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.
The Air Quality Division shares information about facilities regulated by state and federal air quality regulations in Michigan through MiEnviro Portal Site Explorer.
This information includes but is not limited to, Permits to Install (PTI), Renewable Operating Permits (ROP), inspection reports, stack test reports, and enforcement documents. Lists of historical information, pre-December 10, 2024 is still available.
For general questions, please contact us at EGLE-Assist@Michigan.gov or 800-662-9278.
For small businesses, the Clean Air Assistance Program is also available for assistance.
An introduction for agribusiness and farmers of the state and federal regulations regarding the storage and handling of anhydrous ammonia fertilizers.
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.
| 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 |
|
| 10,000 lbs. (approx. 1,820 gallons) |
|
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.
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.
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.
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.
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.
A release of 19 gallons (100 lbs.) or more must be reported immediately (within 15 minutes) to all of the following:
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.
Rule Information, Asbestos Notification System, Notification of Intent to Renovate / Demolish Form, etc.
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:
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.
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.
For details on registering in CEDRI, please see the CEDRI How To Register YouTube videos. For questions related to CEDRI reporting, please contact CEDRI@epa.gov.
| 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 |
| 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) |
* See How to Submit Your Notification of Compliance Status
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.
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.
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.
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.
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:
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.
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.
Dust Fallout 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:
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.
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.
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.
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.
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.
For questions regarding permit applicability and subject regulations, please contact your district office or inspector.
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.
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.
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 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.
Gasoline dispensing facilities located within the red borders are subject to state rules. Areas subject to the Michigan Air Pollution Control Rules referenced above.
| 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. |
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.
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:
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.
Metal Fabrication 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.
Chromium Electroplaters 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.
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.
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.
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?
|
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?
|
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:
|
| 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).
Control Equipment: Scrubber 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."
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.
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.
For additional information, contact the MIOSHA Consultation Education and Training (CET) program.
Workers at a Metal Finishing Facility 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.
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.
Oil Pump 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).
Solvent Degreaser 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.
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:
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.
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.
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.
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 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.
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.
