallons, you must apply for an individual air Permit to Install. For assistance with your permit application or if you have questions, call the Clean Air Assistance Program at 800-662-9278.
Emergency Response of Risk Management Plan
If you are required to have an air permit, you are also required to have an onsite Emergency Response Plan. The emergency response plan must be approved by your local fire department or county emergency response agency.
Farms are encouraged to use the plan template in "Emergency Planning for the Farm." For assistance with this plan, contact your LEPC or call 888-678-3464 to contact your county extension office.
A Risk Management Plan (RMP) is required by federal regulation if you are distributing anhydrous ammonia and store more than 10,000 pounds onsite in one or more tanks. Information about RMPs is available at the Michigan Prepares web site.
MIOSHA Safety Standards
The air permit conditions require that you comply with the Michigan Occupational Safety and Health Act (MIOSHA) safety standards, Part 78: Storage and Handling of Anhydrous Ammonia. These standards address tank specifications including safety relief valves and restrictions on the tank location.
Your air permit also requires that you have an inspection and maintenance program that assures ongoing compliance with the MIOSHA safety standards. Most importantly, safety relief valves must be manufactured or recertified within the past five years. Inspections must be conducted at least twice per year prior to spring and fall application seasons.
For statewide safety and health assistance to employers, visit Michigan Occupational Safety & Health Administration web site or call 517-322-1809.
Secure Your Tanks
Anhydrous ammonia is a key ingredient in the illegal production of methamphetamine, making farms a target for anhydrous ammonia theft. Tank security is important!
To report suspicious activities related to anhydrous ammonia security and theft, contact the Michigan Meth Hotline at 866-METH-TIP (866-638-4847) or your local police department.
In 2007, the Anhydrous Ammonia Safety and Security Practices (AASSPs) were developed. These are recommendations addressing the storage and handling practices for the agricultural use of anhydrous ammonia. Sellers and end users implementing the AASSPs are granted immunity from personal injury and property damage claims caused by anhydrous ammonia theft or unlawful use. The AASSPs can be found at Anhydrous Ammonia Safety and Security Practices web site.
The adoption of the AASSPs helps ensure that farmers can continue to use anhydrous ammonia fertilizer by preventing its theft for drug production. If you have any questions, call 800-292-3939.
In addition, if you store 10,000 pounds or more of anhydrous ammonia you must comply with the federal chemical facility security standards. Complete a preliminary online assessment at the Cybersecurity & Infrastructure Security Agency to determine the level of risk associated with your facility or farm. For more information, call 866-323-2957.
Report all chemical releases!
Report Spills and Releases
A release of 19 gallons (100 lbs.) or more must be reported immediately (within 15 minutes) to all of the following:
- Local Authorities: 911
- State Authorities
- Agriculture Pollution Prevention Hotline (Michigan Department of Agriculture and Rural Development): 800-405-0101; or
- Pollution Emergency Alerting System (PEAS), EGLE: 800-292-4706
- Federal Authorities
- National Response Center (United States Coast Guard): 800-424-8802
For Spill and Release Information go to the SARA Title III Spill Release Reporting web site or call the Michigan SARA Title III Program at 517-284-7272. Because it is difficult to determine the amount of a release quickly, it is recommended that every release be reported.
There is no penalty for over-reporting!
Boiler NESHAP - MACT & GACT for Major and Area Sources
EGLE has developed a set of tools to assist Michigan facilities with boiler NESHAP compliance. By simply answering a number of questions, boiler/process heater owners and operators can determine whether they have equipment that is subject to the NESHAP, determine the relevant NESHAP subcategory that applies to the equipment, and then locate the relevant EGLE permit template conditions to include in any Permit to Install or Renewable Operating Permit application for boiler NESHAP subject equipment. Getting started on NESHAP compliance is as easy as 1-2-3:
- Simply answer the questions in the EGLE Boiler NESHAP Navigation Tool and print a report of your evaluation; or answer the questions in the Boiler NESHAP Flowchart to determine whether your equipment is subject to either standard
- Verify your applicability determination by reviewing the relevant Code of Federal Regulations NESHAP requirements and/or the USEPA compliance guides referenced on this web page.
- Select the NESHAP Boiler / Process Heater permit template for your NESHAP subcategory. If one does not exist, please e-mail InfoBoilerNESHAP@michigan.gov and identify the relevant NESHAP (5D or 6J) and subcategory of your equipment. If new, please also indicate the projected installation date for your equipment.
For details on how to calculate the annual heat input for your boiler or process heater, please refer to the NESHAP, Subpart 5D Annual Heat Input Calculation Guide for major sources and to the NESHAP, Subpart 6J Annual Heat Input Calculation Guide for area sources. For questions on the EGLE compliance assistance tools, please contact Christine Grossman at 517-285-5637. For questions on existing boiler NESHAP permit templates, please contact Kurt Childs at 231-878-2045 or Catherine Asselin at 517-582-3604.
Compliance Assistance Tools
- Major Source NESHAP (5D)
- Area Source NESHAP (6J)
- Important Chances to the Rules
- Sending in the Initial Notification Form
- Facilities Affected by the Boiler Rules
- Requirements of the Rule
- Submitting the Electronic Notification of Compliance Status to CEDRI
- Tune-Up Guidance and Questions
- Determining If a Facility is an Area Source
- Why Boilers are Regulated
- Additional Compliance Tools and Documents
- Implementation Tools
- For USEPA information on the federal rulemaking, USEPA technical resources, and/or access to the federal docket for NESHAP 6J and 5D, see Clean Air Act Standards and Guidelines for Energy, Engines, and Combustion.
- For U.S. Department of Energy (DOE), visit the Financial and Technical Assistance Resources web page.
As of March 2014, all reports that are to be submitted electronically pursuant to NESHAP 6J and 5D must be submitted using the USEPA's Compliance and Emissions Data Reporting Interface (CEDRI) on the USEPA's Central Data Exchange (CDX). The reporting tables below summarize the reports that must be submitted to USEPA electronically under these standards. Major sources should submit a duplicate copy of all NESHAP 5D and 6J reports to the EGLE district office. The reporting will be considered by EGLE staff as they renew major source renewable operating permits for sources subject to NESHAP 5D or 6J.
Major Source NESHAP (5D)
Report Name Report Method Citation Performance Test CEDRI 40 CFR 63.7550(h)(1) Continuous Emission Monitoring System Relative Accuracy Test Audit CEDRI 40 CFR 63.7550(h)(2) Compliance Certification (Semiannual, Annual, Biennial, or Five-Year) CEDRI 40 CFR 63.7550(h)(3) and Table 9
Area Source NESHAP (6J)
Report Name Report Method Citation Notification of Compliance Status CEDRI * 40 CFR 63.1225(a)(4)(vi) Performance Test CEDRI 40 CFR 63.1225(e)(1) Continuous Emission Monitoring System Relative Accuracy Test Audit CEDRI 40 CFR 63.1225(e)(2)
With the November 20, 2015, USEPA NESHAP Reconsideration Final: the EPA is retaining a minimum carbon monoxide (CO) limit of 130 parts per million (ppm) and the particulate matter (PM) continuous parameter monitoring system (CPMS) requirements, consistent with the January 2013 final rule. The EPA is making minor changes to the proposed definitions of startup and shutdown and work practices during these periods, based on public comments received. Among other things, this final action addresses a number of technical corrections and clarifications of the rule. These corrections will clarify and improve the implementation of the January 2013 final Boiler MACT, but do not have any effect on the environmental, energy, or economic impacts associated with the proposed action. This action also includes EPAs final decision to deny the requests for reconsideration with respect to all issues raised in the petitions for reconsideration of the final Boiler MACT for which EPA did not grant reconsideration.
Upon promulgation of NESHAP 5D, 6J, and rules related to Commercial and Industrial Solid Waste Incinerators (CISWIs), the USEPA received a number of petitions for reconsideration. On August 5, 2013, the USEPA agreed to reconsider certain aspects of these rules. On January 21, 2015, the USEPA published proposed rulemaking for NESHAP 5D and 6J, along with changes to the CISWI New Source Performance Standard, Subpart CCCC rules. The proposed rulemaking reconsiders certain aspects of the rules, corrects errors, and provides clarification related to the initial rulemaking. Public comment on the proposed rulemaking was due to USEPA by March 9, 2015. Redline versions of the 5D and 6J changes can be found on-line at Clean Air Act Standards and Guidelines for Energy, Engines, and Combustion. Additional resources may be available at USEPA's Controlling Air Pollution from Boilers and Process Heaters as well.
NESHAP 5D and 6J Remand without Vacatur
On February 28, 2014, the USEPA requested a remand of certain parts of NESHAP 5D & 6J without vacatur. The USEPA sought to further justify the numerical emission limits in the standards while the standards remain in place and effective. On May 15, 2014, the U.S. Court of Appeals granted remand without vacatur as requested. On July 14, 2014, the USEPA filed a "Response to Remand of the Record" providing additional explanation on the USEPA's use of the "Upper Prediction Limit" (UPL) to establish the NESHAP 5D emission limits. The UPL is the statistical method the USEPA used to establish emission limits under the NESHAP 5D. Final briefings were due on January 21, 2015, for 5D and February 4, 2015 for 6J. Owners and operators of industrial, commercial, and institutional boilers subject to emission limits are encouraged to continue to move forward with performance testing and fuel analysis to establish the requisite emission limits and operating requirements specified under the standard during this review period.
Performance Testing and Energy Assessment
For help with performance testing and energy assessments, please see the EGLE Clean Air Consultant Directory and the USEPA's Summary of Energy Assessment Requirements under the Area Source Boiler Rule for an overview of the assessment requirements.
Boiler NESHAP Contacts
- Ms. Sara Ayres, Office of Enforcement and Compliance Assurance, Region 5, 312-353-6266
- Ms. Katharina Bellairs, Office of Enforcement and Compliance Assurance, Region 5, 312-353-1669
- Mr. Ethan Chatfield, Office of Enforcement and Compliance Assurance, Region 5, 312-886-5112
- Mr. Jim Eddinger, Office of Air Quality Planning and Standards, Headquarters (Subpart 5D), 919-541-5426
- Ms. Mary Johnson, Office of Air Quality Planning and Standards, Headquarters (Subpart 6J), 919-541-5025
These two fact sheets have been designed to help owners of commercial, industrial, and municipal buildings operating small natural gas-fired and distillate oil-fired boilers comply with the requirements found in a federal air regulation known as the New Source Performance Standards (NSPS) Subpart Dc.
The United States Environmental Protection Agency (USEPA) created NSPS in an effort to regulate new sources of air pollution and ensure that those sources pollute less than the older ones they replace. NSPS have been written for over 75 categories of sources ranging from small boilers to large municipal sewage sludge incinerators. The NSPS typically places limits on the emission of air pollutants such as carbon monoxide, sulfur dioxide, and particulate matter; and requires performance testing, recordkeeping, reporting, and monitoring.
The information in the Initial Notification Form is required by the Federal Clean Air Act and Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451. The applicable rule is 40 CFR, Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. The information is required for each NSPS-subject boiler and must be sent to the appropriate EGLE AQD district office.
Consumer Product Rules
Crushing - Nonmetallic Mineral
The Michigan Environmental Compliance Guide for Nonmetallic Mineral Crushing Facilities is a publication of the EGLE, developed in partnership with the Michigan Aggregate Association. The guidebook is a ready-reference tool for anyone striving toward compliance with state and federal regulations that affect nonmetallic mineral crushing operations. Although some reference is made to local codes, local requirements are not discussed in the guidebook in any detail. Be sure to contact your local government officials for information on applicable local requirements.
The chapters contain discussion on the following topics:
- how to obtain and complete an air permit application
- the three water quality permits programs that may apply a crushing facility (i.e., groundwater discharge, National Pollutant Discharge Elimination System (NPDES), and industrial storm water program)
- water withdrawal
- step-by-step approach to identifying, characterizing, and disposing your waster materials
- storage tanks
- emergency planning
Each chapter targets a specific regulatory program. This web site contains a complete version of the guidebook and allows you to download it by chapter.
- Background Information, Conditions, Application Forms, and District Office Map (includes EQP5756 and EQP5757)
- Instructions for Relocating and Modifying Non-Metallic Mineral Crushing Facilities
- Fillable Relocation Form (EQP5757)
- Fillable Modification Form (EQP5756)
- Fillable General Permit to Install Application - General Information Form (EQP5727)
- Fillable General Permit to Install Application - Additional Information Form (EQP5729)
- District Office Contact Information
Dust and Fallout
Michigan defines fugitive dust under R 336.1106(k) of the Michigan Air Pollution Control Rules as "particulate matter which can originate from indoor or outdoor industrial or commercial processes, activities, or operations and is emitted into the outer air through building openings and general exhaust ventilation." Dust is also characterized as "fugitive" when it originates from unintended activities such as soil disturbances by wind or from human activities such as walking or driving through an unpaved parking lot. Emissions that are discharged from building stacks are not defined as fugitive dust, nor is fugitive dust considered to be a by-product of open burning activities.
Fugitive dust particles are comprised mainly of soil minerals (i.e. oxides of silicon, aluminum, calcium, and iron), but can also consist of sea salt, pollen, spores, etc. The most common regulated forms of particulate matter are known as PM10 (particulate matter with a diameter of 10 microns or less in size) and PM2.5 (particulate matter with a diameter of 2.5 microns or less in size). PM10 consists of contents such as soil, and are generally larger and less harmful than PM2.5 which is manifested in pollutant gases through physical changes or chemical reactions. Although most fugitive dust particles are larger than 10 microns in size (comparatively, the average human hair is 70 microns in diameter), all have the ability to settle quickly on the ground or adversely affect human health or the environment.
What types of activities generate fugitive dust? All activities have the potential to generate fugitive dust, although frequent and high levels of dust particles often originate from activities in the following industrial sectors: agricultural, mining, construction, manufacturing, transportation and utilities, wholesale/retail trade, and service.
Any level of dust generation is considered air pollution. For example, excessive dust can cause damage to plant vegetation and reduce crop and livestock yields through contamination by its chemical composition. Wind generation of dust particles can cause the erosion of valuable topsoil and contribute to the soiling and discoloration of personal property, requiring monetary costs for repeated cleanup activities. Constant soiling can lead to adverse effects on property and land values in areas where fugitive dust generation is a known problem.
Like any air pollution problem, fugitive dust can also be a health nuisance. The smallest particles (2.5 microns or less in diameter) can easily be inhaled and travel to the deepest parts of the lungs, causing nose and throat irritation; respiratory illnesses, such as bronchitis, lung damage, and asthma; and even premature death in sensitive individuals. Generation of fugitive dust can also reduce visibility (i.e., haze) enough to cause moving vehicle or work site equipment accidents that can result in serious injury or death.
Excessive generation of dust and fallout is monitored by each Air Quality Division District Office of the Michigan Department of Environment, Great Lakes, and Energy.
Technical Assistance Resources
- Guidelines for Selecting Dust Suppressants to Control Dust and Prevent Soil Erosion (February 2014)
- Managing Fugitive Dust - A Guide for Compliance with the Air Quality Regulations for Particulate Matter Generation (February 2005). This fact sheet explains the federal and state statutes and rules that apply to fugitive dust from industrial sources in Michigan.
Electric Arc Furnace Steelmaking
40 CFR Part 63, Subpart YYYYY
The NESHAP for area source electric arc furnace steelmaking facilities was issued on December 28, 2007. In the NESHAP, the U.S. Environmental Protection Agency issued emission standards and pollution prevention practices based on Generally Available Control Technology (GACT) for the control of urban Hazardous Air Pollutants (HAPs) that are emitted from electric arc furnaces (EAF) and argon-oxygen decarburization (AOD) vessels. The NESHAP also established pollution prevention management practices based on Maximum Achievable Control Technology (MACT) for mercury in accordance with Section 112(c)(6) of the Clean Air Act. The pollution prevention management practices reduce mercury emissions generated from furnace charge materials.
A stationary reciprocating internal combustion (IC) engine converts chemical energy to mechanical energy via the combustion of fuel and air. The process occurs inside a cylinder where the combustion of the mixture pushes a piston through the cylinder turning a crankshaft. Stationary reciprocating IC engines are nonroad, nonmobile engines that remain stationary at a single site for at least a full year. A stationary RICE can be categorized as either compression ignition (CI) or spark ignition (SI). CI engines normally fire diesel fuel oil, whereas SI engines primarily fire natural gas, landfill gas, or gasoline. Stationary reciprocating IC engines are commonly used to produce electricity and to power mechanical equipment such as pumps and compressors.
The combustion process of IC engines causes the emittance of air pollutants to the atmosphere through the exhaust. These air pollutants have an adverse impact on public health and the environment, especially for susceptible populations with respiratory and cardiovascular issues. Pollutants commonly emitted from stationary reciprocating (IC) engines include nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOCs), and particulate matter (PM), along with hazardous air pollutants (HAP) and toxic air contaminants (TAC) of formaldehyde, acetaldehyde, acrolein, methanol, and PAH. For these reasons, the emissions from stationary reciprocating (IC) engines are regulated by EGLE and the EPA.
If you are planning on installing, modifying, reconstructing, relocating, and/or operating a stationary RICE in Michigan, you may be required to have an air permit. Rule 201 of the Michigan Air Pollution Control Rules requires a person to obtain an approved Permit to Install (PTI) for any potential source of air pollution unless the source is exempt from the permitting process. Not all stationary RICE units will require an air permit. For example, if the engine meets the permit exemptions outlined in Rules 278 and 285(2)(g), the engine could be considered exempt from the need for a PTI. It is important to note that although your stationary RICE may be exempt from state air permitting, it still may be subject to the federal regulations listed below.
Information to have for permit applicability, application, and subject rules and regulations include the following:
- type of source (major or area)
- intended use (emergency, peak shaving, limited use, etc.)
- engine manufacture, model, and year (new or existing)
- date of installation
- emission certification (if available)
- engine design: power rating, displacement per cylinder, method of ignition (CI or SI), type of fuel used, fuel consumption rate, power stroke (two or four), air-to-fuel ratio (rich-burn or lean-burn), air pollution control equipment (if any)
The United States Environmental Protection Agency (USEPA) finalized standards that place requirements on the owners/operators as well as the manufacturers of stationary reciprocating internal combustion engines to minimize the release of HAPs and criteria pollutants. The federal New Source Performance Standards (NSPS), Subparts IIII and JJJJ regulate emissions of criteria pollutants from new, modified, and reconstructed stationary engines. The federal standard, referred to as the National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart ZZZZ regulates HAP emissions from all existing, reconstructed, and new stationary engines. Subpart ZZZZ is complex since there are many previously unregulated smaller engines, including those designated for emergency use, that are now subject to federal regulations.
- USEPA Stationary Engines
- NESHAP Subpart ZZZZ (also known as MACT ZZZZ)
- NSPS Subpart llll - Compression Ignition Internal Combustion Engines
- NSPS Subpart JJJJ - Spark Ignition Internal Combustion Engines
- RICE NESHAP Navigation Tool
- RICE NSPS Navigation Tool
First, determine if your source is considered a major source or minor source of HAP emissions. A major source of HAP emissions has the potential to emit 10 tons per year (tpy) or more of any single HAP, or 25 tpy or more of combined HAPs.
Second, determine if you have a stationary compression ignition (CI) or spark ignition (SI) engine.
Third, consider the purpose of the engine. Is it an emergency or non-emergency engine? Is it a black-start or limited-use engine?
Fourth, verify the engine's site rating in brake horsepower (HP). You may also need to know the engine's displacement in liters per cylinder.
Fifth, determine if the engine is considered existing, new or reconstructed. For a major source with an engine site rating of over 500 HP, existing means the engine was installed or built on-site before December 19, 2002. New or reconstructed means the engine was installed or built on or after December 19, 2002. For a major or area source with an engine site rating under 500 HP, existing means the engine was installed or built on-site before June 12, 2006. New or reconstructed means the engine was installed or built on site or after June 12, 2006.
Once the above information is known, the following tools can be used to determine the federal NESHAP and NSPS requirements that are applicable to your engine.
- RICE NESHAP Summary Table of Requirements
- NSPS Subpart IIII (CI RICE) Summary Table of Requirements
- NSPS Subpart JJJJ (SI RICE) Summary Table of Requirements
The air permit and subject federal regulations for your stationary RICE may contain recordkeeping, performance testing, and reporting requirements to make permit conditions and federal standards practically enforceable.
Monitoring and Recordkeeping
Typical recordkeeping requirements for engines include fuel usage, hours of operation (if emergency), oil analysis results, maintenance performed on engine and air pollution control equipment (if applicable), malfunctions that occurred with duration and actions performed following, and air pollution control equipment performance parameters (if applicable).
Depending on the power output of the engine, the type of source, and the year it was constructed, the engine may be subject to performance testing to show compliance with established emission limits in a PTI or federal regulation. For example, an existing non-emergency Cl engine greater than 100 HP at a major source must have an initial emission performance test, and re-test every 8,760 hours of operation or three years for engines greater than 500 HP (five years if limited use).
The federal regulations have reporting requirements for a subject stationary RICE. These reports could include initial notification of compliance, notification of compliance after a performance test, along with semi-annual and annual compliance reports. The reports check to see if the source is in compliance with the subject emission limitations or operating limitations, or if there were deviations that occurred. A certification by a responsible official is required.
- RICE NESHAP Semiannual Compliance Report Example
- RICE NESHAP Semiannual Compliance Report
- Notification of Compliance Status Example
- Initial Notification for Stationary RICE NESHAP
Annual Emissions Reporting
The federal Clean Air Act requires that each state maintain an inventory of air pollution emissions for certain facilities and update this inventory each year. Michigan's emission inventory is collected annually using the Michigan Air Emissions Reporting System (MAERS) and submitted to the USEPA to be added to the national data bank. Not all facilities are required to report their annual emissions. Facilities that are generally required to report are considered major sources, synthetic-minor sources, or subject to a federal NSPS, such as Subpart IIII or JJJJ.
The following links can be useful for calculating potential to emit (PTE) and in the preparation of a PTI application for a stationary RICE.
- PTE Workbook
- PTI Workbook
- AP-42 Chapter 3: Emission Factors for Stationary Internal Combustion Sources
- TAC Rule 227 Spreadsheet for Demonstrating Compliance with Rule 225
- PTI Technical Review for RICE
For questions regarding permit applicability and subject regulations, please contact your district office or inspector.
Iron and Steel Foundry Area Sources
40 CFR Part 63, Subpart ZZZZZ
The NESHAP for Iron and Steel Foundry Area Sources was issued on January 2, 2008. In the NESHAP, the U.S. Environmental Protection Agency (USEPA) issued emission standards based on Generally Available Control Technology (GACT) for the control of Urban Hazardous Air Pollutants that are emitted from metal melting furnaces at large area sources. The NESHAP also established pollution prevention management practices based on GACT that apply to all area source foundries. The pollution prevention management practices reduce HAP emissions of organics, metals, and mercury generated from furnace charge materials and prohibit the use of methanol as a component of binder formulations in certain applications.
Semiannual Compliance Reporting Form & Instructions
Code of Federal Regulations
- 40 CFR 63.10880 - 10906 (Subpart ZZZZZ)
- 40 CFR 63.10 (Recordkeeping & Reporting Requirements)
- 40 CFR 63.8 (Monitoring Requirements)
Aluminum, Copper, and Other Non-Ferrous Foundry Area Sources
This NESHAP applies to a facility that owns or operates an aluminum, copper, or other nonferrous foundry that is an area source of hazardous air pollutants (HAPs). The standard applies to existing foundries that melt and new foundries that the have the potential to melt at least 600 tons per year of aluminum, copper, and other non-ferrous metals. In addition to the melt threshold, foundries must also use materials that contain one or more foundry metal HAPs for the NESHAP to be applicable.
USEPA Technical Assistance Resources
Federal Vapor Balance System Standard
On January 10, 2008, the U.S. Environmental Protection Agency (USEPA) finalized a standard that requires gasoline stations to minimize the release of gasoline vapors during the filling of tanks. The federal standard, referred to as the National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart CCCCCC is far more encompassing than the existing Michigan rules.
Stage I Gasoline Vapor Balance Systems
Stage I vapor balance equipment collects vapors when underground or aboveground gasoline storage tanks are being filled. During loading, when vapor balance equipment is connected, the vapors travel through a hose from the storage tank to the tanker truck as opposed to escaping through the vent pipe and into the atmosphere when vapor recovery is not connected. The tanker truck returns the vapors to the terminal where they can be recovered as gasoline.
Gasoline is a valuable commodity. Gasoline vapors lead to the formation of ground level ozone (O3), an air pollutant that triggers a variety of health problems including aggravated asthma, reduced lung capacity, and increased susceptibility to respiratory illnesses like pneumonia and bronchitis. Vapor recovery captures an amount of vapor equivalent to 10 to 15 gallons of gasoline each time a tanker truck unloads(1). During a year, that amounts to five million gallons of gasoline that potentially could be recovered in Michigan -- or in other words, 37.5 million pounds (18,750 tons) of volatile organic compounds (VOCs) not emitted into the air(2).
(1) Petroleum Equipment Institute, December 1992, "Keeping It Clean: Making Safe and Spill-Free Motor Fuel Deliveries."
(2) Based on data from Michigan Department of Treasury, Motor Fuel Division. Approximately five billion gallons of gasoline each year is delivered to Michigan gasoline stations, an average load of gasoline is 10,000 gallons, and vapor recovery is responsible for recovering 10 gallons of gasoline vapor per load.
- Federal and State Vapor Balance Requirements for Gasoline Dispensing Facilities (February 2015) - This fact sheet provides a brief explanation of the regulations that minimize the release of gasoline vapors from storage tanks located at retail gasoline stations, and fleet refueling stations.
- For a more detailed discussion of the regulations, please read Gasoline Station Owners & Tanker Truck Drivers: What You Should Know About Vapor Balance Systems" (2nd Edition, May 2011).
- Frequently Asked Questions: Vapor Balance Requirements for Gasoline Dispensing Facilities (February 2015) - This document is designed to help gasoline station owners and tanker truck drivers understand both the Michigan and new federal Stage I vapor balance requirements that reduce emissions during the loading of gasoline storage tanks. With everyone doing their part, the gasoline service industry can make a significant improvement in the air quality of our urban areas. Questions regarding the content of the publication may be directed to Anita Singh, Office of Environmental Assistance at 517-281-2615.
- Initial Notification and Notification of Compliance Status Form and Instructions (EQP3548)
- Performance Testing Notification Form and Instructions (EQP3549)
Michigan Vapor Balance Rules
- Michigan Air Pollution Control Rules
- R 336.1606: Loading gasoline into existing stationary vessels of more than 2,000-gallon capacity at dispensing facilities handling 250,000 or more gallons per year.
- R 336.1627: Delivery vessels and vapor collection systems.
- R 336.1703: Loading gasoline into new stationary vessels of more than 2,000-gallon capacity at dispensing facilities.
- Motor Fuels Quality Act, Public Act No. 104 (April 6, 2006): Michigan Department of Agriculture and Rural Development.
Maps of Areas Subject to Michigan Stage I Vapor Balance
Gasoline dispensing facilities located within the red borders are subject to state rules. Areas subject to the Michigan Air Pollution Control Rules referenced above.
- Detroit Area Counties (seven Southeast Michigan counties)
Tanker Truck Pressure / Vacuum Testing
Stage I Vapor Balance Related Equipment
Required Poppeted Vapor Recovery Adapter Required Poppeted Vapor Recovery Adapter with Recommended Orange Cap Pressure / Vacuum Vent Cap Reproduced courtesy of OPW. May 2006. Signifying Vapor Recovery Reproduced courtesy of OPW. May 2006.
- Storage Tanks: Tanker Truck Vacuum Pressure Testing Requirements (Michigan Department of Licensing and Regulatory Affairs)
- Motor Fuels Quality (Michigan Department of Agriculture and Rural Development)
Light Bulb Crushers (Fluorescent)
Lithography is a form of printing that employs planographic plates, in which the images are neither raised in relief nor depressed. Instead, the flow of ink is controlled by coatings on the plate with different physicochemical properties. Lithography is the predominant printing process in the United States and accounts for approximately 50 percent of all printing applications. Sheet-fed lithography is used for printing books, posters, greeting cards, labels, packaging, advertising flyers, brochures, periodicals, and for reproducing artwork. Web offset lithography is used for periodicals, newspapers, advertising, books, catalogs, and business forms.
The lithographic printing industry operates processes that emit air contaminants. Printing presses, photographic film processors and cleaning operations all have the potential to emit air contaminants. Although these processes may not directly discharge contaminants to the outer air, they do release air contaminants that eventually escape the building and enter the atmosphere.
The indirect or direct release of these air contaminants into the outer air is regulated under federal and state statutes and rules. The purpose of these requirements is to minimize the adverse impact the air contaminants have on human health and the environment. The U.S. Environmental Protection Agency (EPA) has the responsibility for developing new regulations that implement mandates of the federal Clean Air Act Amendments of 1990. Federal air quality regulations are published under Title 40, Parts 50 through 99 of the Code of Federal Regulations (40 CFR Parts 50-99).
Requirements for the lithographic printing industry are monitored and enforced by each Air Quality Division District Office of the Michigan Department of Environment, Great Lakes, and Energy.
Calculation and Exemption Recordkeeping Forms
- VOC Emission Calculation Sheet for Lithographic Printers (EQP3561) - Lithographic printing facilities can use this form to calculate volatile organic compound (VOC) emissions from inks and other materials, such as fountain solutions and cleaning solvents.
- HAP Emission Calculation Sheet for Lithographic Printers (EQP3560) - Use this form to calculate hazardous air pollutant (HAP) emissions from lithographic printing operations.
- Permit to Install Exemption Record for Lithographic Printers (EQP3559) - Lithographic printers using only non-carcinogenic volatile organic compounds (VOC) can use this form to determine if an air use permit is required. This form uses assumptions from the USEPA Control Techniques Guidelines for Offset Lithographic Printing to provide an easy monthly VOC emission estimation.
Metal Fabrication and Finishing NESHAPS
Nine Metal Fabrication and Finishing Source Categories at Area Sources
40 CFR 63, Subpart XXXXXX
On July 23, 2008, the USEPA published the final rule for "National Emissions Standards for Hazardous Air Pollutants (NESHAP): Area Source Standards for Nine Metal Fabrication and Finishing Source Categories." The rule applies only to area sources where the primary activity of the facility is in one of the following nine source categories:
- Electrical and Electronic Equipment Finishing Operations
- Fabricated Metal Products
- Fabricated Plate Work (Boiler Shops)
- Fabricated Structural Metal Manufacturing
- Heating Equipment (except Electric)
- Industrial Machinery and Equipment Finishing Operations
- Iron and Steel Forging
- Primary Metal Products Manufacturing
- Valves and Pipe Fittings
Many facilities perform the metal fabrication and finishing processes addressed by this rule, but they are not subject to Subpart XXXXXX unless they are "primarily engaged" in operations which are classified in one of the above-listed nine source categories. A more detailed description of the affected source categories is included in the text of the rule, published in the Federal Register. To check if you are subject, crosscheck your SIC / NAICS codes with the SIC / NAICS codes that are subject to this rule affiliated with the above source categories.
Compliance Assistance Tools
- EPA Brochure: Summary of Regulations Controlling Air Emissions for Nine Metal Fabrication and Finishing Source Categories
- EPA Flow Charts for Determining Your Requirements: Nine Metal Fabrication and Finishing Source Categories Area Source NESHAP (Subpart XXXXXX)
- EPA Questions & Answers: Nine Metal Fabrication and Finishing Area Source Categories 40 CFR Part 63 Subpart XXXXXX NESHAP (April 2011)
- EPA Questions & Answers: EPA Method 22 - Visual Determination of Fugitive Emissions
- EPA Table Subpart XXXXXX: Nine Metal Fabrication Applicability by EPA Source Category, SIC, and NAICS Codes
- Kansas SBEAP 6X Metal Fabrication and Finishing NESHAP Webinar
The Metal Finishing Industry is comprised of a large variety of operations. Some of the operations include electroplating (chromium, nickel etc.), electroless or non-electrolytic plating, chromic acid etching, other non-electrolytic metal coating processes, such as chromate conversion coating, electroforming, electropolishing, metal finishing, and dry mechanical polishing, electroforming, and electropolishing. While this list is not exhaustive of the industry, there will be a few specific types of processes highlighted in this guidance document. Furthermore, this guidance will reference additional resources that will help the regulated community and the general population to better understand the regulatory requirements that apply to this industry.
The United States Environmental Protection Agency (USEPA), has issued national regulations for the Metal Finishing Industry. These regulations are found in the National Emission Standards for Hazardous Air Pollutants (NESHAP) that are found in Title 40 of the Code of Federal Regulations, Part 63. Additionally, the Michigan Department of Environment Great Lakes and Energy (EGLE) Air Quality Division (AQD) regulates sources of outdoor air pollution, including emissions generated by the Metal Finishing Industry. This guidance will provide information related to the various types of metal finishing processes and the regulations that may apply. It will also include information on how to make permitting decisions.
In November 1994, the USEPA issued national regulations (NESHAP) to control air emissions of chromium from hard and decorative chromium electroplating and chromium anodizing tanks. The Clean Air Act Amendments of 1990 directs the USEPA to regulate emissions for a number of toxic chemicals, including chromium, from a wide range of industrial sources. Chromium electroplating and chromium anodizing tanks are one of the largest sources of chromium emissions in the United States. The hexavalent form of chromium is highly toxic and a known human carcinogen, causing lung cancer. Less is known about the cancer risk of the trivalent form of chromium, but it can accumulate in the lungs and may result in decreased lung function after continuous exposure. It is important to note that the NESHAP regulates the use of both trivalent and hexavalent chromium in electroplating processes.
Over 1,400 facilities perform chromium electroplating and/or chromium anodizing in the United States. Many facilities are small job shops that are located near residential areas. Hard chromium electroplating operations deposit a layer of chromium directly on a base metal to provide wear and corrosion resistance, low friction, and hardness (for hydraulic cylinders, industrial rolls, etc.). Decorative chromium electroplating operations deposit a thin layer of chromium on a base metal, plastic, or undercoating to provide a bright finish and provides wear and tarnish resistance (for bicycles, auto trim, tools, etc.). Chromium anodizing operations form a chromium oxide layer on aluminum to provide corrosion and wear resistance (for aircraft parts, architectural structures, etc.). Except for the trivalent chrome decorative process, which uses the trivalent form of chromium, all other chromium electroplating processes use the hexavalent form.
The Chromium Plating and Anodizing NESHAP is enforced by each district office of the Michigan Department of Environment, Great Lakes, and Energy, Air Quality Division.
The NESHAP was amended in 2012; and those amendments included changes to source compliance dates as well as emission limitations and the standards required for compliance. As of September 21, 2015, perfluorooctyl sulfonates (PFOS) based fume suppressants are prohibited from being added to tanks subject to the chromium electroplating NESHAP (Subpart N). Subpart N defines PFOS-based fume suppressants as a fume suppressant that contains one percent or greater PFOS by weight. There are a variety of PFOS-free alternatives available.
Technical Assistance Resources
Recordkeeping and Reporting Forms
- NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks: Use this set of twelve forms to comply with the recordkeeping and reporting requirements of National Emission Standard for Hazardous Air Pollutants (NESHAP) for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.
- Reporting Forms
- Recordkeeping Forms
- Composite Mesh-Pad Systems or Combination Packed-Bed Scrubber / Composite Mesh-Pad Systems Operation and Maintenance (EQP5708)
- Fiber-Bed Mist Eliminators Operation and Maintenance (EQP5706)
- Packed-Bed Scrubbers Operation and Maintenance: (EQP5707)
- Monitoring Data (EQP5709)
- Daily Process Operations (EQP5711)
- Fume Suppressants
Nickel electroplating provides a hard corrosion resistant finish and is often applied to other metals such as copper. It is almost always applied to other metals prior to decorative chromium electroplating as well. Airborne nickel is carcinogenic to humans and can also cause breathing difficulties in high concentrations. Nickel electroplating generates nickel in the respirable form. In 2019, the AQD re-evaluated the level of toxicity for nickel. Information on that evaluation can be found at the AQD's Air Toxics Screening Level Justifications website.
General Metal Finishing Industry
The scope of the general Metal Finishing Industry is broad and can include electroless or non-electrolytic plating, other non-electrolytic metal coating processes, such as chromate conversion coating, electroforming, electropolishing, metal finishing, dry mechanical polishing, electroforming, and electropolishing.
Permitting - Requirements and Exemptions
The AQD has established Permit to Install (PTI) exemptions and guidance for the Metal Finishing Industry. This section is designed to assist industry in determining compliance requirements for their operations. When trying to determine whether or not a PTI is needed, the AQD has developed the "Permit to Install - Determining Applicability Guidebook." This guidebook will help you decide what exactly is an emission unit and how that concept applies at your facility. It will also help you determine whether an exemption could apply to your emission unit. This guidebook is the first stop when conducting a process evaluation. After you have done the evaluation as described in the guidebook and reviewed the exclusions in Rule 278, the information below can help you to determine if a PTI is required, or if there is a PTI exemption that is right for your metal finishing operation. The rule identified in the flow chart below can be found in the Michigan Air Pollution Control Rules. The PTI exemptions can be found in their entirety in the Air Permit to Install Exemption Handbook.
R 285(2)(l) R 285(2)(vi) R 285(2)(r) Do you own or operate the following equipment and any exhaust system or collector exclusively serving the equipment?
- Die casting machines
- Equipment for surface preparation of metals by use of aqueous solutions, except for acid solutions.
Do you own or operate equipment for carving, cutting routing, turning drilling, machining, sawing, surface grinding, sanding, planing, buffing, sand blast cleaning, shot blasting, shot peening or polishing metals?
- That which has emissions that are released only into the general in-plant environment?
- Used on a non-production basis?
- That which has externally vented emissions controlled by an appropriately designed and operated fabric filter collector that, for all specified operations with metal, is preceded by a mechanical pre-cleaner?
Do you own or operate equipment used for any of the following metal treatment processes if the process emissions are only released into the general in-plant environment:
- Surface Treatment
- Acid Dripping
- Electrolytic Stripping or Electrolytic Plating
This equipment may be exempt pursuant to Rule 285(2)(l). This equipment may be exempt pursuant to Rule 285(2)(vi). This equipment may be exempt pursuant to Rule 285(2)(r).
There are two additional PTI exemption options that may be available for you to use on emission units at your facility, and those are Rule 290 and Rule 291. Rule 290 exempts an emission unit with limited emissions from the requirement to obtain a PTI. Additional guidance on the use and applicability of the Rule 290 exemption can be found in the Rule 290 Guidance document. Finally, Rule 291 exempts an emission unit with de minimis emissions. Please refer to Rule 291 for details on how to utilize this rule.
To be eligible for a specific PTI Exemption listed in Rule 280-291, any owner or operator of an exempt process or exempt process equipment must be able to provide information demonstrating the applicability of the exemption as specified in Rule 278(a).
If you determine that a PTI is needed, the AQD has additional guidance available for the Metal Finishing Industry that includes information that would need to be included in a PTI application. The guidance is called "Information For Technical Review - Surface Treatment Processes." This guidance specifies exactly what information is required when submitting a PTI application for review for plating, pickling, etching, and cleaning operations. Additionally, the AQD also has guidance for air pollution control equipment, including scrubbers which are frequently utilized in the Metal Finishing Industry. The guidance is called "Additional Technical Information for Control Equipment: Scrubber."
Federal Regulation - Plating and Polishing NESHAP
On June 12, 2008, the USEPA issued final national air toxics standards for smaller-emitting sources, known as area sources, in the plating and polishing industry. These requirements apply to existing and new area sources and include plating and polishing tanks, dry mechanical polishing operations, and thermal spraying operations that use or emit compounds of one or more of the following metal toxic air pollutants: cadmium, chromium, lead, manganese, and nickel. The final rule includes management practices such as the use of wetting agent/fume suppressants. It requires equipment standards such as the use of tank covers or control devices, and the capture and control of emissions from thermal spraying and dry mechanical polishing. The USEPA amended this final rule in September 2011 to clarify certain aspects of the 2008 rule. The Plating and Polishing Area Source NESHAP is codified in 40 CFR Part 63, Subpart WWWWWW. As of 2020, Michigan has not accepted delegated authority for this NESHAP and, therefore, our inspectors do not determine compliance with the established requirements.
EGLE Industrial Pretreatment Program PFAS Initiative
In February 2018, a special effort under the National Pollutant Discharge Elimination System (NPDES) program, EGLE Water Resources Division (WRD) launched the Industrial Pretreatment Program (IPP) Per- and Polyfluoroalkyl Substances (PFAS) Initiative. This initiative aims to reduce and eliminate certain PFAS from industrial sources which are commonly found at Metal Finishing Industry operations that may pass through municipal wastewater treatment plants and enter lakes and streams, potentially causing fish consumption advisories or polluting public drinking water supplies. Additional information on the EGLE IPP PFAS Initiative, can be found on the Water Resources Division website.
The Michigan Occupational Safety and Health Administration (MIOSHA) has informative fact sheets that may be useful for the Metal Finishing Industry.
- MIOSHA Hexavalent Chromium - National Emphasis Program (NEP)
- MIOSHA Fact Sheet Electroplating - Automated Hoist/Transfer Systems
- MIOSHA Part 526 Dipping and Coating Operations
- MIOSHA Part 315 Chromium (VI) in General Industry
For additional information, contact the MIOSHA Consultation Education and Training (CET) program.
Questions About the Metal Finishing Industry
The Metal Finishing Industry and the air permitting rules can be challenging to work through. If you have any questions, feel free to call your district office and speak to the inspector for your facility. For other air quality related questions, contact the Environmental Assistance Center at 800-662-9278 and ask to speak to an Air Quality Specialist.
Oil and Gas
Under the Clean Air Act Amendments of 1990, the U.S. Environmental Protection Agency (USEPA) was charged with regulating 188 sources of toxic air pollutants. These toxic air pollutants, also known as hazardous air pollutants (HAPs), are pollutants which are known or suspected to cause cancer or other serious health effects such as birth defects or reproductive effects. On July 16, 1992, the USEPA published a list of industry groups (known as source categories) that emit one or more of these hazardous air pollutants. The Clean Air Act requires the USEPA to develop standards that are based on stringent air pollution controls, known as maximum achievable control technology (MACT). Oil and natural gas production and natural gas transmission and storage are source categories listed by the USEPA for regulation.
Emissions of HAPs from oil and natural gas production facilities and natural gas transmission and storage facilities occur during the separation, upgrade, transport, and storage of crude oil, condensate, natural gas, and related products and by-products. In addition, emissions occur as a result of vapor leaks from pumps, compressors, valves, flanges, and other equipment in liquid and gas service that contribute to emissions of hazardous air pollutants.
Emissions from various processes and operations at oil and natural gas facilities and natural gas transmission and storage facilities typically contain at least five different HAPs. The primary HAPs emitted from these facilities are benzene, toluene, ethyl benzene, mixed xylenes, and n-hexane.
Approximately 440 of an estimated 100,000 to 250,000 facilities nationwide are affected by the final oil and natural gas production emission standards. The USEPA is requiring affected facilities to apply existing and affordable control technologies to known emission points. In addition, in an effort to increase flexibility, the USEPA is encouraging the use of pollution prevention to reduce emissions of HAPs from the process vents at glycol dehydration systems. These vents constitute the largest single identified HAP emission point for the oil and natural gas production source category.
Requirements for the oil and gas industry are monitored and enforced by each Air Quality Division District Office of the Michigan Department of Environment, Great Lakes, and Energy.
Technical Assistance Resources
- List of Volatile Hazardous Air Pollutants
- Definition of "Facility"
- Notification Letter to Facilities subject to the Oil and Natural Gas Production Facilities and Natural Gas Transmission and Storage Facilities NESHAP
Notification Report Forms
In December 1994, the U.S. Environmental Protection Agency (USEPA) issued national regulations (National Emission Standards for Hazardous Air Pollutants or NESHAP) to control toxic air pollutant emissions from solvent cleaning machines that use any of the following halogenated solvents: methylene chloride; perchloroethylene; trichloroethylene; 1,1,1-trichloroethane; carbon tetrachloride; chloroform; or any combination of these halogenated HAP solvents. This regulation is a pollution prevention regulation that reduces solvent usage by requiring the use of good housekeeping practices and efficient, well-controlled cleaning machines. Solvent cleaning machines are used to dry materials and remove soils, such as grease, wax, and oil from metal parts (such as nuts, bolts, and springs), circuit boards, sheet metal, assemblies, and other materials. The halogenated solvents listed above are known or suspected carcinogens; and they have high usage and emissions in solvent cleaning. Therefore, the USEPA has determined that emissions from cleaning machines using these solvents present a threat to human health or the environment. The USEPA regulates the emissions of these machines in order to meet the requirements of the Clean Air Act Amendments of 1990.
The Halogenated Solvent Degreasing NESHAP is enforced by each Air Quality Division (AQD) district office at the Michigan Department of Natural Resource and Environment (EGLE).
Technical Assistance Resources
- How the Clean Air Act Affects Halogenated Solvent Cleaning Operations (November 1997) - On December 2, 1994, the USEPA promulgated the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Halogenated Degreasers. This fact sheet is a "plain English" version of the actual regulation.
- Questions and Answers on the Halogenated Solvent NESHAP (December 1997) - Answers to commonly asked questions about the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Halogenated Degreasers.
- Initial Notification Report for All Machines (EQP3565) - Use this form to comply with the notification requirements of the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Halogenated Degreasers.
Surface Coating Operations NESHAPS
Miscellaneous Metal Parts and Products
40 CFR 63, Subpart MMMM
This NESHAP applies to a facility that owns or operates a miscellaneous metal parts and products surface coating operation that is a major source, is located at a major source, or is part of a major source of hazardous air pollutant (HAP) emissions. An affected source that uses 250 gallons per year or more of coatings that contain HAP could be subject to this rule.
Paint Stripping and Miscellaneous Surfaces
40 CFR 63, Subpart HHHHHH
The NESHAP for paint stripping and miscellaneous surface coating operations at area sources rule was proposed in the Federal Register on September 17, 2007, and the final Rule was promulgated on January 9, 2008. The Rule regulates three activities:
- Paint stripping using methylene chloride.
- Surface coating of motor vehicles and mobile equipment.
- Surface coating of miscellaneous metal and plastic parts.
- Paint Stripping
- Surface Coating of Motor Vehicles and Mobile Equipment
- Surface Coating of Miscellaneous Metal and Plastic Parts
Frequently Asked Questions
- Initial Notification/Compliance Status (EQP3586)
- Notification of Compliance Status
- Petition for Exemption (for Mobile Vehicle or Mobile Equipment Surface Coating only)
- USEPA Collision Repair Campaign Training
- Collision Repair Training Video
- Surface Coating of Miscellaneous Metal and Plastic Parts
- Federal Register 40CFR Part 63, Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (January 9, 2008; Page 1760)
We Need Your Input
The following documents were mailed to Michigan automotive collision shops in November 2010. We encourage you to complete and submit the Self-Certification Checklist so that we can measure and improve the effectiveness of our outreach to you.
Air Permits for Small Surface Coating Operations
Surface coating operations are subject to a variety of state and federal air requirements. One of them is obtaining an air permit to install (PTI) from EGLE's Air Quality Division for small surface coating operations. This document provides operators of small surface coating operations (approximately 30 tons per year or less of volatile organic compounds or VOCs) a logical approach to determining what activities trigger the need for a PTI, as identified in Rule 201 of the Michigan Administrative Rules (Michigan Rules) for Air Pollution Control. Additional information about permit exemptions and the General Permit to Install will help guide you through the air permit process.
- Rule 287(2)(c) Permit to Install Exemption Record: Surface Coating Equipment" - Rule 287(2)(c) of the Michigan Administrative Rules for Air Pollution Control exempts surface coating operations that use less than 200 gallons of coating per month from having to obtain a permit to install. This form can be used to comply with the coating usage record-keeping requirements of the rule:
- Michigan Air Pollution Control Rules Rule 290 Guidance (February 2020)" - Rule 290 of the Michigan Administrative Rules for Air Pollution Control exempts sources of air pollution with limited emissions for having to obtain a permit to install. This guidance can be used when determining how to comply with emission data record-keeping requirements of the rule.
- VOC / HAP Emissions Calculation: Spreadsheet and Instructions - This recordkeeping spreadsheet can be used to calculate VOC and HAP emissions from paints, solvents, and other evaporative loss products. This spreadsheet is specifically geared towards smaller companies who need help with recordkeeping to demonstrate compliance with their general permit or exemption. NOTE: You must save the file to your computer before entering data into the spreadsheet. When you open the spreadsheet, you may get a message box asking you to enable/disable macros. Please click "enable macros." Go up to your top menu and click on "Tools" > "Macro Security." You will need to change your security level to medium and then press OK. You will now be able to use the spreadsheet.
- General Permit to Install for a Coating Line Emitting up to 10 tons per year of volatile organic compounds
- Permit to Install Application and Instructions
Plastic Parts and Products
40 CFR 63, Subpart PPPP
This NESHAP applies to a facility that owns or operates a plastic parts and products surface coating operation that is a major source, is located at a major source, or is part of a major source of hazardous air pollutant (HAP) emissions. An affected source that uses 100 gallons per year or more of coatings that contain HAP could be subject to this rule.
Technical Assistance Resources
Webinars - Past Events and Recordings
Once the page opens, type the word "air" (with no quotation marks) in the search box. Past webinars include "A Deep Dive into Air Permitting: A Webinar Series," "Clean Air Act (Title V) ROP Webinar Series," and "Year of Clean Air: AQD 101 Webinar Series."
Wood Burning and Air Quality
Wood burning has been a part of Michigan's heritage. Homeowners choosing to use fireplaces and woodstoves need to understand that healthy indoor and outdoor air quality requires good wood burning habits. The following guidelines for responsible wood burning minimize health problems and help keep the environment clean. For Open Burning information, visit the open burning web page.
Wood Burning Tips
- Know When to Burn
- Monitor all fires; never leave a fire unattended.
- Upgrade an older woodstove to one with a catalytic combustor that burns off excess pollutants.
- Be courteous when visitors come to your home. Wood smoke can cause problems for people with developing or sensitive lungs (i.e. children, the elderly) and people with lung disease
- Know What to Burn
- Split large pieces of wood into smaller pieces and make sure it has been seasoned (allowed to dry for a year). Burning fresh cut logs = smoky fires.
- When buying wood from a dealer, do not assume it has been seasoned.
- Season your fuel wood.
- Small hot fires are more efficient and less wasteful than large fires.
- Never burn chemically treated wood or non-wood materials.
- Manufactured fire logs provide a nice ambience, have the least impact to air quality, and are a good choice for homeowners who use a fireplace infrequently.
- Know How to Burn
- Proper combustion is key. Make sure your wood fire is not starved. If excess smoke is coming from the chimney or stack, the fire isn't getting enough air.
- Visually check your chimney or stack 10 to 15 minutes after you light a fire to ensure it is not emitting excess amounts of smoke.
- Homeowners should have woodstoves and fireplaces serviced and cleaned yearly to ensure they are working properly.
Outdoor Wood Boilers
- Outdoor Wood Boiler (OWB) Fact Sheet
- OWB Photos are Worth a Thousand Words
- Conventional (High Polluting) OWB Plume Data
- High-Efficiency (Clean) OWB Plume Data
- Smoke Gets in Your Lungs. This is a report which documents health problems associated with OWB.
- Outdoor Boilers - Wood Heat Organization, Inc. Info
- OWB Technical Handbook - Environment Australia
Wood Burning Links
- Outdoor Burning Model Ordinance: A Guide for Michigan Counties, Cities, Villages, and Townships
- MSU Extension Service
Wood Smoke and Health Links
- Burning Issues. Public education about the hazards of exposure to wood smoke and pollution.
- Health Effects of Wood Smoke
- Wood Heat Organization, Inc. is a nonprofit, non-governmental agency committed to the responsible use of wood as a home heating fuel.
- Fireplace Safety Tips
- Woodburning Study in Mio, Michigan 1983
- New York Times Article on Outdoor Wood Boilers
Wood Burning Regulations in Other States
- Know When to Burn
Wood Furniture Manufacturing
The Clean Air Act as amended in 1990 (CAA) directs the U.S. Environmental Protection Agency (USEPA) to regulate emissions of 188 toxic chemicals (hazardous air pollutants or HAPs) from a wide range of industrial sources by establishing National Emission Standards for Hazardous Air Pollutants (NESHAP). The NESHAP is a national standard that applies to facilities that are engaged in, either in part or in whole, the manufacture of wood furniture or wood furniture components. Examples of wood furniture components include (but are not limited to) drawer sides, cabinet doors, and laminated tops.
Wood is coated to protect it from physical and chemical damage, and natural degradation, as well as to impart an aesthetically pleasing finish. Surface coating of wood furniture was listed as a source category to be regulated under the CAA because the materials traditionally used by the furniture industry contain a substantial quantity of solvents that volatilize to the air within the plant and/or are directly vented to the outside, usually without treatment. Many of the coatings, adhesives, and solvents used in the wood furniture industry contain toxic chemicals such as toluene, xylene, methanol, methyl ethyl ketone, glycol ethers, and formaldehyde.
Wood furniture manufacturers are the largest industrial users of solvents in paints and coatings among original equipment manufacturers in the United States, using over twice as much solvents as automobile manufacturers. Exposure to these and other air toxics associated with wood furniture manufacturing can cause adverse health effects, including eye, nose, throat, and skin irritation; damage to the heart, liver, and kidneys; and reproductive effects.
Requirements for the wood furniture manufacturing industry are monitored and enforced by each district office of the Air Quality Division, Michigan Department of Environ, Great Lakes, and Energy.
Technical Assistance Resources
- Hazardous Air Pollutants: A listing of all 188 compounds designated as hazardous air pollutants (HAPs).
- Wood Furniture Manufacturing Operations NESHAP: Questions & Answers: This document contains answers to the most commonly asked questions regarding the NESHAP for wood furniture manufacturing operations (October 1996).
Notification Report Form
- Initial Notification Letter: A cover letter that the Air Quality Division sent out to facilities believed to be subject to the NESHAP for wood furniture manufacturing operations (July 2, 1995).
- Initial Notification Report (EQP5712): Use this form to comply with the notification requirement of the NESHAP for wood furniture manufacturing operations (June 1996).