ENERGY AND ENVIRONMENT CABINET 

OFFICE OF THE SECRETARY 

Steven L. Beshear 

Governor 

Ms. Gwen Keyes-Fleming 

Regional Administrator 

U.S. EPA, Region 4 

61 Forsyth Street, SW, Suite 9T43 

Atlanta, GA 30303-8960 

Dear Ms. Fleming, 

Capital Plaza Tower 

500 Mero Street, 12111 Floor 

Frankfort, Kentucl<y 40601 

Phone: (502) 564-3350 

Fax: (502) 564-7484 

http://eec.ky.gov 

May 3, 2012 

Leonard K. Peters 

Secretary 

In a letter dated May 26, 2011, the Kentucky Division for Air Quality (Division) received 

a State Implementation Plan (SIP) submittal package from Louisville Metro Air Pollution 

Control District (District). The package included two separate SIP requests for one regulation 

and one specific source. The requested actions are as follows: 

1. Regulation 3.01, version 5, Ambient Air Quality Standards- Submit for Approval into 

the SIP. 

2. Ford Motor Company, Louisville Assembly Plant, Reasonably Available Control 

Technology (NOx RACT)- Withdraw the NOx RACT permit from the SIP and replace it with 

Title V Permit No. 147-97-TV (R2). 

The Division granted concurrence for Regulation 3.01 in a letter dated June 23, 2011. 

Concurrence for replacing the Ford Motor Company NOx RACT Board Order from the SIP with 

Title V Permit No. 147-97-TV (R2) is hereby granted as well. 

The Kentucky Energy and Environment Cabinet (Cabinet) hereby requests that the U.S. 

EPA approve the enclosed regulatory amendments as a revision to the Jefferson County portion 

of the Kentucky SIP. Included in the administratively complete SIP submittal package are 

documentation of public comment periods and public hearings that were held in regard to these 

SIP revisions. 

KentuckyUnbridledSpirit.com An Equal Opportunity Employer M/F/0 

Ms. Gwen Keyes-Fleming 

May 3, 2012 

Page 2 

Additionally, pursuant to 40 CFR 51.103(a), two hard copies and a disc containing all 

documents are included. The Cabinet appreciates your prompt response to this request. If you 

have any further questions or concerns regarding this submittal, please contact Andrea Smith at 

(502) 564-3999, ext. 4410 or by e-mail at Andrea.Smith@ky.gov. 

Cc: Lynorae Benjamin 

LKP/lg 

Enclosures 

KentuckyUnbridledSpirit.com 

~~ Leonard K. Peters, Secretary 

An Equal Opportunity Employer M/F/D 

AIR POLLUTION CONTROL DISTRICT 

GREG FISCHER 

MAYOR 

Mr. John Lyons, Director 

Division for Air Quality 

200 Fair Oaks Lane, 1st Floor 

Frankfort, KY 40601 

Dear~: ]:hM,' 

LOUISVILLE, KENTUCKY 

LAUREN ANDERSON, DIRECTOR 

May 26,2011 

The Air Pollution Control District of Jefferson County (District) requests that the enclosed 

material be submitted to the U.S. Environmental Protection Agency (EPA) as revisions to 

the Jefferson County portion of the Kentucky State Implementation Plan (SIP). Enclosed 

are two paper copies and two CD' s, one of each for the EPA and one of each for the Kentucky 

Division for Air Quality (DAQ). 

This package contains separate SIP requests for one regulation and one source specific 

requirements. The District requests that the Commonwealth request the following for each: 

1. Regulation 3.01,Ambient Air Quality Standards- Submit for approval into the SIP. 

2. Ford Motor Co., Louisville Assembly Plant, Reasonably Available Control Technology 

for a major source of oxides of nitrogen (NOx RACT) Board Order- Withdraw from the 

SIP. 

Your prompt consideration of this request is appreciated. If you have any questions or 

comments, please contact Ms. Cynthia Lee at (502) 574-7217. 

Enclosures 

Sincerely, 

Kc?---

Lauren Anderson 

Executive Director 

www.louisvilleky. gov 

WWW.LOUISVILLEKY.GOV/APCD 850 BARRET AVENUE, ROOM 205' LOUISVILLE, KENTUCKY 40204-1745 502.574.6000 FAX, 5'02.574.5306 

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louisville Metro Air Pollution Control District 

State Implementation Plan Amendment Submittal 

District Regulations 

Regulation 3.01, Ambient Air Quality Standards 

Source Specific NOx RACT 

Ford Motor Co., Louisville Assembly Plant 

Prepared by: 

louisville Metro Air Pollution Control District 

850 Barret Avenue, Room 205 

louisville, Kentucky 40204 

May 26,2011 
Contents 

District Regulation 3.01 

Ambient Air Quality Standards 

Request for EPA Action 

Completeness Checklist and Pollutant/Area Identification 

Regulation Version 4 (June 2005) 

Regulation Version 5 (April 2011) 

Red line strike out version 

Final version 

Regulatory Impact Assessment 

Comment Response Document 

Strategy Committee Meeting Agenda 

Strategy Committee Minutes 

Public Notices- first and second 

Public Hearing and Board Meeting 

Minutes of the Public Hearing 

Minutes of the Regular Meeting 

------------------------------------------------------------------------------ ------------------------------------------------------------------------------

Ford Motor Co., LAP 

Request for EPA Action 

Permit No: 147-97-TV (R2) pages 4 and 45 

Board Order 

Public Notice 

Cover letter 

Permit No: 147-97-TV (R2) and Statement of Basis 

Permit No: 245-09-C (R1) and Statement of Basis 
Regulations 3.01 

District Part 3 Regulations were consolidated into one regulation and the National Ambient Air Quality 

Standards were updated on June 21, 2005. 

The version of Regulation 3.01, Purpose of Standards and Expression of Non-Degradation Intention that 

is currently approved in the SIP is Version 3 dated June 13, 1979. This approval was published at 66 FR 

53658 on October 23, 2001. The amendment that occurred on June 21, 2005 (Version 4) includes the 

contents of Regulations 3.02, 3.03, 3.04, and 3.05. 

The version of Regulation 3.02, Applicability of Ambient Air Quality Standards that is currently approved 

in the SIP is Version 3 dated June 13, 1979. The version of Regulation 3.03, Definitions, that is currently 

approved in the SIP is Version 3 dated June 13, 1979. The version of Regulation 3.04, Ambient Air Quality 

Standards, that is currently approved in the SIP is Version 5 dated April20, 1988. The version of 

Regulation 3.05, Methods of Measurements, that is currently approved in the SIP is Version 4 dated April 

20, 1988. These approvals were published at 66 FR 53658 on October 23, 2001. All four regulations 

were repealed and superseded by Regulation 3.01 on June 21, 2005. 

The District forwarded Regulation 3.01 Version 4, renamed Ambient Air Quality Standards, to the 

Kentucky Division for Air Quality (DAQ) for submittal to EPA to revise the SIP on November 9, 2010. The 

submission was subsequently forwarded to EPA, Region 4 on March 22, 2011. 

An administratively complete package for Version 5 Ambient Air Quality Standards, is contained herein. 

The District requests that the Commonwealth request that Version 5 of Regulation 3.01 be approved 

into the SIP. 
Completeness Checklist 

Regulation 3.01 Ambient Air Quality Standards, formerly, Purpose of 

Standards and Expression of Non-Degradation Intention 

Regulation Version 4 (June 2005) 

Regulation Version 5 (April 2011) 

Red line strike out version 

Final version 

Regulatory Impact Assessment 

Comment Response Document 

Strategy Committee Meeting Agenda 

Strategy Committee Minutes 

Public Notices- first and second 

Public Hearing and Board Meeting Agenda 

Minutes of the Public Hearing 

Minutes of the Regular Meeting 

Pollutant/ Area Identification 

Pollutant: All 

Affected Area: Jefferson County, Kentucky 

Location: Louisville MSA 

Area Designation: Nonattainment- Annual PM2.s; 

Attainment- all other pollutants 

Area SIP Status: Ozone- maintenance 

Resulting Emissions Changes: N/A 

Increase 

Decrease -------

·.:·'· 
PART 3 

Ambient Air Quality Standards 

REGULATION 3.01 Ambient Air Quality Standards 

Air Pollution Control District of Jefferson County 

Jefferson County, Kentucky 

Relates To: KRS Chapter 77 Air Pollution Control 

Pursuant To: KRS Chapter 77 Air Pollution Control 

Necessity And Function: KRS 77.180 authorizes the Air Pollution Control Board to adopt and 

enforce all orders, rules, and regulations necessary or proper to accomplish the purposes of KRS 

Chapter 77. This regulation establishes ambient air quality standards, the methods for 

measuring air contaminants, and the intention of the Board to prohibit further significant and 

avoidable deterioration of air quality. 

SECTION 1 Definitions 

Terms used in this regulation that are not defined in this regulation shall have the meaning given 

them in Regulation 1.02 Definitions. 

SECTION 2Purpose 

The purpose of an ambient air quality standard is to establish a concentration, including a 

time-averaging interval over which that concentration is measured, for a particular air 

contaminant that the Board determines is necessary, with an adequate margin of safety, to protect 

public health and welfare from any known or anticipated adverse effect of that air contaminant. 

SECTION 3Non-degradation Intention 

In establishing an ambient air quality standard, it is the intention of the Board to prohibit further 

significant and avoidable deterioration of air quality in areas where the air quality is presently 

numerically equal t.o or better than the standard. 

SECTION 4 General Prohibition 

A person shall not cause or allow the emission of an air contaminant that would violate, or 

interfere with the attainment or maintenance of, an ambient air quality standard. 

7-05 3.01-1 
SECTION 5 Ambient Air Quality Standards 

Secondary 

Air Contaminant Primary Standards Averaging Times Standards 

5.1 Carbon Monoxide 

5.1.1 9 ppm (10 mg/m3

) 8-hour1 None 

5.1.2 

35 ppm (40 mg/m3

) 1-hour1 None 

5.2 Lead 1.5 )lg/m3 Quarterly Average Same as Primary 

5.3 Nitrogen Dioxide 0.053 ppm (100 )lg/m3

) Annual Same as Primary 

(Arithmetic Mean) 

5.4 Particulate Matter 

5.4.1 (PM10) 50 )lglm3 Annuaf Same as Primary 

(Arithmetic Mean) 

5.4.2 150 )lg/m3 24-hour7 

5.5 Particulate Matter 

5.5.1 (PM2.s) 15 )lg/m3 Annuae Same as Primary 

(Arithmetic Mean) 

5.5.2 65 )lglm3 24-hour4 

5.6 Ozone 

5.6.1 0.08 ppm 8-hour5 Same as Primary 

5.6.2 0.12 ppm 1-hour6 Same as Primary 

5.7 Sulfur Oxides 

5.7.1 0.03 ppm Annual 

(Arithmetic Mean) 

5.7.2 0.14 ppm 24-hour1 

5.7.3 3-hour1 0.5 ppm 

(1300 )lg/m3

) 

5.8 Hydrogen Sulfide Maximum 1-hour 14 )lg/m3

• 

1 

average 

5.9 Gaseous Fluorides 

5.9.1 (expressed as HF) 400 )lglm3 Annual arithmetic 

mean 

5.9.2 Maximum 0.82 )lg/m3 

1-month average 

7-05 3.01-2 
Secondary 

Air Contaminant Primary Standards Averaging Times Standards 

5.9.3 Maximum 1.64 flg/m3 

1-week average 

5.9.4 800 flg/m3 Maximum 2.86 f.Lg/m3 

24-hour average 

5.9.5 Maximum 3.68 flg/m3 

12-hour average 

5.10 Total Fluorides8 

5.10.1 G . 9 rowmg season 40 ppm (w/w) 

5.10.2 2-month average 60 ppm (w/w) 

5.10.3 1-month average 80 ppm (w/w) 

1 Not to be exceeded more than once per year. 

2 To attain this standard, the expected annual arithmetic mean PM10 concentration at each 

monitor within an area must not exceed 50 flg/m3

. 

3 To attain this standard, the 3-year average of the annual arithmetic mean PM2.5 concentrations 

from single or multiple community-oriented monitors must not exceed 15 flg/m3

• 

4 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at 

each population-oriented monitor within an area must not exceed 65 flg/m3

• 

5 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour 

average ozone concentrations measured at each monitor within an area over each year must 

not exceed 0.08 ppm. 

6 The standard is attained when the expected number of days per calendar year with maximum 

hourly average concentrations above 0.12 ppm is :S 1, as determined by 40 CPR Part 50 

Appendix H. The 1-hour ozone standard shall be in effect until June 15, 2005. 

7 To attain this standard, the 3-year average of the annual 99th percentile values at each 

monitoring site must not exceed 15 0 f.Lg/m 3

. 

8 Dry weight basis (as fluoride ion) in and on forage for consumption by grazing ruminants. 

9 Average concentration of monthly samples over growing season (not to exceed 6 consecutive 

months). 

SECTION6 Applicability of Ambient Air Quality Standards 

The ambient air quality standards shall apply, be achieved, and maintained in Jefferson County, 

Kentucky. 

SECTION7 Methods of Measurement 

7-05 3.01-3 
The air contaminants listed in sections 5.1 to 5. 7 shall be measured by the reference or equivalent 

methods and at the frequency specified in EPA regulations on Ambient Air Quality Surveillance 

(40 CPR Parts 50, 53, and 58). 

SECTION 8Savings Clause 

Any emission standard established pursuant to Regulation 3.04 Ambient Air Quality Standards 

section 1.7, 2.7, 2.8, or 2.9 that is reflected in a permit condition as of July 1, 2005, shall remain 

in effect until replaced with an emission standard established pursuant to Regulation 5 .21. 

Adopted vl/4-19-72; effective 4-19-72; amended v2/9-1-76, v3/6-13-79, v4/6-21-05 effective 

7-1-05. 

7-05 3.01-4 
Version 5/Draft #1 February 16, 2011 

[][adopted, this would amend the July 1, 2005 version o[Regulation 3.017 

PART -3 

Ambient Air Quality Standards 

REGULATION 3.01 Ambient Air Quality Standards 

Louisville Metro Air Pollution Control District of Jefferson County 

Jefferson County, Kentucky 

Relates To: KRS Chapter 77 Air Pollution Control 

Pursuant To: KRS Chapter 77 Air Pollution Control 

Necessity And Function: KRS 77.180 authorizes the Air Pollution Control Board to adopt and 

enforce all orders, rules, and regulations necessary or proper to accomplish the purposes of KRS 

Chapter 77. -_This regulation establishes ambient air quality standards to protect public health and 

welfare. , the methods for measuring air contaminants, and the intention of the Board to prohibit 

further significant and avoidable deterioration of air quality. 

SECTION 1_-Definitions 

Terms used in this regulation that are not defined in this regulation shall have the meaning given to 

them in Regulation 1.02, Definitions. 

SECTION 2 Purpose 

The purpose of an ambient air quality standards in Section 7 of this regulation-fs-te establish a 

concentrations of air contaminants, , measured over a including a time-averaging interval .. -e¥eF 

which that concentration is measured, for a particular air contaminant that the Board determines is 

necessary, that are necessary with an adequate margin of safety, to protect public health with an 

adequate margin of safety -and public welfare from any known or anticipated adverse effect§. of 

theseat air contaminant§.. 

SECTION 3 Non-Degradation Intention 

~-an-ambient air quality standards in Section 7 of this regulation are intended,it 

is the intention of the Board to prevent theprohibit significant further significant and avoidable 

deterioration of air quality in those areas where the air quality is presently numerically equal to or 

better than the standard. 

SECTION 4 General Prohibition 

NoA person shall-Bet cause or allow the emission of an air contaminant that would violate, or 

interfere with the attainment or maintenance of, an ambient air quality standard. 

SECTIONS Methods of Measurement 

The air contaminant concentrations listed in sections 7.1 to 7.7 shall be measured by the reference 

-or equivalent methods and at the frequency specified in 40 CPR Parts 50, 53, and 58 relating to 

3.01 5 
Version 5/Draft #1 February 16, 2011 

[I{ adopted, this would amend the July 1, 2005 version o{Regulation 3. 011 

ambient air quality surveillance. 

SECTION 6 Savings Clause 

Any emission standard established pursuant to Regulation 3.04 Ambient Air Quality Standards 

sections 1.7, 2.7, 2.8, or 2.9 and included as a permit condition as of July 1, 2005, shall remain in 

effect until replaced with an emission standard established pursuant to Regulation 5.21. 

SECTION 

SECTION 7.§ Ambient Air Quality Standards 

The following air contaminant concentrations shall be applied, achieved and maintained in 

Jefferson County, Kentucky: 

Seeendary 

Ail' Gentaminant Pl'imary Stanaal'as lnzel'aging ±imes Stanaal'as 

5.1 Gal'ben Mene*ide 

5.1.1 9 ppm EHl mg/m~j 8 fieHl Neoo 

5.1.2 ~~ppm E4Q mg/m~j l fieHl NeHS 

5.2 bead l.~ j±gffil QHart:eFly 2<\:'Y:eFage Same as PFimffi'y 

5.3 NitFegen Die*ide Q.Q~~ wm (lQQ f±gklj AHHHal Same as PFimaFy 

EAfitfl:metie MeaH1 

5.4 Pal'tie~:~late Mattei' 

5.4.1 fFM±ot ~Q j±ghn~ AHHHal~ Same as PFimaFy 

EA:Fitflmetie MeaH1 

5.4.2 l§Q ~::~g,Lm~ ~4 R8Hf:;z 

5.5 Pal'tieHiate Mattei' 

5.5.1 ~j l~ j±ghn~ AHHHal~ Same as .Primafy 

E26ttitfl:metie MeaH1 

5.5.2 6~ j±g/m~ ~4 R8Hf4 

5.6 Q'lene 

5.6.1 Q.Q8 ppm 8 R8Hf,) Same as .PFimaFy 

5.6.2 Q.l~ ppm 1 M:eHF" Same as PFimaFy 

H S~:~lful' Q*ides 

~.01 ~ 
Version 5/Draft #1 February 16, 2011 

[l[adopted, this would amend the July 1, 2005 version o[Regulation 3.017 

Seeeadaey 

Ail' Geatamiaaat FFimaey StaadaFds fr.'eFagiag +imes StaadaFds 

~ 0.03 ppm Annual 

(AFithmetie Mean) 

~ O.l4 ppm ~4 heul 

~ J-he.uf+ 0.5 ppm 

0300 !lg/mJ) 

-5-.& HydFegea Sulfide Mredmum l fl8Uf l4 !lg/m~_+ 

average 

~ Gaseeus FlueFides 

-5-4.-l- (expFessed as HF) 400 rtg/nl Annual arithmetie 

-ffiWil 

~ Mfr*imum 0.8~ !lg/mJ 

1 menth avemge 

~ Ma*imum 1.64 !lg/mJ 

1 week a>refage 

§.;.9.4 800 !lg/mJ Ma~dmum ~.86 !lg/mJ 

~4 heur avemge 

~ Ma~<imum 3.68 !lg/mJ 

l ~ heUF average 

~ Tetal FlueFides8 

~ Gwwing seasen9 40 ppm (n•l"z) HI H 

~ ~ menth a>,zerage 60 ppm ('1' 1 ttl~t '1'1 

~ l menth a'f'efage 80 ppm (n '

1 tt/'t~ '"1 

I~ 3.01 5 
Version 5/Draft #I February I6, 20II 

[Jfadopted, this would amend the July I, 2005 version o[Regulation 3.0Il 

I 7.1 

7.1.1 

Carbon Monoxide 

Pollutant 

8-Hour Average 

~ 9ppm \lJ None 

7.1.2 1-Hour Average 35 ppm (IJ 

7.2 Lead 

7.2.1 Rolling 3-Month Average 0.15 ug/m3 Same as Qrimary 

7.3 Nitrogen Dioxide 

7.3.1 Annual Average 0.053 J2J2m Same as Qrimary 

7.3.2 1-Hour Average 100 ppb (LJ 

7.4 Ozone 

7.4.1 8-Hour Average 0.075 ppm (2008 std) t<>J Same as Qrimary 

7.4.2 0.08 ppm \J) (1997 std) en 

7.5 Particulate Matter (measured as PM2.5} 

7.5.1 Annual Average 15.0 w:dmc; \

4J Same as Qrimary 

7.5.2 24~Hour Average 35 ug/m3 PI 

7.6 Particulate Matter (measured as PM10} 

7.6.1 24-Hour Average 150 ug/m3 <

3

> Same as Qrimary 

7.7 Sulfur Oxides 

7.7.1 3-Hour Average ----- 0.5 ppm \lJ -

7.7.2 1-Hour Average 75 PPbm \~J -----

7.8 Hydrogen Sulfide 

7.8.1 Maximum 1-Hour average ~ ~~ 14 ug/m3 \ll 

7.9 Gaseous Fluorides (exQressed as HF) 

I 7.9.1 Annual Arithmetic Mean 400 ug/m3 

7.9.2 Maximum 1-Month Average 0.82 ug/m3

<

1

> 

7.9.3 Maximum 1-Week Average 1.64 ug/m3

<

1

> 

7.9.4 Maximum 24-Hour Average 800 ug/m3

<

1

> 2.86 ug/m3<

1

> 

7.9.5 Maximum 12-Hour Average 3.68 ug/m3

<

1

J 

I 7.10 Total Fluorides \Y) 

I 7.10.1 Growing Season (tVJ 40 QJ2m (w/w} 

7.10.2 2-Month Average 60 J2J2m (w/w} 

7.1 0.3 1-Month Average 80 QJ2m (w/w} 

I~ 3.01 5 
Version 5/Draft #1 February 16, 2011 

[l[adopted, this would amend the July 1, 2005 version o[Regulation 3.017 

1- Not to be exceeded more than once per year. 

2 To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at 

each monitor within an area must not exceed 100 ppb. (Effective January 22, 201 0.) 

3 Not to be exceeded more than once per year on average over 3 years. 

4 To attain this standard,-wl:ten the 3-year average of the weighted annual mean PM2.5 concentrations from 

single or multiple community-oriented monitors must not exceed 15.0 ug/m3

• 

5 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each 

population-oriented monitor within an area must not exceed 35 ug/m3

. (Effective December 17, 2006.) 

6 To attain this standard, the 3-year average ofthe fourth-highest daily maximum 8-hour average ozone 

concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm. 

(Effective May 27, 2008.) 

7 (a) To attain this standard, the 3-year average of the fowih highest daily maximum 8-hour average ozone 

concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. 

(b) The 1997 standard - and the implementation rules for that standard -will remain in place for 

implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone 

standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering the standards set in 

March 2008. 

8 To attain this standard, the 3-year average of the 99111 percentile of the daily maximum 1-hour average at 

each monitor within an area must not exceed 75 ppb. (Final rule signed June 2, 2010.) 

9 Dry weight basis (as fluoride ion) in and on forage for consumption by grazing ruminants. 

10 Average concentration of monthly samples over growing season (not to exceed 6 consecutive months). 

Not to be e1cceeded more than once per year. 

To attain this standard, the ex:pected annual arithmetic mean PM.w concentration at each monitor 

within an area must not mcceed 50 !J:g/m;;7 

J To attain this standard, the 3 year average of the annual arithmetic mean PMg concentrations from 

single or multiple community oriented monitors must not exceed 15 f::lg/m;;7 

To attain this standard, the 3 year average ofthe 98* percentile of2'1 hour concentrations at each 

population oriented monitor '..vithin an area must not exceed 65 ~~;;7 

" To attain this standard, the 3 year average of the fourth highest daily maximum g hour average 

ozone concentrations measured at each monitor vlithin an area over each year must not eKceed 0.08 ppm. 

t. The standard is attained when the expected number of days per calendar year with maximum hourly 

I~ 3.01 5 
Version 5/Draft #1 February 16, 2011 

[][adopted, this would amend the July 1, 2005 version o[Regulation 3.017 

average concentrations above 0.12 ppm is< 1, as determined by 40 CFR Part 50 Appendb< H. The 1 hour 

ozone standard shall be in effect until June 15, 2005. 

:t To attain this standm·d, the 3 year ave;·age of the ammal 994 percentile valaes at each monitoring 

site must not exceed 150 jlg/m'\ 

s Dry weight basis (as fh!oride ion) in and on forage for consumption by grazing ruminants. 

Average concentration of monthly samples over grovring season (not to exceed 6 consecutive 

months). 

8ECTIOH 6 lrpplicability of Ambient Air Quality 8tandards 

The ambient air quality standards shall apply, be achieved, and maintained in Jefferson County, 

Kentucky. 

8ECTION7 Methods ofMeasurement 

The air contaminants listed in sections 5.1 to 5.7 shall be measured by the reference or equivalent 

methods and at the frequency specified in EPA regulations on Ambient Air Quality 8urveillance 

(40 CFR Parts 50, 53, and 58). 

8ECTION 8 8avings Clause 

Any emission standard established pursuant to Regulation 3.0 11 Ambient Air Quality Standards 

section 1.7, 2.7, 2.8, or 2.9 that is reflected in a permit condition as ofJuly 1, 2005, shall remain in 

effect until replaced with an emission standard established pursuant to Regulation 5 .21. 

Adopted v1/4-19-72; effective 4-19-72; amended v2/9-1-76, v3/6-13-79, v4/6-21-05 effective 

7-1-0 5_,_, v!-..!:5:.<.-./ --~~ 

I~ 3.01 5 
REGULATION 3.01 Ambient Air Quality Standards 

Louisville Metro Air Pollution Control District 

Jefferson County, Kentucky 

Relates To: KRS Chapter 77 Air Pollution Control 

Pursuant To: KRS Chapter 77 Air Pollution Control 

Necessity And Function: KRS 77.180 authorizes the Air Pollution Control Board to adopt and 

enforce all orders, rules, and regulations necessary or proper to accomplish the purposes of KRS 

Chapter 77. This regulation establishes ambient air quality standards to protect public health and 

welfare. 

SECTION 1 Definitions 

Terms used in this regulation shall have the meaning given to them in Regulation 1.02, Definitions. 

SECTION 2 Purpose 

The ambient air quality standards in Section 7 of this regulation establish concentrations of air 

contaminants, measured over a time-averaging interval, that are necessary to protect public health 

with an adequate margin of safety and public welfare from any known or anticipated adverse 

effects of these air contaminants. 

SECTION 3 Non-Degradation 

The ambient air quality standards in Section 7 of this regulation are intended to prevent the 

significant deterioration of air quality in those areas where the air quality is presently numerically 

equal to or better than the standard. 

SECTION 4 General Prohibition 

No person shall cause or allow the emission of an air contaminant that would violate, or interfere 

with the attainment or maintenance of, an ambient air quality standard. 

SECTIONS Methods of Measurement 

The air contaminant concentrations listed in sections 7.1 to 7. 7 shall be measured by the reference 

or equivalent methods and at the frequency specified in 40 CFR Parts 50, 53, and 58 relating to 

ambient air quality surveillance. 

SECTION 6 Savings Clause 

Any emission standard established pursuant to Regulation 3.04 Ambient Air Quality Standards 

sections 1.7, 2.7, 2.8, or 2.9 and included as a permit condition as of July 1, 2005, shall remain in 

effect until replaced with an emission standard established pursuant to Regulation 5 .21. '· 

1 
SECTION 7 Ambient Air Quality Standards 

The following air contaminant concentrations shall be applied, achieved and maintained in 

Jefferson County, Kentucky: 

Pollutant 

I Maximum Con~en~ration 

7.1 Carbon Monoxide 

7.1.1 8-Hour Average 9ppm\lJ None 

7.1.2 1-Hour Average 35 ppm (lJ 

7.2 Lead 

7.2.1 Rolling 3-Month Average 0.15 ~-tg/m 3 Same as primary 

7.3 Nitrogen Dioxide 

7.3.1 Annual Average 0.053 ppm Same as primary 

7.3.2 1-Hour Average 100 ppb (L) 

7.4 Ozone 

7.4.1 8-Hour Average 0.075 ppm (2008 std) (OJ Same as primary 

7.4.2 0.08 ppm (jJ (1997 std) UJ 

7.5 Particulate Matter (measured as PM2.5) 

7.5.1 Annual Average 15.0 J.lg/mj \

4J Same as primary 

7.5.2 24-Hour Average 35 J.lg/mj \)J 

7.6 Particulate Matter (measured as PM10) 

7.6.1 24-Hour Average 150 J.lg/m3 PJ Same as primary 

7.7 Sulfur Oxides 

7.7.1 3-Hour Average ----- 0.5 ppm (IJ 

7.7.2 1-Hour Average 75 ppb (~) -----

7.8 Hydrogen Sulfide 

7.8.1 Maximum 1-Hour average 14 J.lg/m3 (lJ 

7.9 Gaseous Fluorides (expressed as HF) 

7.9.1 Annual Arithmetic Mean 400 J.lg/m3 

7.9.2 Maximum 1-Month Average 0.82 J.lg/m3

<

1

J 

7.9.3 Maximum 1-Week Average 1.64 J.lg/m3

<

1

J 

7.9.4 Maximum 24-Hour Average 800 J.lg/m3

<

1

J 2.86 J.lg/m3

<

1

J 

7.9.5 Maximum 12-Hour Average 3.68 J..!g/m3

<

1

J 

7.10 Total Fluorides ('IJ 

7.10.1 Growing Season \lUJ 40 ppm (w/w) 

7.10.2 2-Month Average 60 ppm (w/w) 

7.10.3 1-Month Average 80 ppm (w/w) 

2 
Not to be exceeded more than once per year. 

2 To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at 

each monitor within an area must not exceed 100 ppb. (Effective January 22, 2010.) 

3 Not to be exceeded more than once per year on average over 3 years. 

4 To attain this standard, the 3-year average of the weighted annual mean PM2.s concentrations from single 

or multiple community-oriented monitors must not exceed 15.0 J..Lg/m3

• 

5 To attain this standard, the 3-year average of the 98u1 percentile of 24-hour concentrations at each 

population-oriented monitor within an area must not exceed 35 J..Lg/m3

• (Effective December 17, 2006.) 

6 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone 

concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm. 

(Effective May 27, 2008.) 

7 (a) To attain this standard, the 3-year average of the fourth highest daily maximum 8-hour average ozone 

concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. 

(b) The 1997 standard - and the implementation rules for that standard- will remain in place for 

implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone 

standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering the standards set in 

March 2008. 

8 To attain this standard, the 3-year average of the 99th percentile of the daily maximum 1-hour average at 

each monitor within an area must not exceed 75 ppb. (Final rule signed June 2, 2010.) 

9 Dry weight basis (as fluoride ion) in and on forage for consumption by grazing ruminants. 

10 Average concentration of monthly samples over growing season (not to exceed 6 consecutive months). 

Adopted vl/4-19-72; effective 4-19-72; amended v2/9-1-76, v3/6-13-79, v4/6-21-05 effective 

7-1-05, vS/4-20-11. 

3 
Louisville Metro Air Pollution Control District 

Regulatory Impact Assessment 

Regulations 3.01 

Ambient Air Quality Standards 

Version #5, Draft #1 Proposed, February 16,2011 

Purpose of the Proposed Action: 

The purpose of the proposed action is to update the current federal National Ambient Air Quality 

Standards (NAAQS). The language of the regulation has been generally simplified and the sections 

reordered. These are administrative changes with no impact other than improving readability. 

If adopted by the Board, Regulation 3.01 will be submitted to EPA for inclusion in the Kentucky 

State Implementation Plan. 

Estimated Costs and Savings: 

The draft proposed action does not change the cost or savings associated with meeting the 

federal requirements for implementing the Clean Air Act. 

Feasibility of All Alternatives 

There are no alternatives available; these changes are required by EPA. 

Comparison with Any Minimum or Uniform Standards: 

The District is required to periodically update its regulations to incorporate the most recent 

federal NAAQS as part of its delegated implementation of the Clean Air Act. There are no 

changes in the draft proposed action that are intended to be inconsistent with the federal 

requirements. 

Report on Public Outreach Efforts: 

A draft of Regulation 3.01 was sent for formal review to all persons who requested to be 

informed of proposed changes to any District regulation; EPA Region 4; and the Kentucky 

Division for Air Quality. In addition, pursuant to Regulation 1.08, Administrative Procedures, 

the public was provided a 30-day period in which to make written comments and an opportunity 

to comment at the public hearing held on April20, 2011, prior to adoption of the regulation. 

Comments were submitted to the District during the public comment period. The District 

recommended that the Board adopt the following administrative revisions to the proposed draft 

of Regulation 3.01 in response to comments from DAQ: 
• Section 7.7.2, insert phrasing "75 ppb", delete "75 ppm". 

• Section 7.8.1, insert "14 llf,/m30h under the secondary standard 

column, delete "14 IJ.g/m3

< ), from the primary standard column. 

• Section 7.9.2, insert "0.82 IJ.g/m3(1J,, delete "0.82 11g/m3

" 

• Section 7.9.3, insert "1.64 IJ.g/m30l", delete "1.64 1J.glm3

" 

3(1) 3" 

• Section 7.9.4, insert "800 11g/m ",delete "800 11glm , 

insert "2.86 11g/m30l", delete "2.86 1J.glm3". 

• Section 7.9.5, insert "3.68 IJ.g/m30l", delete "3.68 IJ.g/m3

". 

• Footnote 4- delete "when" after "To attain this standard .... " 

The Board adopted the recommended administrative revisions at the public hearing held on April 

20, 2011. No substantive changes to the proposed draft Regulation 3.01 were made as part of the 

public review process. 
Louisville Metro Air Pollution Control District 

Comment and Response Document 

Regulation 3.01 

Ambient Air Quality Standards 

Version 5, Draft 1- Proposed February 16,2011 

Public Comment Period: The following comments were received during the public comment 

period. 

Comment: Revise the following: 

Response: 

• Section 7. 7.2, insert phrasing "75 ppb ", delete "75 ppm". 

• Section 7. 8.1, insert "14 JlfJ/m3

(J)" under the secondary standard 

column, delete "14 pg!m3

() "from the primary standard column. 

• Section 7.9.2, insert "0.82 pg/m3(J) ", delete "0.82 pg/m3

" 

• Section 7. 9. 3, insert "1. 64 pg/m3(J) ", delete "1. 64 pg/m3" 

• Section 7.9.4, insert "800 pg!m3

(J) ", delete "800 pg/m3 ", 

insert "2.86 pg/m3(J) ", delete "2.86 pg/m3". 

• Section 7.9.5, insert "3.68 pg/m3(J) ", delete "3.68 pg!m3". 

• Footnote 4- delete "when" after "To attain this standard .... " 

Division for Air Quality 

The District will recommend that the Louisville Metro Air Pollution Control 

Board adopt the suggested revisions. 

Comment: After section 7.1 0. 3, insert "Odors" under pollutant column; insert phrasing, "At 

any time when 1 volume unit of ambient air is mixed with 7 units of odorless air, 

the mixture must have no detectable odor" under secondary standard column, 

and renumber appropriately. 

Response: 

Division for Air Quality 

The District disagrees with the Division's suggestion to add a new section to 

Regulation 3.01 addressing "odors." The District's current SIP approved version 

of Regulation 3.04 includes an ambient air standard for odors that applies to 

"[a]ny ambient air sample of at least 50 ml which, undiluted, is established by a 

documented investigation or measurement to be offensive, foul, unpleasant, or 

repulsive." 1 (Emphasis added). This standard was removed from Part 3 of the 

District's regulations as part of the District's 2005 STAR Program regulatory 

rulemakings because "odors are regulated in Regulations 1.09, 1.12, and 1.13."2 

1 Regulation 3.04, v5 (Aprill988); see 40 CFR 52.920 Identification of Plan; Table 2- EPA-Approved Jefferson 

County Regulations for Kentucky. 

2 Draft Final Regulatory Impact Assessment (May 31, 2005), p. 8; available at 

http://www.louisvilleky.gov/NR!rdonlyres/25F All C4-EC7C-4E09-9CAAEDAOCEC2565F/O/ST AR RIA DraftFinal.pdf. 

3.0lv5 1 April20, 2011 
Louisville Metro Air Pollution Control District 

Comment and Response Document 

The Division granted prior concurrence on the 2005 STAR Program rulemaking, 

including the proposed amendments to the District's Pmi 3 regulations, on April 

7, 2005, contingent upon the inclusion of the Kentucky ambient air quality 

standards for gaseous fluorides, hydrogen sulfide, and total fluorides. 3 

Public Hearing: No comments were received during the public hearing. 

Concurrence: 

Substantive Changes Resulting from Public Review Process: Comments were submitted to 

the District during the public comment period. The District recommended that the Board adopt 

the following administrative revisions to the proposed draft of Regulation 3.01 in response to 

comments from DAQ: 

• Section 7.7.2, insert phrasing "75 ppb", delete "75 ppm". 

• Section 7.8.1, insert "14 ~-t?/m (')" under the secondary standard 

column, delete "14 11g/m3

( ), from the primary standard column. 

• Section 7.9.2, insert "0.82 ~-tg/m (1),, delete "0.82 ~-tglm " 

• Section 7.9.3, insert "1.64 ~-tg/m C'h, delete "1.64 11g/m3

" 

• Section 7.9.4, inse1i "800 ~-tglm 30 )", delete "800 ~-tglm ", 3(1) 3" insert "2.86 11g/m ", delete "2.86 11g/m . 

• Section 7.9.5, insert "3.68 ~-tglm 30 h, delete "3.68 ~-tglm ". 

• Footnote 4- delete "when" after "To attain this standard .... " 

The Board adopted the recommended administrative revisions at the public hearing on April 20, 

2011. No substantive changes to the proposed draft Regulation 3.01 were made as part of the 

public review process. 

3 Id. at p. 27. 

3.01v5 2 Apri120, 2011 
GREG FISCHER 

MAYOR 

AIR POLLUTION CONTROL DISTRICT 

LOUISVILLE, KENTUCKY 

Notice of Meeting 

Strategy Committee 

of the 

LAUREN ANDERSON, DIRECTOR 

Louisville Metro Air Pollution Control Board 

The Strategy Committee of the Louisville Metro Air Pollution Control Board will meet 

in the 2nd Floor Conference Room of the Louisville Metro Air Pollution Control District 

(District) at 9:15a.m. on Wednesday, February 16,2011. The District is located at 850 Barret 

A venue, Louisville, Kentucky. The Board invites the public to attend. 

Agenda 

1. Call to Order- Recognition of Quorum 

2. Draft amendments to Regulation 3.01 Ambient Air Quality Standards 

3. Draft amendments to Regulation 5. 02 Adoption and Incorporation by Reference of 

Natlonal Emission Standards for Hazardous Air Pollutants 

4. Adjourn 

www.louisvilleky. gov 

WWW.LOUISVILLEKY.GOVfAPCD 850 BARRET AVENUE, ROOM 205 LOUISVILLE, KENTUCKY 40204·1745 502,574.6000 FAX, 502.574.5306 
Minutes 

Strategy Committee Meeting 

of the 

Louisville Metro Air Pollution Control Board 

February 16, 2011 

A meeting of the Strategy Committee of the Louisville Metro Air Pollution Control Board was 

called to order on February 16, 2011, at 9:20 a.m. in the second floor Conference Room of the Louisville 

Metro Air Pollution Control District (District), 850 Barret Avenue, Louisville, Kentucky. Members 

attending were Dr. Nadir Al-Shami and Ms. Bonnie Biemer. A quorum was present. 

The following District staff members were present: Lauren Anderson, Rachael Hamilton and 

Monica Little. Also attending was Assistant County Attorney Stacy Fritze Dott. 

Guest Emily McKilmey attended representing Frost Brown Todd, LLC. 

1. Draft amendments to Regulation 3.01 Ambient Air Standards, Version 5, Draft 1-Proposed, 

February 16, 2011 

Ms. Hamilton said the purpose of the draft amendments to Regulation 3.01 was to include 

updated language from the most recent standards promulgated by the U.S. Environmental Protection 

Agency and to incorporate the Kentucky State standards for fluoride. 

The District also reformatted the regulations to improve readability. The District recommended 

that Regulation 3. 0 I be released for a formal 3 0-day comment period. 

Motion: Dr. Al-Shami moved that the draft amendments to Regulation 3.01 be released for a 

formal public 30-day comment period as recommended by the District. 

The motion passed unanimously. 

2. Draft amendments to Regulation 5.02 Adoption and Incorporation by Reference of National 

Emission Standards for Hazardous Air Pollutants, Ve•·sion 18, Draft 1-Proposed, February 16, 

2011 

Ms. Hamilton said the purpose of the draft amendments was to incorporate by reference the July 

1, 2010, version of the Code of Federal Regulations into Regulation 5.02 as ofthe date the regulations are 

adopted by the Board. 

Statements 

Dr. Al-Shami asked how often the CFR's are updated. Ms. Hamilton said the regulations are 

updated daily but are published in print annually on July 1st. 

Ms. Biemer asked if it was necessary for the District to revise the regulations annually. Ms. 

Hamilton and Ms. Anderson explained the process and stated that it was a federal requirement that affects 

the District's permitting work. 
Motion: Ms. Biemer moved that Regulation 5.02 be released for a formal 30-day comment 

period as recommended by the District. 

The motion passed unanimously. 

Adjournment 

The meeting adjourned at 9:33 a.m. 

Bonnie Biemer 

Louisville Metro 

Air Pollution Control Board 

Secretary-Treasurer 

Strategy Committee 

February 16, 201 I 
THE COURIER-JOURNAL INC. 

STATE OF KENTUCKY 

County ofJefferson 

I, 9/£~ 6)ff;J; ofTHE COURIER-JOURNAL, clerk of 

THE COURIER JOURNAL general circulation printed 

and published at Louisville, Kentucky, do solemnly swear 

that from my own personal knowledge; .and reference to 

the files of said publication, the advertisement of: 

Title: Notice ofPublic Comment Lines: 97 

Date: 2/19/2011 Inches: 1x9.45 

Signature of person making proof 

Subscribed and sworn to before me this 21st day of Februaryt 2011. 

. t'amtee C@ m'~ 

Notary Pubflc, State at Large, KY 

My commission expires June 14, 2014 
:2 ;v/ p-fl~~ ·~ 

;o C~tJ. /u£iMr 

'l 
Louisville Metro Air Pollution Control Board 

Notice ofPubJic Hearing and Board Meeting 

The Louisville Metro Air Pollution Control Board will hold a public hearing and its regular 

monthly meeting at 10:00 a.m. on Wednesday, Apri120, 2011, 1n the Board Room, 850 Barret Avenue, 

Louisville. The Board invites the public to attend. 

Public Hearing Agenda 

1. Proposed amendments to District Regulations 1.15 Version of Federal Regulations 

Adopted and Incorporated by Reference, Version #15, Draft #1; 3.01 Ambient Air Quality 

Standards, Version #5, Draft # 1; 5. 02 Adoption and Incorporation by Reference of 

National Emission Standards for Hazardous Air Pollutants, Version #18, Draft#; and 

7.02Adoption and Incorporation by Reforence ofNew Source Performance Standards, 

Version#l5, Draft #1, which were proposed, February 16,2011. 

Meeting Agenda 

1. Call to Order 

A. Recognition of Quorum 

2. Introductions · 

3. Public Recognitions· 

· 4. Approval ofMinutes- Public Hearing and regular Board meeting held on March 16, 2011 

5. Public Comment1 

6. Unfinished Business 

7. New Business 

A. Proposed amendments to District Regulations 1.15 Version of Federal Regulations 

Adopted and Incorporated by Reference, Version #15, Draft #1; 3.01 Ambient Air 

Quality Standards, Version #5, Draft #1; 5.02 Adoption and Incorporation by 

Reference ofNational Emission Standards for Hazardous Air Pollutants, Version 

#18, Draft#; and 7.02 Adoption and Incorporation by Reference ofNew Source 

Performance Standards, Version #15, Draft #1, which were proposed, February 16, 

2011. 

8. Committee Reports 

9. StaffReports 

A. Director 

B. Air Quality Data 

C. Enforcement Status Report 

D. Excess Emission Report 

E. Permitting Backlog Report 

10. Adjourn 

The next Board meeting is Wednesday, May 18,2011, at 10:00 a.m. 

1

This is a regularly scheduled agenda item to give individuals and organizations an opportunity to address the Board on air pollution 

issues. Presentations shall be limited to two minutes, except that the Board Chair may, for cause, allow three minutes. Persons wishing to 

address the Board shall notifY the Secretary-Treasurer (502/574-5218) and submit a completed speaker's registration card to the SecretaryTreasurer before 10:00 a.m. of the day of the Board meeting.· 

l 

I 

l 

t 

f 

l 

I 

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I 
Public Hearing Minutes 

of the 

Louisville Metro Air Pollution Control Board 

April 20, 2011 

A public hearing of the Louisville Metro Air Pollution Control Board was called to order on April 

20, 2011, at 10:00 a.m. in the Board Room of the Louisville Metro Air Pollution Control District, 850 

Barret Avenue, Louisville, Kentucky, by the Chairman, Dr. Robert Powell. 

General Statement, Rules and Purpose 

The Chairman read the opening announcements, rules and purpose of the Public Hearing, which 

was to review proposed amendments to four District regulations. Ms. Rachael Hamilton, Regulatory 

Specialist, introduced the proposed regulations and recommended their adoption by the Board on behalf 

of the District. 

1. Regulation 1.15 Version of Federal Regulations Adopted and Inc01porated by Reference, Version 

#15, Draft #1 -proposed, February 16, 2011 

The proposed action updates the District's regulation to incorporate the Code of Federal 

Regulations (CFR) by changing the date to reference the most recent version, July 1, 2010. 

2. Regulation 3.01 Ambient Air Quality Standards, Version #5, Draft #1- proposed, February 16, 

2011 

The proposed action for Regulation 3.01updates the current federal national air ambient air 

quality standards. The regulation also includes several provisions specific to Kentucky. Pending the 

Board's approval, Regulation 3.01 would also be submitted to EPA for inclusion in the District's State 

Implementation Plan. 

The District received public comments that identified some technical and/or footnote corrections 

in Sections 7.72, 7.8.1, 7.9.2, 7.9.3, 7.9.4, 7.9.5. The District concurred with the comments and, because 

the comments were administrative in nature and not intended to be a substantive change fi·om federal law, 

revised Regulation 3.01 Version 5 Draft 1 accordingly. 

Statement 

Dr. Powell stated the correction to Section 7.7.2 to delete "75 ppm" and change to "75 ppb" 

sounded substantive, had it not been made in error. Ms. Hamilton said the change to 75 ppb is the 

current federal standard and that 75 ppm was a typographical error. 

3. Regulation 5.02 Adoption and Incorporation by Reference of National Emission Standards for 

Hazardous Air Pollutants, Version #18, Draft #1- proposed, February 16,2011 

·Changes to Regulation 5.02 adopt and incorporate by reference the current federal regulations in 

40 CFR 61 and 40 CFR 63 published in the July 1, 2010, Code of Federal Regulations. The District also 

proposed to adopt Regulation 5.02 on a semi-annual basis, effective as of the date the regulation would be 

adopted. Other changes include clarifYing that sources must comply with NESHAP and any more 

stringent provisions of the District regulations consistent with the District's prior version of the 

regulation. 
One comment was received on the proposed regulation requesting that the phrase "Lead Acid 

Mattery" in Section 3.121 be changed to "Lead Acid Battery". In addition, the District corrected the 

section numbers in 3, 4 and 6 to conform the proposed numbering and capitalized "From" throughout the 

regulation. 

4. Regulation 7.02 Adoption and Incorporation by Reference of Federal New Source Performance 

Standards, Version #15, Draft #1- proposed, February 16,2011 

The proposed changes to Regulation 7.02 adopt and incorporate by reference the federal 

regulations in 40 CFR Part 60 published in the July 1, 2010 version of the Code of Federal Regulations, 

effective as of the date Regulation 7.02 is adopted. Other changes include clarifying that sources must 

comply with NESHAP and any more stringent provisions of the District regulations consistent with the 

District's prior version of the regulation. 

Adjournment 

The public hearing adjourned at 10:11 a.m. 

Robert W. Powell, M.D. 

Chairman 

Louisville Metro 

Air Pollution Control Board 

Secretary-Treasurer 

Public Hearing 

Apri120, 2011 
Minutes 

Regular Meeting 

of the 

Louisville Metro Air Pollution Control Board 

April 20, 2011 

The regular meeting of the Louisville Metro Air Pollution Control Board was called to order on 

April 20, 2011, at 10:12 a.m. in the Board room of the Louisville Metro Air Pollution Control District, 

850 Barret Avenue, Louisville, Kentucky, by the Chairman, Dr. Robert Powell. Other Board members 

present were Dr. Nadir Al-Shami, Mr. Ronald Thomas, Ms. Bonnie Biemer, and Mr. Steve Thomas. A 

quorum was present. 

The following Louisville Metro Air Pollution Control District staff members were present: Lauren 

Anderson, Rachael Hamilton, Paul Aud, Matt Stun, Teni" Phelps, Cynthia Lee, Eva Addison, Lany 

Garrison, Matt King, Michelle King, Karen Thorne, Dr. Yiqiu Lin, Steven Gravatte, Donald Fountain, 

Diana Prentice, Emily Tyler, Rick Williams, Bob Wesely, Craig Butler, and Monica Little. Also present 

were Assistant County Attorney Stacy Fritze Dott and County Attorney staff member Tammy Brown. 

The following guests were present: Andy Battjes, Brown-Forman; Paul Bowe, Marcus Paint; Dennis 

Conniff, Frost Brown Todd, GLI & ATTF; Tim Corrigan, GLI; Bradley Coyle, Linebach Funkhouser, 

Inc.; Brad Dillon, GD&M; Carolyn Embry, American Lung Association; Carol Hilton, West Jefferson 

County Community Task Force; Paul Howard, Terracon; Betsy Janes, American Lung Association; Joan 

Lindop, Siena Club; Kathy Little, resident of Cane Run/Road Claremore Acres; Wallace McMullen, 

Sierra Club; Paige Mosser Theriac, Theriac Environmental Consultants, Inc.; Dan Weiss, Duke Energy; 

and Mark Young, Automotive Service Council of Kentucky. 

Approval of Minutes 

The minutes of the Public Hearing and Board meeting held on March 16, 2011, were approved as 

written. 

Public Comment 

Ms. Kathy Little, a resident and representative for the neighbors of the Claremore Acres/Cane Run 

Road subdivision, addressed District staff and the Board about emissions of fugitive fly ash from the 

LG&E Cane Run coal ash landfill. Ms. Little said -the residents are very concerned about the buildup of 

ash on their home and property, and the health effect on their children. 

New Business 

A. Proposed amendments to District Regulations 1.15 Version of Federal Regulations 

Adopted and Incorporated by Reference, Version #15, Draft #1 ~Proposed, February 16,2011 

Ms. Hamilton recommended on the District's behalf that the Board adopt Regulation 1.15, Version of 

Federal Regulations Adopted and Incorporated by Reference, as proposed. 

Motion: Mr. Ron Thomas moved to adopt Regulation 1.15, Version 15, as proposed by the District. 

The motion passed tmanimously. 

B. Proposed amendments to District Regulation 3.01 Ambient Air Quality Standards, 

Version #5, Draft #1 -Proposed, February 16, 2011 
Ms. Hamilton recommended on the District's behalf that the Board adopt Regulation 3.01, Ambient 

Air Quality Standards, with the administrative revisions discussed in the Public Hearing on April 20, 

2011. 

Motion: Mr. Ron Thomas moved to adopt Regulation 3.01, Version 5, as proposed by the District. 

The motion passed unanimously. 

C. Proposed amendments to District Regulation 5.02 Adoption and Incorporation by 

Reference of National Emission Standards for Hazardous Air Pollutants, Version #18, Draft #1 -

Proposed, February 16, 2011 

Ms. Hamilton recommended on the District's behalf that the Board adopt Regulation 5.02, Adoption 

and Incorporation by Reference ojNational Emission Standards for Hazardous Air Pollutants, with the 

administrative revisions discussed at the Public Hearing on Apri120, 2011. 

Motion: Dr. Al-Shami moved to adopt Regulation 5.02, Version 18, as proposed by the District. 

The motion passed unanimously. 

D. Proposed amendments to District Regulation 7.02 Adoption and Incorporation by 

Reference of Federal New Source Peiformance Standards, Version #15, Draft #1 -Proposed, 

February 16, 2011 

Ms. Hamilton recommended on the District's behalf that the Board adopt Regulation 7 .02, Adoption 

and Incorporation by Reference of New Source Performance Standards, as proposed. 

Motion: Dr. Al-Shami moved to adopt Regulation 7.02, Version 15, as proposed by the District. 

The motion passed unanimously. 

Staff Reports 

A. Director 

Ms. Anderson addressed the concerns of residents from the Claremore Acres/ Cane Rlm Road 

subdivisions about emissions of fugitive fly ash from LG&E's Cane Run Generating Station. She 

reported that the District had investigated the landfill and would continue to address the issue under 

guidelines in Regulation 1. i 4 Fugitive Emissions. In addition, Ms. Anderson said the District will seek 

input from neighborhood residents, the state, and LG&E, and will keep the Board informed on the issue. 

Mr. Ron Thomas said he lives near the LG&E coal ash plant near Cane Run Road and expressed his 

concerns about the issue. 

Ms. Anderson repmted that she received authorization to begin recruitment for two vacant 

c.ompliance officer positions in the Enforcement section. She also reported that a reorganization of the 

Engineering department, which was recommended by EPA to create a career path for District engineers, 

was recently approved by Metro Human Resources and implemented by the District. As a result, the 

following staff were promoted: Steve Taylor, Dr. Yiqiu Lin and Karen Thorne were promoted to 

Engineer III; and Rick Williams, Donald Fountain and Bob Wesely were promoted to Engineer II. Ms. 

Anderson thanked Paul Aud, Environmental Engineering Manager, for his diligence with the 

reorganization. 

Louisville Metro 

Air Pollution Control Board 

2 

Board Meeting 

April20, 20 II 
Ms. Terri Phelps, Enforcement Manager, reported on the supplemental environmental projects (SEP) 

the Board had previously approved as part of the Agreed Board orders with Rohm & Haas Company and 

the University of Louisville. She reported that Rohm & Haas had submitted a proposal to the District for 

a SEP to replace the agitator and seals in two storage tanks to reduce hazardous emissions of Methyl 

Methacrylate by 500 lbs. per year. The project is expected to cost Rohm & Haas $260,000 and the 

District granted a $30,000 SEP credit for the project. With respect to the Agreed Board Order with the 

University of Louisville, the District had allowed the University a SEP credit of $15,000 to produce an 

asbestos training video. She reported that the University had notified the District that it would not submit 

a SEP for an asbestos video, and instead had paid the $15,000 penalty in full. 

Ms. Anderson reported that Carbide Industries submitted a construction permit application to the 

District to rebuild the fumace damaged during the March 2011 plant explosion. 

Ms. Anderson reported that the District held a public hearing on April 13, 2011, at Memorial 

Auditorium regarding the issuance of a Title V construction permit to Nuplex Resins. The public hearing 

was attended by a number of residents from the Beechmont neighborhood and videotaped by MetroTV. 

Ms. Anderson stated that Mayor Greg Fischer recently celebrated his first I 00 days in office. Mayor 

Fischer asked several department directors, including the District's, to provide him with information on 

how they measured performance related to metrics and benchmarks. Ms. Anderson reviewed the 

information she shared with the Mayor, which included design values used by the District to measure 

work in air monitoring, permitting, lawn care and new projects. 

Ms. Hamilton reported that the District recently completed the renewable energy project approved by 

the Board in February 2010, to install solar powered generating equipment at the Cannons Lane air 

monitoring site. Funding for the project was provided by a $25,000 EPA Air Planning Agreement grant 

and $17,859.80 from the District's Air Quality Tmst Fund (AQTF). Ms. Hamilton said the balance 

remaining in the AQTF fund was $16,376.51 and that a full accounting report of the fund would be 

provided in June 2011. 

B. Air Quality Data 

Ms. Anderson repmted the District has applied for resignation of attainment of the PM2.s standard 

and the process was moving forward. Also, she said the Thunder Over Louisville event held on April 16, 

2011, did not produce any air quality issues for the community. 

The air quality monitoring report was submitted for filing. A copy is attached to the original 

minutes. 

C. Enforcement Status Report 

The enforcement report was submitted for filing. A copy is attached to the original minutes. 

D. Excess Emission Report 

The March 2011 Excess Emission Report was submitted for filing. A copy is attached to 

the original minutes. 

E. Permitting Bacldog Report 

The permitting backlog report was submitted for filing. A copy is attached to the original 

3 

Louisville Metro 

Air Pollution Control Board 

Board Meeting 

April 20,2011 
minutes. 

Next Meeting 

The next regular Board meeting is scheduled Wednesday, May 18,2011, at I 0:00a.m. 

Adjourn 

The meeting was adjourned at 10:55 a.m. 

' Robert W. Powell, M.D. 

Chairman 

Louisville Metro 

Air Pollution Control Board 

4 

akc~ a-/l,,,j;_ Rachae! Hamilton 

Secretary-Treasurer 

Board Meeting 

April 20, 20 ll 


REQUEST FOR EPA ACTION 

Louisville Metro Air Pollution Control District (District) requests a source specific 

revision to the Jefferson County portion of the State Implementation Plan (SIP) for the 

Ford Motor Co., LAP: 

Withdraw from the SIP the NOx RACT plan approved on October 23, 2001 and 

published in 66FR53684, and replace it with the accompanying PAL/Title V permit. 

This proposed SIP revision is needed because District Permit No. 14 7-97-TV (R2) allows 

fewer annual emissions and contains the remaining relevant ozone season provisions 

from the approved plan. For convenience, the two pertinent pages, 4 and 45, follow and 

may also be found in the enclosed documents. 
Contents 

Ford Motor Co., LAP 

Request for EPA Action 

Permit No: 147-97-TV (R2) pages 4 and 45 

Board Order 

Public Notice 

Cover letter 

Permit No: 147-97-TV (R2) and Statement of Basis 

Permit No: 245-09-C (R1) and Statement of Basis 
Permit No: 147-97-TV (R2) Plant ID: 0072 

P AL!fitle V Permit Revisions/Changes 

Revision Issue Public Attachment 

No. Date Notice Date Type No./Page No. Description 

N/A 10/6/2000 4/23/2000 Initial Entire Permit Initial TV Permit 

Issuance 

Rl 9/17/2010 7/19/2010 InitiaV Entire Permit 5 year Renewal; 

Renewal Incorporate PAL, STAR 

TAC requirements, RO 

change, DRE for E-coat 

control device change 

and 112(J) Part 1 & 2 

applications. 

R2 3/31/2011 NA Admin Pages 43,45 Revision to include 

Revision and 50 permit 229-96-0, add 

NOx RACT language 

and correct Methanol 

Tank Vapor Pressure 

Application # Date Type 

9761 09/09/2004 TV Revision (Multi Request) 

9509' 08/28/2003 TV Revision (Stage II) Request 

10016. 07/22/2005 TV Admin Change 

10457 07/22/2005 TV Renewal 

10789 12/07/2007 TV Revision Request DRE forE-Coat 

System Control Device 

11033 07/17/2008 TV Revision Request Reporting Revision 

11042 08/07/2008 TV IP AL Renewal application - Updated 

11230 03/06/2009 112(J) Part 1 & 2 applications 

11319 04/30/2009 TVRO Change 

SCH Page 4 of·130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

S2. 

SCH 

i. The owner or operator shall not cause to be discharged into the 

atmosphere from that affected facility . any gases which contain sulfur 

dioxide in excess of 0.99 pounds per million BTU actual total heat input 

for combustion of liquid and gaseous fuels. (Regulation 7.06, section 

5.1.1) (See Comment 1) 

11. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

d. NOx 

i. The owner or operator shall not allow or cause the plant-wide NOx 

emissions to exceed 99 tons during any consecutive 12-month period in 

order to stay below NOx RACT applicability thresholds. (Regulation 

6.42)(See Comment 6) 

u. For Emission Points E04A, E04B and E05: 

The owner or operator shall not allow or cause NOx emission to exceed 37 

tons per boiler during March 1 through October 31. 

111. For Emission Point E02A: 

e. TAC 

No boiler shall have a monthly capacity factor greater than 10.0% for any 

month during the period March 1 to October 31. The term "monthly 

capacity factor" means the ratio between the actual heat input to a. boiler 

from fuel combusted during a month and the potential heat input to a 

boiler form fuel combusted during a month and the potential heat input to 

the boiler had it been operated for 24 hours per day for the number of days 

in the month at the maximum steady state design heat input capacity. 

The owner or operator shall not allow any TAC emrss10ns to exceed 

environmentally acceptable levels whether specifically established by modeling or 

derived from default de minimis levels. (Regulation 5.01, section 3.) 

Monitoring (Regulation 2.16, section 4.1.9.1.2) 

a. PM 

·For emission points E02A, E04A, E04B and E05, the owner or operator shall 

maintain records of monthly natural gas and/or other fuel usage. 

b. Opacity 

There are no monitoring requirements for Opacity compliance. (See Comment 2) 

Page 45 of 130 03-31-2011 

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Air Pollution Control Board of Jefferson County 

Board Order 

This Board Order is issued by the Air Pollution Control Board of Jefferson County pursuant to 

the authority granted in Kentucky Revised Statutes Chapter 77 Air Pollution ControL 

Company: Ford Louisville Assembly Plant (Ford LAP) 

2000 Fern Valley Road 

Louisville, Kentucky 40213 

Background and Discussion 

Regulation 6.42 Reasonably Available Control Technology Requirements for Major Volatile 

Organic Compound- and Nitrogen Oxides-Emitting Facilities requires the establishment and 

implementation of reasonably available control technology (RACT) for certain affected facilities 

that emit oxides of nitrogen (NOx) and that are located at a major stationary source for NOx. 

Section 4.4 requires that each determination ofRACT approved by the Air Pollution Control 

District of Jefferson County (District) be submitted to the U.S. Environmental Protection Agency 

(EPA) as a site-specific revision of the Kentucky State Implementation Plan (SIP). 

A Public Hearing on this Board Order was held before the Board on November 8, 1999. Based 

upon the evidence presented at that hearing, the Board determined that approval of this Board 

Order and submittal as a site-specific revision of the Kentucky SIP were appropriate. 

Now therefore be it ordered that: 

1. The attached NOx RACT Plan applicable to Ford LAP is approved by the District. Ford 

LAP shall comply with this plan. 

2. Compliance with the attached NOx RACT Plan shall be deemed compliance with the 

requirements of Regulation 6.42 section 1.2, section 1.3, Section 2 to the extent that this 

Section applies to section 4.3, section 4.3, and Section 5 to the extent that this Section 

applies to verification of compliance with the requirements pursuant to section 4.3. 

3. This Board Order shall not be deemed or construed to be the result of any violation of 

any federal, state, or local statute, regulation, or ordinance for any purpose whatsoever. 

4. Ford LAP has reviewed this Board Order and consents to all its requirements and terms. 

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5. The effective date ofthis Board Order is January 1, 2000. 

Dated this 8th day ofNovember, 1999. 

Air Pollution Control Board 

of Jefferson Cmmty 

By: F<UvUJit/J 

Robert W. Powell, M.D. 

Chairman 

Air Pollution Control District 

of Jefferson County 

By: 

Arthur L. Williams 

Acting Air Pollution 

Control Officer 

Ford Louisville Assembly Plant 

Approved as to form and legality: 

Air Pollution Control District 

of Jefferson County 

By: ~~~t~~z£ Gayl . d R Ballard 

Attorney 

-2-
.:-· 

f 

Ford Louisville Assembly Pic...,L 

NOx RACT Plan 

1. The oxides of nitrogen (NOx, expressed as N02) emission from each of Boiler #4 and Boiler 

#5 shall not exceed 0.20 pound per million Btu ofheat input. 

2. Ford Louisville Assembly Plant (Ford LAP) shall conduct an ammal performance test for 

NOx for each of Boiler #4 and Boiler #5. If the requirements of Regulation 6.42 Reasonably 

Available Control Technology Requirements for lviajor Volatile Organic Compound- and 

Nitrogen Oxides-Emitting Facilities section 5.1 are met, and subject to the annual 

performance test schedule reinstitution provision, performance testing may be done on a 

biennial schedule. Performance testing shall meet the following requirements; · 

A. Emissions concentrations and the mass detenn:inations shall be obtained using 

Reference ~1ethods of 40 CFR Part 60 Appendix A. The following methods shall 

be used: · 

(1) Method 1 or 1A, which furnishes guidance in site and traverse selection for 

sampling velocity at traverse points in stationary sources, 

(2) Method 2, 2A, 2B, 2C, 2D, 2E, 2F, 2G, or 2H, .which applies to measurements 

of gas volumetric flow rates, 

(3) Method 3, 3A, 3B, or 3C, which is applicable for determining the 

concentrations of one or more of the following gases: carbon dioxide, 0 2, CO, 

nitrogen, and methane, . 

( 4) Method 4, which determines the moisture content in stack gases, and 

(5) Method 7, 7 A, 7B, 7C, 7D, or 7E, which provides the analyticafmethod for 

determining the concentration ofNOx emissions from stationary sources. 

B. The use of other Reference Methods that are added to 40 CFR Part 60 Appendix A, 

alternative tests, or modifications to the Reference Methods listed in NOx RACT 

Plan Element (Element) No. 2.A. may be proposed by Ford LAP as part of the 

testing plan required by Element No. 2.D. Such methods may be used if approved 

in vv.riting by the District. 

C. Performance testing shall meet the requirements of Regulation 1.04 Performance 

Tests that are not addressed in this Element 

D. A notification of intent to conduct a performance test shall be submitted to the 

District ~t least 25 working days in advance of the projected starting' date for the 

performance test. The notification shall include the proposed test methods t9 be 

used. 

E. If a pre-test conference to discuss the proposed test methods is deemed necessary 

by the District, a pre-test conference shall be arranged by District personnel. 

F. At least 10 working days' prior notice ofthe scheduled starting date for the 

performance test shall be provided to the District. 

G. A performance test report shall be submitted to the District ·within 60 days of 

completion of performance testing. The report shall ill elude the calculations used 

to determine emissions. The NOX emission rate shall be expressed in both pounds 

per hour and pounds per million Btu formats. The raw data shall be retained by 

Ford LAP for a minimum of 5 years and made available to the District upon 

NOx RACT Plan Page 1 --November 8, 1999 

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Ford Louisville Assembly PI:c. .•• 

request. Selected portions of the ·raw data used to calculate the emissions shall be 

included in the report in a format provided by the District. 

3. Boiler# 1, Boiler #2, and Boiler. #3 shall comply with the following requirements: 

A. No boiler shall have a monthly capacity factor greater than 10.0 % for any month 

during the period March 1 to October 31. The term "monthly capacity factor" 

means the ratio between the actual heat input to a boiler from fuel combusted 

during a month and the potential heat input to the boiler had it been operated for 24 

hours per day for the number of days in the month at the maximum steady state 

design heat :input capacity. The maximum heat input capacity provided by the 

manufacturer shall be used unless Ford LAP determines the maximum heat input 

capacity using the heat loss method described in sections 5 and 7.3 of the AS:tvffi 

Power Test Codes 4.1, and 

B. No boiler shall combust a fuel other than natural gas, distillate oil, or residual oil.· 

4. Ford LAP shall make a record of the type and amount of fuel com busted during each day of 

operation of Boiler #1, Boiler #2, or Boiler #3 during the period March 1 to October 31. 

Ford LAP shall, at the end of each month during this period, calculate and record, for each 

of Boiler #1, Boiler #2, and Boiler #3, the monthly capacity factor. Each record shall be 

maintained for a minimum of 5 years and made available to the District upon request. 

5. 

6. 

Ford LAP sha11 keep a record identifying all deviations from the requirements of this NO" 

RACT Plan and shall submit to the District a written report of all deviations that occurred 

during the preceding semi-annual period. Semi-annual periods shall run from January 1 to 

June 30 and July 1 to December 31. The report shall contain the following :information: 

A. The boiler number, 

B. The beginning and ending date of the reporting period, 

C. Id~mtification of all periods during which a deviation occurred, 

D. A description, including the magnitude, of the deviation, 

E. If known, the cause ofthe deviation, and 

F. A description of all corrective actions taken to abate the deviation. 

If no deviation occurred dming the semi-animal period, the report shall contain a negative 

declaration. Each report shall be submitted -vvithin 60 days following the end of the semiannual period; 

In lieu of the requirements in this NO" RACT Plan, Ford LAP may comply with altemative 

requirements regarding emission limitations, equipment operation, test methods, monitoring, 

recordkeeping, or reporting, provided the following conditions are met: 

A. The alternative requirements are established and incorporated into an operating 

permit pursuant to a Title V Operating Permit issuance, renewal, or significant 

permit revision· process as established in Regulation 2.1 6, 

B. The alternative requirements are consistent with the streamlining procedures and 

guidelines set forth in section II.A of White Paper Number 2 for Improved 

Implementation ofthe Part 70 Operating Permits Program, March 5, 1996, U.S. · 

Environmental Protection Agency, Office of Air Quality Planning and Standards. 

NOx RACT Plan Page 2 November 8, I 999 

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Ford Louisville Assembly PI1u.L 

The overall effect of compliance with alternative requirements shall consider the 

effect on an intrinsic basis, such as pounds per million Btu, 

C. The U.S. Environmental Protection Agency (EPA) has not objected to the 

issuance, renewal, or revision of the Title V Operating Permit, and either 

D. If the public comment period preceded the EPA review period, then the DistriCt 

had transmitted any public comments concerning the alternative requirements to 

EPA with the proposed permit, or 

E. Ifthe EPA and public comment periods ran concurrently, then the District had 

transmitted any public comments concerning the alternative requirements to EPA 

no later than 5 working days after the end of the public comment period. 

The District's determination of approval of any alternative requirements is not binding on 

EPA. Noncompliance with any alternative requirement established pursuant to the Title V 

Operating Permit process constitutes a violation of the NOx RACT Plan. 

NOx RACT Plan Page 3 November 8, 1999 

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'I'HE COURIER-JOURNAL INC. 

County of Jeffel"son 

Mfidavit of Publication 

Notice of Action 

ona1'itleV ·, Operatl!.l£l,fer.~ . 

· The ·Loui~vllle Metr-o Alr Poll.utlon control 01s· 

trii::t (D!stri~"t) proposes to lSsue a Title V op- erating permit to· . Ford Motor Company-Louisv.il!e. · Assembly Pla!1t, 

2000 Fern Valley Road, in accor- dance with Reg- ulation 2.16. T!Je 

30 day rubllc commen pertad 

starts June 11,. 

2010 and ends on . July 11; 2010: A . public heanng. 

I, Margie Wise of THE COURIER-JOIJRNAl, In~., clerk of THE tOURIJ ~i~~ rttt.~hp\~:. ·· 

1 . l . . d d bJ" h d . vill trict determmes JOURN.AI. genera Circu atlon pnnte an pu lS e atLoms e, that there are . germane, u.nr.e· 

Kentucky, do solemnly swear that from my own personal ~ebvst~~~~e;u~: 

knowledge:~ and reference to the files of said publication,. the ~gc~~j:~~~t\.Jig • "Regulatio!12.07. advertisement of: Drafts. !·~__!!e 

l 

Title:'~ 0-fJ ~ 

Run Date(s): fL/u J d-.D 10 

94.argie 'Wise 

Signature of person making proof 

Subscribecl and sworn to before me this /1 ~ 

Janice C rR.icfiarcfson 

permit are "vad• 

able at the·Pls· 

trict office, 850 · Barret Ave, Lou·. Total Lines: K '!s.ville between d 8:30 a.m. and 

4·30 p.m., Man· d~y through frl· 

T alI h day by cal.lmg Ot TIC es: /x ). Matt Kl ng a

4

t 

(502) 57 4-6-7-1 • · = Written c9m-· . ments will be·accepted by Matt 

King, Perml'\:ting Engineering SU· 

day of June, 2010. 

g

. ervisor at the . istri'ct offlc.<? un- · til 5 p.m. July 11, 

2010. . . 

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GREG FISCHER 

MAYOR 

Ford Motor Co., LAP 

Greg Long 

POBOX32990 

Louisville, KY 40232-2990 

Dear Mr. Long: 

AIR POLLUTION CONTROL DISTRICT 

LOUISVILLE, KENTUCKY 

March 28, 2011 

LAUREN ANDERSON, DIRECTOR 

Enclosed are the approved revised Title V permit P-147-97-TV(R2), the revised PAL 

construction permit P-24509-C(Rl), and the accompany Statement of Basis, issued by the 

Louisville Metro Air Pollution Control District. These permits include both general and specific 

conditions, compliance with these permit conditions help maintain a healthy environment for the 

citizens of Louisville. 

The District encourages facilities to investigate pollution prevention. These efforts can 

save you money, while reducing pollution and energy consumption. For more guidance on 

identifying opportunities for waste reduction and energy efficiency, please contact the Kentucky 

Pollution Prevention Center at (502) 852-0965. 

Please do not hesitate to contact the Permit Engineer identified on the permit at (502) 

574-6000 if you have any questions regarding the permit or permit conditions. 

Sincerely, 

-poJJJCkL 

Paul G. Aud, P.E. 

Engineer Manager 

Enclosures: Revised Title V Operating Permit P-147-97-TV (R2) 

TV Statement of Basis (SoB) 

PA: da 

Revised PAL Construction Permit P-24509-C (Rl) 

PAL Construction Permit Statement of Basis (SoB) 

www .louisvilleky .gov 

WWW.LOUISVILLEKY.GOV/APCD 850 BARRET AVENUE, ROOM 205 LOUISVILLE, KENTUCKY 40204-1745 502.574.6000 FAX: 502.574.5306 
Louisville Metro Air Pollution Control District 

850 Barret Avenue 

Louisville, Kentucky 40204-17 45 

Title V Operating Permit 

Permit No.: 147-97-TV (R2) Plant ID: 0072 

Effective Date: 03/31/2011 Expiration Date: 10/31/2015 

Permission is hereby given by the Louisville Metro Air Pollution Control District to operate the 

process(es) and equipment described herein which are located at: 

Ford Motor Company-Louisville Assembly Plant 

2000 Fern Valley Road 

Louisville, Kentucky 40213 

The applicable procedures of District Regulation 2.16 regarding review by the U.S. EPA and 

public participation have been followed in the issuance of this permit. Based on review of the 

application on file with the District, permission is given to operate under the conditions 

stipulated herein. If a renewal permit is not issued prior to the expiration date, the owner or 

operator may continue to operate in accordance with the terms and conditions of this permit 

beyond the expiration date, provided that a complete renewal application is submitted to the 

District no earlier than eighteen (18) months and no later than one-hundred eighty (180) days 

prior to the expiration date. 

Permit Writer: Shannon Clemons Hosey 

-poJlJ~ Air Pollution Control Officer 

Administratively Complete: 09/20/2005 and 10/06/2008 

Date of Public Notice: 07/19/2010 

Date of Proposed Permit: 03/31/2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Table of Contents 

PAL/Title V Permit Revisions/Changes ......................................................................................... 4 

Abbreviations and Acronyms ......................................................................................................... 5 

Preamble ......................................................................................................................................... 6 

General Conditions ......................................................................................................................... 7 

Plant-wide Applicability Limits .................................................................................................... 16 

Plant-wide Applicability Limit (PAL) Specific Conditions ............................................. 16 

PAL Monitoring and Record Keeping Requirements ....................................................... 18 

PAL Permit Requirements ................................................................................................ 22 

PAL Compliance Demonstration ...................................................................................... 25 

PAL Reporting Requirements ........................................................................................... 28 

PAL Performance Testing ................................................................................................. 29 

Plant-wide Applicability Limits Comments ..................................................................... 31 

Louisville Assembly Plant, Ford Motor Company Maximum Achievable Control Technology 

(MACT) Requirements ..................................................................................................... 32 

STAR Requirements ..................................................................................................................... 40 

U002 - U004 Emission Unit Description: Five Boilers ............................................................... 42 

U002 - U004 Regulations ................................................................................................. 42 

U002 - U004 Control Devices .......................................................................................... 43 

U002- U004 Specific Conditions ..................................................................................... 44 

U002 - U004 Comments ................................................................................................... 48 

U008 Emission Unit Description: Volatile Organic Liquid Storage Tanks ................................ 49 

U008 Applicable Regulations ........................................................................................... 49 

U008 Emission Points ....................................................................................................... 50 

U008 Control Device ........................................................................................................ 50 

U008 Specific Conditions ................................................................................................. 51 

U008 Comments ............................................................................................................... 52 

U009 Emission Unit Description: Glass Installation ................................................................... 53 

U009 Applicable Regulations ........................................................................................... 53 

U009 Emission Points ....................................................................................................... 54 

U009 Control Devices ....................................................................................................... 54 

U009 Specific Conditions ................................................................................................. 55 

UOIO Emission Unit Description: E-Coat Operation ................................................................... 58 

UO 1 0 Applicable Regulations ........................................................................................... 58 

U01 0 Emission Points ....................................................................................................... 59 

UO 10 Control Devices ....................................................................................................... 60 

UO 1 0 Specific Conditions ................................................................................................. 61 

UO 10 Comments ............................................................................................................... 67 

U011 Emission Unit Description: Guidecoat Operation .............................................................. 68 

U011 Applicable Regulations ........................................................................................... 68 

U011 Emission Points ....................................................................................................... 70 

U011 Control Devices ....................................................................................................... 71 

U011 Control Devices ....................................................................................................... 71 

UO 11 Specific Conditions ................................................................................................. 72 

UO 11 Comments ............................................................................................................... 79 

SCH Page 2 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

UO 12 Emission Unit Description: Topcoat Operation ................................................................. 80 

U012 Applicable Regulations ........................................................................................... 80 

U012 Emission Points ....................................................................................................... 82 

U012 Control Devices ....................................................................................................... 85 

U012 Specific Conditions ................................................................................................. 86 

U012 Comments ............................................................................................................... 92 

UO 13 Emission Unit Description: Plant-wide Product Fueling ................................................... 93 

UO 13 Applicable Regualtions ........................................................................................... 93 

UO 13 Emissions Points ..................................................................................................... 94 

UO 13 Control Equipment .................................................................................................. 94 

U013 Specific Conditions ................................................................................................. 95 

UO 13 Comments ............................................................................................................... 97 

U014 and U022 Emission Unit Description: Paint Equipment Cleaning Operation ................... 98 

U014 and U022 Applicable Regulations .......................................................................... 98 

UO 14 and U022 Emission Points ...................................................................................... 99 

UO 14 and U022 Control Devices ...................................................................................... 99 

UO 14 and U022 Specific Conditions .............................................................................. 100 

U014 and U022 Comments ............................................................................................. 103 

U015 Emission Unit Description: Sealer Deck ......................................................................... 104 

UO 15 Applicable Regulations ......................................................................................... 104 

UO 15 Emission Points ..................................................................................................... 105 

U015 Control Devices ..................................................................................................... 105 

UO 15 Specific Conditions ............................................................................................... 106 

UO 16 Emission Unit Description: Final Repair Spray Booth .................................................... 109 

UO 16 Applicable Regulations ......................................................................................... 109 

U016 Control Devices ..................................................................................................... 112 

UO 16 Specific Conditions ............................................................................................... 113 

U016 Comments ............................................................................................................. 117 

U023 Emission Unit Description: Phosphate Operation ........................................................... 118 

U023 Applicable Regulations ......................................................................................... 118 

U023 Emission Points ..................................................................................................... 118 

U023 Control Devices ..................................................................................................... 118 

U023 Specific Conditions ............................................................................................... 119 

U025 Emission Unit Description: Twelve (12) Direct Heat Exchangers .................................. 120 

U025 Applicable Regulations ......................................................................................... 120 

U025 Emission Points ..................................................................................................... 120 

U025 Control Devices ..................................................................................................... 120 

U025 Specific Conditions ............................................................................................... 121 

U025 Comments ............................................................................................................. 123 

Permit Shield ............................................................................................................................... 124 

Alternative Operating Scenarios ................................................................................................. 124 

Insignificant Activities ................................................................................................................ 124 

Compliance Assurance Monitoring ............................................................................................ 127 

Attachment A .............................................................................................................................. 13 0 

SCH Page 3 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

PAL/Title V Permit Revisions/Changes 

Revision Issue Public Attachment 

No. Date Notice Date Type No./Page No. Description 

N/A 10/6/2000 4/23/2000 Initial Entire Permit Initial TV Permit 

Issuance 

R1 9/17/2010 7119/2010 Initial/ Entire Permit 5 year Renewal; 

Renewal Incorporate PAL, STAR 

TAC requirements, RO 

change, DRE forE-coat 

control device change 

and 112(J) Part 1 & 2 

applications. 

R2 3/31/2011 NA Admin Pages 43,45 Revision to include 

Revision and 50 permit 229-96-0, add 

NOx RACT language 

and correct Methanol 

Tank Vapor Pressure 

I Application # I Date I Type I 

9761 09/09/2004 TV Revision (Multi Request) 

9509 08/28/2003 TV Revision (Stage II) Request 

10016 07/22/2005 TV Admin Change 

10457 07/22/2005 TV Renewal 

10789 12/07/2007 TV Revision Request DRE forE-Coat 

System Control Device 

11033 07/17/2008 TV Revision Request Reporting Revision 

11042 08/07/2008 TV IP AL Renewal application - Updated 

11230 03/06/2009 112(J) Part 1 & 2 applications 

11319 04/30/2009 TYRO Change 

SCH Page 4 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

Abbreviations and Acronyms 

AFS - Airs Facility Subsystem 

AIRS - Aerometric Information Retrieval System 

APCD - Air Pollution Control District 

ASL - Adjusted Significant Level 

atm - Atmosphere 

BACT- Best Available Control Technology 

Btu - British Thermal Unit 

CEMS - Continuous Emission Monitoring System 

CAAA- Clean Air Act Amendments (15 November 1990) 

HAP - Hazardous Air Pollutant 

hr - hour 

lbs - Pounds 

1 - Liter 

MACT- Maximum Achievable Control Technology 

m - Meter 

mg - Milligram 

mm - Millimeter 

MM - Million 

MOCS- Management of Change System 

NAICS- North American Industry Classification System 

NSR - New Source Review 

NOx - Nitrogen oxides 

NSPS - New Source Performance Standards 

PAL - Plant-wide Applicability Limit 

PM - Particulate Matter 

PMw - Particulate matter less than 10 microns 

ppm - Parts per million 

PSD - Prevention of Significant Deterioration 

PMP - Preventive Maintenance Plan 

psia - Pounds per square inch absolute 

RACT- Reasonably Available Control Technology 

SC - Specific Condition 

SIC - Standard Industrial Classification 

SIP - State Implementation Plan 

S02 - Sulfur dioxide 

TAC -Toxic Air Contaminant 

TAL - Threshold Ambient Limit 

TAP - Toxic Air Pollutant 

tpy - Tons per year 

UTM - Universal Transverse Mercator 

VOC - Volatile Organic Compound 

SCH Page 5 of 130 

Plant ID: 0072 

03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Preamble 

Title V of the Clean Air Act Amendments of 1990 required EPA to create an operating permit 

program for implementation by state or local air permitting authorities. The purposes of this 

program are (1) to require an affected company to assume full responsibility for demonstrating 

compliance with applicable regulations; (2) to capture all of the regulatory information 

pertaining to an affected company in a single document; and (3) to make permits more consistent 

with each other. 

A company is subject to the Title V program if it meets any of several criteria related to the 

nature or amount of its emissions. The Title V operating permit specifies what the affected 

company is, how it may operate, what its applicable regulations are, how it will demonstrate 

compliance, and what is required if compliance is not achieved. In Jefferson County, Kentucky, 

the Air Pollution Control District (APCDJC) is responsible for issuing Title V permits to affected 

companies and enforcing local regulations and delegated federal and state regulations. EPA may 

enforce federal regulations but not "District Only Enforceable Regulations". 

Title V offers the public an opportunity to review and comment on a company's draft permit. It is 

intended to help the public understand the company's compliance responsibility under the Clean 

Air Act. Additionally, the Title V process provides a mechanism to incorporate new applicable 

requirements. Such requirements are available to the public for review and comment before they 

are adopted. 

Title V Permit general conditions define requirements which are generally applicable to all Title 

V companies under the jurisdiction of APCDJC. This avoids repeating these requirements in 

every section of the company's Title V permit. Company-specific conditions augment the general 

conditions as necessary; these appear in the sections of the permit addressing individual emission 

units or emission points. 

The general conditions include references to regulatory requirements that may not currently 

apply to the company, but which provide guidance for potential changes at the company or in the 

regulations during the life of the permit. Such requirements may become applicable if the 

company makes certain modifications or a new applicable requirement is adopted. 

When the applicability of a section or subpart of a regulation is unclear, a clarifying citation will 

be made in the company's Title V permit at the emission unit/point level. Comments may also be 

added at the emission unit/point level to give further clarification or explanation. 

The source's Title V permit may include a current table of "insignificant activities." 

Insignificant activities are defined in District Regulation 2.16 section 1.22, as of the date the 

permit was proposed for review by U.S. EPA, Region 4. Insignificant activities identified in 

District Regulation 2.02, Section 2 may be subject to size or production rate disclosure 

requirements pursuant to Regulation 2.16 section 3.5 .4.1.4. Insignificant activities identified in 

District Regulation 2.02, Section 2 shall comply with generally applicable requirements as 

required by Regulation 2.16 section 4.1.9.4. 

SCH Page 6 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

General Conditions 

1. Compliance - The owner or operator shall comply with all applicable requirements and 

with all terms and conditions of this permit. Any noncompliance shall constitute a 

violation of the Act, State and District regulations and shall cause the source to be subject 

to enforcement actions including, but not limited to, the termination, revocation and 

reissuance, or revision of this permit, or denial of a permit application to renew this 

permit. Notwithstanding any other provision in the Jefferson County portion of the 

Kentucky SIP approved by EPA, any credible evidence may be used for the purpose of 

establishing whether the owner or operator is in compliance with, has violated, or is in 

violation of any such plan. (Regulation 2.16, sections 4.1.3, 4.1.13.1 and 4.1.13.7) 

2. Compliance Certification - The owner or operator shall certify, annually or more 

frequently if required in applicable regulations, compliance with the terms and conditions 

contained in this permit, including emission limitations, standards, or work practices. 

This certification shall meet the requirements of Regulation 2.16, sections 3.5.11 and 

4.3.5. The owner or operator shall submit the annual compliance certification directly to 

the following address as well as to the District, as set forth in Regulation 2.16, section 

4.3.5.4: 

US EPA- Region IV 

Air Enforcement Branch 

Atlanta Federal Center 

61 Forsyth Street 

Atlanta, GA 30303-8960 

3. Compliance Schedule - A compliance schedule must meet the requirements of 

Regulation 2.16, section 3.5.9.5. The owner or operator shall submit a schedule of 

compliance for each emission unit that is not in compliance with all applicable 

requirements. A schedule of compliance shall be supplemental to, and shall not condone 

noncompliance with, the applicable requirements on which it is based. For each schedule 

of compliance, the owner or operator shall submit certified progress reports at least semiannually, or at a more frequent period if specified in an applicable requirement or by the 

District in accordance with Regulation 2.16 section 4.3.4. The progress reports shall 

contain: 

a. Dates for achieving the activities, milestones, or compliance required in the 

schedule of compliance, and dates when activities, milestones, or compliance 

were achieved. 

b. An explanation of why dates in the schedule of compliance were not or will not 

be met, and preventive or corrective measures adopted. 

4. Duty to Supplement or Correct Application - If the owner or operator fails to submit 

relevant facts or has submitted incorrect information in the permit application, it shall, 

SCH Page 7 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

upon discovery of the occurrence, promptly submit the supplementary facts or corrected 

information in accordance with Regulation 2.16, section 3.4. 

5. Emergency Provision 

a. An emergency shall constitute an affirmative defense to an enforcement action 

brought for noncompliance with technology-based emission limitations. The 

affirmative defense of emergency shall be demonstrated through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

1. An emergency occurred and that the owner or operator can identify the 

cause ofthe emergency. 

n. The permitted facility was at the time being properly operated. 

iii. During the period of the emergency the owner or operator expeditiously 

took all reasonable steps, consistent with safe operating practices, to 

minimize levels of emissions that exceeded the emission standards or 

other requirements in this permit. 

iv. The owner or operator submitted notice meeting the requirements of 

Regulation 1.07 of the time when emissions limitations were exceeded 

because of the emergency. This notice must fulfill the requirement of this 

condition, and must contain a description of the emergency, any steps 

taken to mitigate emissions, and any corrective actions taken. 

b. In an enforcement proceeding, the owner or operator seeking to establish the 

occurrence of an emergency has the burden of proof. 

c. This condition is in addition to any emergency or upset provision contained in an 

applicable requirement. (Regulation 2.16, sections 4.7.1 through 4.7.4) 

6. Emission Fees Payment Requirements - The owner or operator shall pay annual 

emission fees in accordance with Regulation 2.08. Failure to pay the emissions fees when 

due shall constitute a violation of District Regulations. Such failure is subject to penalties 

and an increase in the fee of an additional 5% per month up to a maximum of 25% of the 

original amount due. In addition, failure to pay emissions fees within 60 days of the due 

date shall automatically suspend this permit to operate until the fee is paid or a schedule 

for payment acceptable to the District has been established. (Regulation 2.08, section 1.3) 

7. Emission Offset Requirements - The owner or operator shall comply with the 

requirements of Regulation 2.04. 

8. Enforceability Requirements- Except for the conditions that are specifically designated 

as "District Only Enforceable Conditions", all terms and conditions of this permit, 

SCH Page 8 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

including any provisions designed to limit a source's potential to emit, are enforceable by 

EPA and citizens as specified under the Act. (Regulation 2.16, sections 4.2.1 and 4.2.2) 

9. Enforcement Action Defense 

a. It shall not be a defense for the owner or operator in an enforcement action that it 

would have been necessary for the owner or operator to halt or reduce the 

permitted activity in order to maintain compliance with the conditions of this 

permit. 

b. The owner or operator's failure to halt or reduce activity may be a mitigating 

factor in assessing penalties for noncompliance if the health, safety or 

environmental impacts of halting or reducing operations would be more serious 

than the impacts of continued operation. (Regulation 2.16, sections 4.1.13 .2 and 

4.1.13.3) 

10. Hazardous Air Pollutants and Sources Categories - The owner or operator shall 

comply with the applicable requirements ofRegulations 5.02 and 5.14. 

11. Information Requests - The owner or operator shall furnish to the District, within a 

reasonable time, information requested in writing by the District, to determine whether 

cause exists for revising, revoking and reissuing, or terminating this permit, or to 

determine compliance with this permit. The owner or operator shall also furnish, upon 

request, copies of records required to be kept by this permit. (Regulation 2.16, section 

4.1.13.6) 

If information is submitted to the District under a claim of confidentiality, the source 

shall submit a copy of the confidential information directly to EPA. (Regulation 2.07, 

section 1 0.2) 

12. Insignificant Activities - The owner or operator shall: 

a. Notify the District in a timely manner of any proposed change to an insignificant 

activity that would require a permit revision. (Regulation 2.16, section 5) 

b. Submit a current list of insignificant activities by April 15 of each year with the 

annual compliance certification, including an identification of the additions and 

removals of insignificant activities that occurred during the preceding year. 

(Regulation 2.16, section 4.3.5.3.6) 

13. Inspection and Entry - Upon presentation of credentials and other documents as 

required by law, the owner or operator shall allow the District or an authorized 

representative to perform the following during reasonable hours: 

SCH 

a. Enter the premises to inspect any emissions-related activity or records required in 

this permit. 

Page 9 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

b. Have access to and copy records required by this permit. 

c. Inspect facilities, equipment (including monitoring and air pollution control 

equipment), practices, or operations regulated or required by this permit. 

d. Sample or monitor substances or parameters to assure compliance with this permit 

or any applicable requirements. (Regulation 2.16, section 4.3.2) 

14. Monitoring and Related Record Keeping and Reporting Requirement -The owner 

or operator shall comply with the requirements of Regulation 2.16, section 4.1.9. The 

owner or operator shall submit all required monitoring reports at least once every three 

months, unless more frequent reporting is required by an applicable requirement. The 

reporting period shall be January 1st through March 31, April1 through June 301

h, July 

1st through September 30 and October 1 through December 31st of each calendar year. 

All reports shall be postmarked by the 60th day following the end of each reporting 

period. If surrogate operating parameters are monitored and recorded in lieu of emission 

monitoring, then an exceedance of multiple parameters may be deemed a single violation 

by the District for enforcement purposes. All reports shall include the company name, 

plant ID number, and the beginning and ending date of the reporting period. The 

compliance reports shall clearly identify any deviation from a permit requirement. All 

quarterly compliance reports shall include the following certification statement per 

Regulation 2.16. 

SCH 

"Based on information and belief formed after reasonable inquiry, I certify that 

the statements and information in this document are true, accurate, and complete". 

Signature and title of company responsible official. 

If a change in the "Responsible Official" (RO) occurs during the term of this permit, the 

owner or operator shall provide written notification (Form 9400-A and Form AP-0208) to 

the District within 30 calendar days following the date a change in the designated RO 

occurs for this facility. 

The quarterly compliance reports are due on or before the following dates of each 

calendar year: 

Reporting Period 

January 1 through March 30 

April1 through June 30 

July 1 through September 30 

October 1 through December 31 

Note: 

The date for leap years is February 29. 

Page 10 of 130 

Report Due Date 

May30 

August 29th 

November 29 

March 1 stl 

03-31-2011 
PermitNo: 147-97-TV (R2) PlantiD: 0072 

15. Off-permit Documents- Any applicable requirements, including emission limitations, 

control technology requirements, or work practice standards, contained in an off-permit 

document cannot be changed without undergoing the permit revision procedures in 

Regulation 2.16, Section 5. (Regulation 2.16, section 4.1.5) 

16. Operational Flexibility - The owner or operator may make changes without permit 

revision in accordance with Regulation 2.16, section 5.8. 

17. Permit Amendments (Administrative) - This permit can be administratively amended 

by the District in accordance with Regulation 2.16, sections 2.3 and 5.4. 

18. Permit Application Submittal - The owner or operator shall submit a timely and 

complete application for permit renewal or significant revision. If the owner or operator 

submits a timely and complete application then the owner or operator's failure to have a 

permit is not a violation until the District takes formal action on this permit application. 

This protection shall cease to apply if, subsequent to completeness determination, the 

owner or operator fails to submit, by the deadline specified in writing by the District, 

additional information required to process the application as required by Regulation 2.16, 

sections 3 and 5.2. 

19. Permit Duration - This permit is issued for a fixed term of 5 years, in accordance with 

Regulation 2.16, section 4.1.8.3. 

20. Permit Renewal, Expiration and Application - Permit renewal, expiration and 

application procedural requirements shall be in accordance with Regulation 2.16, sections 

4.1.8.2 and 5.3. This permit may only be renewed in accordance with section 5.3. 

21. Permit Revisions -No permit revision shall be required under any approved economic 

incentives, marketable permits, emissions trading and other similar programs or processes 

for changes that are provided for in the permit. (Regulation 2.16, section 4.1.16) 

22. Permit Revision Procedures (Minor)- Except as provided in 40 CFR Part 72, the Acid 

Rain Program, this permit may be revised in accordance with Regulation 2.16, section 

5.5. 

23. Permit Revision Procedures (Significant) - A source seeking to make a significant 

permit revision shall meet all the Title V requirements for permit applications, issuance 

and Permit renewal, in accordance with Regulation 2.16, section 5.7, and all other 

applicable District Regulations. 

24. Permit Revocation and Termination by the District - The District may terminate this 

permit only upon written request of the owner'or operator. The District may revoke a 

permit for cause, in accordance with Regulation 2.16, section 5.11.1.1 through 5.11.1.5. 

For purposes of Section 5, substantial or unresolved noncompliance includes, but is not 

limited to: 

SCH Page 11 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

a. Knowingly operating process or air pollution control equipment in a manner not 

allowed by an applicable requirement or that results in excess emissions of a 

regulated air pollutant that would endanger the public or the environment. 

b. Failure or neglect to furnish information, analyses, plans, or specifications 

required by the District. 

c. Knowingly making any false statement in any permit application. 

d. Noncompliance with Regulation 1.07, section 4.2; or 

e. Noncompliance with KRS Chapter 77. 

25. Permit Shield - The permit shield shall apply m accordance with Regulation 2.16, 

section 4.6.1. 

26. Prevention of Significant Deterioration of Air Quality - The owner or operator shall 

comply with the requirements of Regulation 2.05. 

27. Property Rights - This permit shall not convey property rights of any sort or grant 

exclusive privileges in accordance with Regulation 2.16, section 4.1.13 .5. 

28. Public Participation - Except for modifications qualifying for administrative permit 

amendments or minor permit revision procedures, all permit proceedings shall meet the 

requirements ofRegulations 2.07, Section 1; and 2.16, sections 5.1.1.2 and 5.5.4. 

29. Reopening For Cause - This permit shall be reopened and revised by the District in 

accordance with Regulation 2.16 section 5.9. 

30. Reopening for Cause by EPA - This permit may be revised, revoked and reissued or 

terminated for cause by EPA in accordance with Regulation 2.16 section 5.10. 

31. Risk Management Plan (112(r)) -For each process subject to Section 112(r) of the Act, 

the owner or operator shall comply with 40 CFR Part 68 and Regulation 5.15. 

32. Severability Clause - The conditions of this permit are severable. Therefore, if any 

condition of this permit, or the application of any condition of this permit to any specific 

circumstance, is determined to be invalid, the application of the condition in question to 

other circumstances, as well as the remainder of this permit's conditions, shall not be 

affected. (Regulation 2.16, section 4.1.12) 

33. Stack Height Considerations - The owner or operator shall comply with the 

requirements of Regulation 2.10. 

34. Startups, Shutdowns, and Upset Conditions Requirements - The owner or operator 

shall comply with the requirements of Regulation 1.07. 

SCH Page 12 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

35. Submittal of Reports, Data, Notifications, and Applications 

a. Applications, reports, test data, monitoring data, compliance certifications, and 

any other document required by this permit as set forth in Regulation 2.16 

sections 3.1, 3.4, 3.5, 4.1.13.6, 5.8.5 and 5.11.7 shall be submitted to: 

Louisville Metro Air Pollution Control District 

850 Barret Ave 

Louisville, KY 40204-1745 

b. Documents which are specifically required to be submitted to EPA as set forth in 

Regulation 2.16 sections 3.3, and 5.8.5 shall be mailed to EPA at the following 

address: 

US EPA -Region IV 

APTMD -12th floor 

Atlanta Federal Center 

61 Forsyth Street 

Atlanta, GA 30303-3104 

36. Other Applicable Regulations - The owner or operator shall comply with all applicable 

requirements ofthe following: 

Regulation Title 

1.01 General Provisions 

1.02 Definitions 

1.03 Abbreviations And Acronyms 

1.04 Performance Tests 

1.05 Compliance With Emissions Standards And Maintenance Requirements 

1.06 Source Self-Monitoring and Reporting 

1.07 Emissions During Shutdowns, Malfunctions, Startups, and Emergencies 

1.08 Administrative Procedures 

1.09 Prohibition of Air Poilution 

1.10 Circumvention 

1.11 Control of Open Burning 

1.14 Control of Fugitive Particulate Emissions 

2.01 General Application 

2.02 Air Poiiution Regulation Requirements and Minor Facility Exemptions 

2.03 Permit Requirements -Non-Title V Construction and Operating Permits and Demolition/ 

Renovation Permits 

2.07 Public Notification for Title V, PSD, and Other Offset Permits; SIP Revisions; and Use of 

Emission Reduction Credits 

2.09 Causes for Permit Suspension 

SCH Page 13 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

1.-. -• ion Title 

2.10 Stack Height Considerations 

2.11 Air Quality Model Usage 

2.16 Title V Operating Permits 

4.01 General Provisions for Emergency Episodes 

4.02 Episode Criteria ---

4.03 General Abatement Requirements 

4.07 Episode Reporting Requirements 

6.01 General Provisions (Existing Affected Facilities) 

6.02 Emission Monitoring for Existing Sources 

7.01 General Provisions (New Affected Facilities) 

District Only Enforceable: 

tion Title 

1.12 Control ofNuisances 

1.13 Control of Objectionable Odors 

2.08 Emission Fee, Permit Fees and Permit Renewal Procedures 

5.01 Standards for Toxic Air Contaminants and Hazardous Air Pollutants 

5.20 Methodology for Determining Benchmark Ambient Concentration of a Toxic Air Contaminant 

5.21 Environmental Acceptability for Toxic Air Contaminants 

5.22 Procedures for Determining the Maximum Ambient Concentration of a Toxic Air Contaminant 

5.23 Categories of Toxic Air Contaminants 

37. Stratospheric Ozone Protection Requirements - Any facility having refrigeration 

equipment, including air conditioning equipment, which uses a Class I or II substance 

(listed in 40 CFR 82, Subpart A, Appendices A and B), and any facility which maintains, 

services, or repairs motor vehicles using a Class I or II substance as refrigerant must 

comply with all requirements of 40 CFR 82, Subparts A, B, and F. Those requirements 

include the following restrictions: 

SCH 

a. Any facility having any refrigeration equipment normally containing fifty (50) 

pounds of refrigerant, or more, must keep servicing records documenting the date 

and type of all service and the quantity of any refrigerant added according to 40 

CPR 82.166; 

b. No person repairing or servicing a motor vehicle may perform any service on a 

motor vehicle air conditioner (MV A C) involving the refrigerant for such air 

conditioner unless the person has been properly trained and certified as provided 

in 40 CFR 82.34 and 40 CFR 82.40, and properly uses equipment approved 

according to 40 CFR 82.36 and 40 CFR 82.38, and complies with 40 CFR 82.42; 

Page 14 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

c. No person may sell or distribute, or offer for sale or distribution, any substance 

listed as a Class I or II substance in 40 CPR 82, Subpart A, Appendices A and B, 

except in compliance with 40 CPR 82.34(b ), 40 CPR 82.42, and/or 40 CPR 

82.166. 

d. No person maintaining, serviCmg, repamng, or disposing of appliances may 

knowingly vent or otherwise release into the atmosphere any Class I or II 

substance used as a refrigerant in such equipment and no other person may open 

appliances (except MV ACs as defined in 40 CPR 82.152) for service, 

maintenance, or repair unless the person has been properly trained and certified 

according to 40 CPR 82.161 and unless the person uses equipment certified for 

that type of appliance according to 40 CPR 82.158 and unless the person observes 

the practices set forth in 40 CPR 82.156 and 40 CPR 82.166; 

e. No person may dispose of appliances (except small appliances, as defined in 40 

CPR 82.152) without using equipment certified for that type of appliance 

according to 40 CPR 82.158 and without observing the practices set forth in 40 

CPR 82.156 and 40 

CPR 82.166; 

f. No person may recover refrigerant from small appliances, MV ACs and MV AClike appliances (as defined in 40 CPR 82.152), except in compliance with the 

requirements of 40 CPR 82 Subpart P; 

g. If the permittee manufactures, transforms, imports, or exports, a Class I or II 

substance (listed in 40 CPR 82, Subpart A, Appendices A and B), the permittee is 

subject to all requirements as specified in 40CPR82 Subpart A, Production and 

Consumption Controls. (Regulation 2.16, section 4.1.5) 

Page 15 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Louisville Assembly Plant, Ford Motor Company Plant-wide Applicability Limit (PAL): 

FEDERALLY ENFORCEABLE REGULATIONS 

Regulation Title Applicable Sections 

Permit Requirements Non-Title V Construction and 

2.03 Operating Permits and Demolition/Renovation 1, 2, 3, 4, & 5 

Permits 

2.05 Prevention of Significant Deterioration of Air Quality 1 

40 CFR 52.21 Approval and Promulgation of Implementation Plans 

Plant-wide Applicability Limits 

Pollutant Tons/Year** 

voc 1,316 

PM 21.2 

PMIO 21.2 

PM2.s 17.2 

NOx 99.0 

S02 39.33 

co 151.4 

** Represents a 12-month rolling total 

Sl. Plant-wide Applicability Limit (PAL) Specific Conditions (Regulation 2.05, section 1 

& Regulation 2.03) 

SCH 

a. Under the provisions of this PAL, if the permittee adds a new emission unit or 

modifies an existing unit, the unit would not be subject to major NSR (nonattainment or PSD) as long as the PAL emission limits (ton per year limits in the 

above table) are not exceeded. 

b. Operational and Equipment Modifications 

1) Ford Motor Company Louisville Assembly Plant is authorized to perform 

the physical or operational changes, or changes deemed consistent with 

those physical or operational changes, without applying for or obtaining a 

construction permit or amendment from the permitting authority pursuant 

to Regulation 2.03 as long as the PAL is not exceeded. 

2) The permittee shall maintain a log of equipment installed and/or modified 

and the date on which construction and/or modification and operation 

began. In addition, the permittee shall maintain a log of equipment 

Page 16 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

removed from the installation and the date on which it was removed. The 

log must account for all equipment present at the installation at any given 

time. Attachment A, or equivalent forms may be used for this purpose. 

3) If the permittee wishes to make physical or operational changes that are 

not deemed consistent with the physical or operations changes listed in 

this construction permit and are not exempt from the construction permit 

rule, then the permittee must first apply for and obtain a construction 

permit or amendment. 

c. Notification of Actual Construction of Change: 

Ford Motor Company Louisville Assembly Plant shall submit written notification 

to the permitting authority at least ten days prior to the actual construction change 

to or addition of any emission unit covered by this PAL permit that are not 

excluded under Specific Condtions S 1.h. The notification shall contain the 

following: 

1) Detailed description of the physical or operational change including the 

effect on existing equipment; 

2) A plant layout diagram with representation of existing equipment and 

physical or operational changes; 

3) A schedule of construction activities related to the change; 

4) A statement of applicability for any New Source Performance Standard, 

National Emissions Standard of Hazardous Air Pollutants and /or state 

regulations not identified as core requirements in the operating permit; 

5) An emissions calculation sheet for the change; 

6) A statement of verification that the physical or operational change will not 

result in installation emissions that exceed the limitations stated in 

Specific Conditions S 1.b.; and 

7) A summary of the impact analysis on the capture efficiency as outlined in 

Specific Condition S2.i. for those units where compliance with an 

applicable emission limit or standard is dependent upon the use of the 

control device. 

d. Portions of the notification such as descriptions of changes and associated 

applicability determination shall become an enforceable part of this construction 

permit upon receipt by the permitting authority. 

e. The permitting authority may disapprove any activity that has not demonstrated to 

Page 17 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

the satisfaction of the Program to be related to the changes. At the time, the 

permittee shall cease construction of the change until an appropriate authorization 

of the activities is obtained (such as a construction permit, if necessary). 

f. Notification of Actual Start-up of Change: 

Ford Motor Company Louisville Assembly Plant shall submit written notification 

to the permitting authority at least ten days prior to the actual start-up or operation 

of any change listed in this PAL permit. The notification shall contain the 

following: 

1) Reference to the notification of actual construction including date of 

notification and brief description of change; 

2) Verification that the physical or operational change was completed as 

described in the original notification; and 

3) Scheduled date operations will be commenced. 

g. It is a violation of this construction permit for Ford Motor Company Louisville 

Assembly Plant to construct, modify or operate the installation not in accordance 

with the notification Specific Condtions S 1.f. 

h. The notification letter identified in c. and f. above is not required for sources that 

are otherwise exempt from the requirement to obtain a permit or are included in 

the list of insignificant sources in the Appendix to this Title V Operating Permit. 

S2. PAL Monitoring and Record Keeping Requirements (Regulation 2.05, section 1 & 

Regulation 2.03) 

SCH 

a. The permittee shall maintain a copy of all records necessary to determine 

compliance with requirements of the PAL, including a determination of each 

emission unit's monthly and twelve-month rolling total emissions, for five years 

from the originating date of such record. 

b. The permittee shall retain a copy of the following records for the duration of the 

PAL effective period plus five years: 

1) A copy of the PAL permit application and any applications for revisions to 

the PAL; and 

2) Each annual certification of compliance pursuant to Title V and the data 

relied on in certifying compliance. 

Page 18 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

3) Copies of any notification for any new or modified emission units that is 

not subject to the requirement to obtain a Permit to Construct under the 

provisions ofthe PAL. 

c. The permittee shall monitor all emission units at the facility in accordance with 

the specific monitoring requirements contained in each emission unit. 

d. Ford Motor Company Louisville Assembly Plant shall submit a quarterly 

emissions report to the permitting authority within 60 days after the end of each 

reporting period. 

The reports shall contain the following information: 

1) Identification of owner and operator and the permit number; 

2) Total annual emissions in tons per year based on a 12-month rolling total 

for each month in the reporting period. 

3) A summary of all data relied upon, including but not limited to, any 

Quality Assurance or Quality Control data, in calculating the monthly and 

annual PM, PM10, PM25, NOx, S02, CO and VOC emissions; 

4) A list of any emissions units modified or added to the installation during 

the preceding three-month period; 

5) The number, duration, and cause of any deviations or monitoring 

malfunctions, and any corrective action taken; 

6) A notification of shutdown of any monitoring system, whether the 

shutdown was permanent or temporary, the reason for the shutdown, the 

anticipated date that the monitoring system will be fully operational or 

replaced with another monitoring system, and whether the emissions unit 

monitored by the monitoring system continued to operate, and the 

calculations ofthe emissions. 

7) A signed statement by the responsible official certifying the truth, 

accuracy, and completeness of the information provided in the report. 

e. Quality Assurance/Quality Control: 

Following completion of the initial performance test reports, Ford Motor 

Company Louisville Assembly Plant shall maintain an operation and maintenance 

plan on site at all times. A table of contents of the plan shall be submitted to the 

permitting authority with sixty (60) days of receipt of the performance test reports 

required of Specific Condition S6.c. The plan should be detailed, specific to the 

Louisville Assembly Plant and include the following information: 

Page 19 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

1) A preventative maintenance program for avoidance of excess emissions 

which shall include all maintenance activities, with inspection schedule, 

repair actions, and replacements inventory. 

2) A range of operating conditions and outlet variables for normal operation. 

3) A summary of operating conditions and outlet variables for all control 

equipment that will be monitored for malfunction or breakdown and a 

description of the method of detecting and informing responsible 

personnel of any malfunction or breakdowns, including alarm systems, 

lights and other indicators. 

4) A description of the generic corrective procedures that will be taken in the 

event of a malfunction or breakdown in order to restore compliance with 

the applicable emission limitations and permit conditions (e.g. reducing of 

production rate). 

f. Capture and Control Equipment: 

The specified control device (e.g. thermal oxidizer, carbon adsorber, and /or 

fluidized bed carbon concentrator) must be in use at all times when a control 

efficiency is claimed for compliance with the VOC emissions limitation. When a 

control efficiency is claimed, the control device shall be operated in accordance 

with applicable specifications and with the temperature range determined in 

Specific Conditions S6. 

g. Thermal Oxidizer Requirements: 

1) The operating temperature shall be continuously monitored and recorded 

when a control efficiency is claimed for compliance with the VOC 

emissions limitation. The operating temperature of the thermal oxidizer 

shall be maintained on a rolling 3-hour average within 50 degrees 

Fahrenheit of the average temperature of the oxidizer recorded during the 

compliance test specified in Specific Condition S6. The acceptable 

temperature range may be reestablished by performing a new set of 

emission tests. The most recent sixty months of records shall be 

maintained on-site and shall be made immediately available upon request. 

2) An assessment of thermal oxidizer valve operation and leakage shall be 

conducted as part of the maintenance and inspection activities, at least 

annually. 

h. Carbon Adsorber and Fluidized Bed Concentrator Requirements: 

1) Ford Motor shall monitor the desorption gas inlet temperature on the 

Page 20 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

carbon adsorption and/or the SCR temperature on a fluidized bed 

concentrator unit with an appropriate monitoring device to ensure that the 

device is operating properly when a control efficiency is claimed for 

compliance with the VOC emissions limitation. 

2) For each carbon adsorption device and/or fluidized bed concentrator unit, 

the monitoring device required in 1) above shall be identified, the 

parameters that will be monitored (e.g. desorption temperature), the 

frequency that the unit is monitored, and the temperature range as 

determined in Specific Condition S6 for each control device. 

i. Capture Equipment Requirements: 

1) Ford Motor shall evaluate changes that involve em1sswns directed to 

emission control equipment where compliance with an applicable 

emission limit or standard is dependent upon the use ofthe control device 

subject to the change for potential impacts to emission control equipment 

capture efficiency. This evaluation shall include the following: 

1. An impact analysis of the change on the capture efficiency; 

11. A determination of the need for a new capture efficiency test based 

on the impact analysis; 

iii. A summary of the evaluation to be included in the Notification of 

Actual Construction as stated in Specific Condition S 1.c. 

2) Within 180 days of start up of new projects, Ford Motor shall develop a 

monitoring plan for each capture system (booth) that: 

1. Identifies the operating parameter(s) to be monitored to assure 

capture efficiency, 

ii. Explains why this parameter is appropriate for demonstrating 

ongoing compliance, 

iii. Identifies the specific monitoring procedures, and 

1v. Specifies the operating parameter value or range of values (or the 

procedures for establishing the values) that shall be maintained to 

demonstrate capture efficiency is being maintained. 

3) Ford Motor shall install and maintain, for any intermittently controllable 

work station, a system to monitor when bypass of the control device 

system occurs while the work station is in operation. 

4) Ford Motor shall maintain an operating and maintenance log for the 

capture and control systems (enclosures and thermal oxidizers) for a 

period of (60) sixty months which shall include the following: 

1. Incidents of malfunction, with impact on emissions, duration of 

Page 21 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

event, probable cause, and corrective actions; and 

11. Maintenance activities, with inspection schedule, repair actions, 

and replacement, etc. 

111. A written record of regular inspection schedule, the date and 

results of all inspections including any actions or maintenance 

activities that result from that inspection. 

J. Ford Motor LAP has the flexibility to change any of their control devices as long 

as Ford Motor can demonstrate to the District upon request that the new 

equipment has the same or better control efficiency as the current control devices. 

The requirement for the same or better control efficiency applies only to situations 

where compliance with an applicable emission limit or standards is dependent 

upon the use of a control device. 

S3. PAL Permit Requirements (Regulation 2.05, section 1 & Regulation 2.03) 

SCH 

a. The PAL shall be effective for ten years. The PAL term commences on the date 

of issuance of the PAL permit (245-09-C (R1)). The PAL shall also remain 

effective during the periods of review of Title V renewal applications regardless 

of the status of the application or permit shield. 

b. Reopening of the Construction Permit: 

1) The permitting authority may reopen this construction permit to 

accomplish the following actions: 

i. Revise to reflect an increase in the PAL as outlined in Specific 

Condition S3.k. 

11. Reduce the PAL to reflect newly applicable Federal and/or State 

requirements with compliance dates after the issuance of this 

construction permit. 

111. Reduce the PAL if the pennitting authority determines that a 

reduction is necessary to avoid causing or contributing to a 

National Ambient Air Quality Standard or Prevention of 

Significant Deterioration increment violation, or to an adverse 

impact on air quality. 

2) All reopening that increase the PAL level are required to be placed on 

public notice for at least a thirty (30) day period for submittal of public 

comment. 

c. Permit Application Submission Requirements: 

If the permittee chooses to renew this PAL, the permittee shall submit a complete 

application between six and eighteen months prior to the expiration of the PAL. 

This PAL shall not expire until a revised PAL permit is issued if a complete 

Page 22 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

application is received by Louisville Metro Air Pollution Control District within the 

time frame specified. 

d. PAL Renewal Requirements: 

1) A complete application shall consist of written documentation and/or 

calculations for the following item: 

1. A proposed PAL level; 

ii. A list of all emissions units with applicable Federal or State 

requirements; 

111. The potential emissions of all current equipment at the installation; 

IV. Identification ofthe baseline period; 

v. Baseline actual emissions; and 

VI. A compliance plan for the proposed PAL. 

2) The permitting authority will have the final authority to set the new plantwide emissions limitation based on the following guidelines: 

i. If the baseline actual emissions at the time of renewal are equal to 

or greater than eighty percent of the PAL, the PAL may be 

renewed at the same level. 

11. The PAL may not be set at a level that is greater than the potential 

to emit of the entire installation. 

111. The PAL shall be adjusted to account for any applicable State or 

Federal requirement with a compliance date that occurs during 

effective period ofthis PAL. 

IV. A PAL level higher than the current PAL level cannot be approved 

unless otherwise approved through Specific Condition S3.j. 

3) Any request to renew the PAL level is required to be placed on public 

notice for at least a thirty (30) day period for submittal of public comment. 

e. A complete application shall consist of a proposed allowable emission limitation 

for each emissions unit (or each group of emissions units) by distributing the PAL 

allowable emissions for the installation among each of the emissions units that 

existed under the PAL. If the PAL had not yet been adjusted for an applicable 

requirement that became effective during the PAL effective period, such 

distribution shall be made as if the PAL had been adjusted. 

f. The PAL limits for each regulated pollutant will remain in effect until a revised 

permit is issued by the Air Pollution Control District. 

g. Any physical change or change in the method of operation at the installation that 

meets the definition of major modification will be subject to major construction 

permitting requirements. 

Page 23 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

h. Ford Motor Company Louisville Assembly Plant shall continue to comply with 

any State or Federal applicable requirements that may have applied either during 

the PAL effective period or prior to the PAL effective period. 

i. Any physical change in or change in the method of operation of a major stationary 

source that maintains its total source-wide emissions below the PAL level: 

1. Is not a major modification for the PAL pollutant; 

ii. Does not have to be approved through the PSD program; and 

iii. Is not subject to the provisions addressing restrictions on relaxing 

enforceable emission limitations that the major stationary source used to 

avoid applicability of the major NSR program. 

J. Increase of the PAL during the Effective Period: 

1) If Ford Motor Company Louisville Assembly Plant wishes to alter this 

construction permit to allow the installation to emit more than the limit of 

any one of the regulated pollutants, Ford Motor shall submit a complete 

application to request an increase in the PAL meeting all the requirements 

for a major modification. 

2) A complete application shall consist of written documentation and/or 

calculations to accomplish the follow items: 

1. Identify the emissions units contributing to the increase in 

emissions so as to cause Ford Motor emissions to equal or exceed 

the PAL. 

ii. Determine the Best Available Control Technology (BACT) 

equivalent controls for each emission unit using current 

technology. 

iii. Demonstrate that the sum of the baseline actual emissions of the 

small emissions units, plus the sum of the baseline actual 

emissions of the new or modified emissions units exceeds the 

PAL. 

IV. Comply with the provisions of a current BACT analysis for all 

emissions unit(s) identified in Specific Condition S3.j.(2)i. 

3) The revised PAL level shall be placed on public notice for at least thirty 

(30) day period for submittal of public comment. 

k. Operational Requirements from Previous Construction Permits: (See Comment 3) 

1) Upon request by the Air Pollution Control District, Ford Motor Company 

Louisville Assembly Plant shall supply to the Air Pollution Control 

District a drawing showing rooftop locations of current process exhaust 

Page 24 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

stacks. 

Plant ID: 0072 

2) Each stack must be identified by the associated source operation name and 

a short code that Ford chooses. 

3) There must be a unique code for all stacks associated with each new 

emission unit. 

S4. PAL Compliance Demonstration (Regulation 2.05, section 1 & Regulation 2.03) 

SCH 

The owner or operator shall maintain records and emission calculations as described 

below to demonstrate compliance with the PAL. Further, compliance with all other 

permit conditions and applicable regulations identified within this permit shall be 

demonstrated using the methods prescribed for each Emission Unit and for each Emission 

Point. 

a. Emissions calculations to demonstrate compliance with the PAL include VOC, 

PM/PM10/PM2.s, CO, S02 and NOx emissions from startups, shutdowns, and 

malfunctions. 

b. The permittee shall determine monthly VOC, PMIPM10/PM2.5, CO, S02 and NOx 

emissions in accordance with the Monitoring and Record Keeping Requirements 

for each emissions unit for the purpose of summing plant-wide VOC, 

PM/PM10/PM2.

5, CO, S02 and NOx emissions and determining the rolling, 12-

month emissions for each pollutant. 

c. Compliance with applicable emission rates for the e-coat, guidecoat and topcoat 

systems can be demonstrated based upon the recordkeeping and emissions 

calculation methods described in "Protocol for Determining Daily Volatile 

Organic Compound Emission Rate of Automobile and Light-Duty Truck Topcoat 

Operations," EPA-450/3-88-018 (Docket ID No. OAR-2002-0093 and Docket 

ID No. A-2001-22). The same information can be utilized to determine monthly 

emission rates for support of PAL compliance. 

d. Compliance with annual emission rates for sealer, black-out/wax, glass 

installation and purge/cleaning solvent operations, and all other VOC emission 

units, shall be demonstrated using mass balance calculation methods. Monthly 

material usage data and the applicable VOC content of each material shall be 

maintained. 

e. Compliance with mass VOC emission limitations for sealer, black-out/wax, glass 

installation and purge/cleaning solvent operations, shall be demonstrated using 

mass balance calculation methods. Monthly material usage data and the 

applicable VOC content of each material shall be kept. Daily emission rates shall 

be determined by prorating monthly usage based on daily production levels. 

Page 25 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

n 

VOC Value= S Ui V; (1- Ci D;) 

i=l 

Where: 

U = material usage 

V = VOC content 

C = capture efficiency 

D = destruction efficiency 

i = number of operating days 

The owner or operator shall correct capture and destruction efficiency values as 

appropriate to reflect equipment malfunction, downtime or other periods of 

reduced performance. Daily usage of each material shall be prorated from 

monthly values based on daily production: 

= U PDaily 

UDai/y Monthly P 

Monthly 

Where: 

Unaily = material usage for a particular calendar day 

UMonthly = recorded material usage for a particular month 

Pnaily = recorded vehicle production for a particular day 

PMonthly = total vehicle production for a particular month 

For these operations, the VOC content of each material used shall be determined 

using U.S. EPA Reference Method 24, manufacturer's formulation data, or an 

approved alternative method. 

f. To demonstrate compliance with the PAL emission limits, the permittee may use 

either of the following: 

VOC Emission Rate Annual Emission Calculation (tons VOC/year) (12 month 

rolling time period) 

Page 26 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

VOC Emission Rate Annual Emission Calculation (tons VOC/year) (12 month 

rolling time period) 

The owner or operator shall update and correct capture and destruction efficiency 

values as appropriate to reflect equipment malfunction, downtime, or other 

periods of reduced performance. 

g. To demonstrate compliance with plant-wide NOx emission limits and to determine 

PM; PM10 and PM25 emissions associated with natural gas combustion, the owner 

or operator shall maintain monthly plant-wide natural gas usage records. 

Emissions shall be determined using prorated usage rates and appropriate U.S. 

EPA AP-42 Emission Factors or vendor emissions data. 

n 

NOx I PMaValue = LViEF(l-Ci) 

i~l 

Where: 

a= PM subscript for total PM, PM10, or PM2.

5 

U = material usage 

EF = emission factor 

C = control efficiency 

i = number of operating months 

h. To demonstrate compliance with annual plant-wide PMIPM10/PM25 emissions 

associated with surface coating operations, the owner or operator shall maintain 

monthly plant-wide coating usage records. Emissions shall be determined using 

materials usage rates, solids content, transfer efficiency and particulate control 

device efficiency, or some combination of these parameters. As an alternative, 

the facility may rely on stack test data* or design criteria if such data is available 

and can provide a more process-specific emission estimation technique. 

*Stack test results used for PM2.s shall not include condensable particulate matter 

as specified in 40 CPR Part 51.166 as the permit is issued prior to January 1, 

2011. 

1. The permittee shall complete the calculations specified in S4.a. through h. no later 

than 30 days after the end of the month for which emissions are being calculated. 

The permittee shall report to the Air Pollution Control District, 850 Barret Ave, 

Louisville, KY 40204, no later than ten (1 0) days after the calculations are 

complete for the month during which the records indicate that the source exceeds 

the limitations of the PAL. 

Page 27 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

J. The permittee shall keep documentation of any em1sswn factors used to 

demonstrate compliance with the PAL. Emission factors must be obtained from 

the most recent edition of AP-42, Compilation of Air Pollutant Emission Factors, 

the most recent stack performance test results, a mass balance approach using the 

Material Safety Data Sheets (MSDS) of all materials, and/or by a method 

approved by the permitting authority. 

k. The permittee shall keep documentation of any overall control efficiencies used to 

demonstrate compliance with the PAL. Overall control efficiency is the product of 

the capture efficiency and control efficiency of the pollution control device. 

1. Operational Requirement: 

The permittee shall keep the solvents and cleaning solutions in sealed containers 

whenever the materials are not in use. The permittee shall provide and maintain 

suitable easily read permanent markings on all solvent and cleaning solution 

containers used with this equipment. 

SS. PAL Reporting Requirements (Regulation 2.05, section 1 & Regulation 2.03) 

SCH 

The owner or operator shall submit a summary of required monitoring reports at least 

once every three months, unless more frequent reporting is required by an applicable 

requirement. 

a. Quarterly report: 

The reporting period shall be January 1st through March 31, April I through June 

30th, July 1st through September 30 and October 1 through December 31st of each 

calendar year. All reports shall be postmarked by the 60th day following the end 

of each reporting period. 

1. The identification of owner and operator, the facility ID, and the permit toConstruct numbers or any applicable permit-to-install. 

ii. Total annual emissions (tons per year) based on a twelve-month rolling 

total for each month in the reporting period. 

111. A summary of the data relied upon, including, but not limited to, any 

quality assurance or quality control data, in calculating the monthly and 

annual PAL pollutant emissions. A copy of the data relied upon shall be 

maintained on site for a minimum period of three years. 

lV. A list of any emissions units modified or added to the major stationary 

source during the preceding six-month period (including exempt and 

insignificant sources). 

v. The number, duration, and cause of any deviations or monitoring 

malfunctions (other than the time associated with zero and span calibration 

checks), and any corrective action taken. 

Page 28 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

VI. A notification of a shutdown of any monitoring system, whether the 

shutdown was permanent or temporary, the reason for the shutdown, the 

anticipated date that the monitoring system will be fully operational or 

replaced with another monitoring system, and whether the emissions unit 

monitored by the monitoring system continued to operate, and the 

calculation of the emissions of the monitored pollutant or the number 

determined by method included in the PAL permit 

vii. A signed statement by the responsible official certifying the truth, 

accuracy, and completeness of the information provided in the report. 

b. Deviation report: 

The major stationary source owner or operator shall promptly submit reports of 

any deviation from or exceedance of the PAL requirements, including periods 

where no monitoring is available. The deviation reports shall be submitted within 

the time limits prescribed by Regulation 1.06. The reports shall contain the 

following information: 

i. The identification of owner and operator, the facility ID, and the permit 

numbers for any applicable permits; 

ii. The PAL requirement that experienced the deviation or the exceedance; 

111. Emissions resulting from the deviation or the exceedance; and 

lV. A signed statement by the responsible official certifying the truth, 

accuracy, and completeness of the information provided in the report. 

c. Re-validation results: 

The owner or operator shall submit to the Louisville Metro Air Pollution Control 

District the results of any re-validation test or method within three months after 

completion of such test or method. 

S6. PAL Performance Testing (Regulation 2.05, section 1 & Regulation 2.03) 

SCH 

a. Ford Motor shall conduct performance tests on existing control devices in the 

following table and any future control devices used for compliance with the PAL 

in accordance with the schedule identified in item c. below. 

Control Device 

Thermal Oxidizer 

Location Description 

E-Coat Oven RTO 

E-Coat Oven (3rd Pass) RTO 

E-Coat Oven (1st and 2nd Pass) 

Guidecoat Oven (1st and 2nd Pass) 

Guidecoat Oven (3rd Pass) 

North Main Enamel Oven RTO 

North Main Enamel Booth RTO 

Page 29 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

Carbon Adsorber 

South Main Enamel Booth RTO 

South Main Enamel Oven RTO 

North Main Enamel Booth 

South Main Enamel Booth 

Ford Motor shall determine the VOC destruction and /or removal efficiencies and 

operating parameters of these control devices when all the processed controlled 

by these devices are in normal operation. 

b. For each capture system, Ford Motor shall: 

1) Confirm that the capture system continues to meet the requirements of 

EPA Method 204 from an approved performance test with no changes to 

operating parameters, or 

2) Conduct a performance test to determine the capture efficiency and 

establish the value or range of values for the selected operating 

parameter(s) when all the processes controlled by these devices are in 

normal operation. 

c. Within the initial 1 0-year term of the PAL permit and at least within 10 years of 

the most recent performance tests, Ford Motor Company Louisville Assembly 

Plant shall: 

1) Conduct performance tests to verify the operating parameters and/or 

control efficiencies ofthe control devices; and 

2) Confirm the capture efficiencies of the total or partial enclosures by 

Specific Condition S6.b.l) or S6.b.2). 

3) The emission testing requirements are designed to obtain representative 

emission testing. However, it is recognized that circumstances or other 

reasons may arise that would necessitate changes to the testing 

requirements. Therefore, upon mutual agreement between the permittee 

and the District, the testing requirements specified in this permit may be 

changed. 

For any control device installed subsequent to the issuance of this construction 

permit, performance tests shall be preformed no later than 180 days after initial 

start-up ofthe control equipment. 

d. Testing shall be conducted in accordance with the procedures outlined in Specific 

Condition S6.e. Ford Motor shall maintain a record of the results of all 

performance tests required by Specific Condition S6.a. and S6.b. 

Page 30 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

e. Proposed Test Plan: 

1) A completed Proposed Test Plan must be submitted to the Air Pollution 

Control District, within thirty (30) days prior to the proposed test date so 

that the District may arrange a pretest meeting, if necessary, and assure 

that the test date is acceptable for an observer to be present. The Proposed 

Test Plan may serve the purpose of notification and must be approved 

prior to conducting the required emission testing. 

2) A copy of a written report of the performance test results shall be 

submitted to the District within thirty (30) days of completion of any 

required testing, unless an extension is requested and approved by the 

District. The extension must be submitted in writing at least ten days prior 

to the thirty (30) day deadline. The report must include legible copies of 

raw data sheets, analytical instrument laboratory data and complete sample 

calculations from the required U.S. EPA Method for at least one sample 

run. 

3) The test report is to fully account for all operational and emission 

parameters addressed both in the construction permit conditions as well as 

in any other applicable state or federal rules or regulations. 

Plant-wide Applicability Limits Comments 

1. The Plant-wide Applicability Limit(s) (PAL) are set at levels equal to the baseline 

determination submitted by Ford Motor Company February 2, 2009 and historical actual 

emission levels. 

2. The PAL permit provisions (under Regulation 2.05 Prevention of Significant 

Deterioration of Air Quality) have been adopted by the Louisville Metro Air Pollution 

Control District (LMAPCD). "Baseline actual emissions" as of a particular date are 

generally defined as "rate of emissions, in tons per year, of a regulated NSR pollutant, 

that the unit actually emitted during any consecutive twenty-four (24) month period 

selected by the owner or operator within the ten (1 0) year period beginning on or after 

November 15, 1990, and immediately preceding the earlier of the date the owner or 

operator begins actual construction of the project or the date a complete permit 

application is received by the agency". 

3. This action will allow department personnel to identify which source is not meeting 

regulatory requirements, if the situation occurs. 

SCH Page 31 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Louisville Assembly Plant, Ford Motor Company Maximum Achievable Control 

Technology (MACT) Requirements: 

40 CFR 63 Subpart IIII- Surface Coating of Automobiles and Light Duty Trucks 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

HAPs 

a. The permittee shall choose to comply with one of the following HAPs limits: 

1. 0.60 lbs HAPs/GACS on a calendar month basis: E-Coat, guidecoat, 

topcoat, glass bonding primer, and glass bonding adhesive operations plus 

all coatings and thinners, except for deadener materials and for adhesive 

and sealer materials that are not components of glass bonding systems, 

used in coating operations in the paint shop. (40 CPR 63.3091(a)) 

ii. 1.10 lbs HAPs/GACS on a calendar month basis: guidecoat, topcoat, 

glass bonding primer, and glass bonding adhesive operations plus all 

coatings and thinners, except for deadener materials and for adhesive and 

sealer materials that are not components of glass bonding systems, used in 

coating operations in the paint shop. (40 CPR 63.3091(b)) 

The permittee may choose to comply with the emission limit specified by 

S 1. b. only if E-Coat meets either of the following requirements. ( 40 CPR 

63.3092) 

a. Each individual material added to E-Coat contains no more than 

1.0 percent by weight of any organic HAP and no more than 0.10 

percent by weight of any OSHA-defined carcinogenic organic 

HAP; or, 

b. The emissions from all E-Coat bake ovens are captured and ducted 

to the oven thermal oxidizer which achieves a minimum 

destruction efficiency of at least 95 percent (by weight). 

iii. 0.01 lbs HAPs per lb of coating on a calendar month basis for sealers, 

deadeners and adhesive materials that are not components of glass 

bonding systems. 

b. The permittee shall develop and implement a work practice plan to minimize the 

organic HAP emissions from the storage, mixing and conveying of coatings, 

thinners, and cleaning materials used in, and waste materials generated by, all 

coating operations for which an emission limit has been established above. The 

work practice plan must specify practices and procedures to ensure that, at a 

minimum, the following elements are implemented consistent with the 

Page 32 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

requirements of 40 CPR 63.3094. The permittee shall comply with the applicable 

work practice plans at all times. ( 40 CPR 63.3094) 

i. All organic-HAP-containing coatings, thinners, cleaning materials, and 

waste materials must be stored in closed containers. 

n. Spills of organic-HAP containing coatings, thinners, cleaning materials, 

and waste materials must be minimized. 

iii. Organic-HAP-containing coatings, thinners, cleaning materials, and waste 

materials must be conveyed from one location to another in closed 

containers or pipes. 

IV. Mixing vessels, other than day tanks equipped with continuous agitation 

systems, which contain organic-HAP-containing coatings and other 

materials must be closed except when adding to, removing, or mixing the 

contents. 

v. Emissions of organic HAP must be minimized during cleaning of storage, 

mixing, and conveying equipment. 

vi. Organic HAP emissions from cleaning and from purging of equipment 

associated with all coating operations subject to emission limits in Sl.a 

and Sl.b. above must be minimized by addressing: 

1) Vehicle body wipe pursuant to 40 CPR 63 .3094( c )(1 )(i); 

2) Coating line purging pursuant to 40 CPR 63.3094(c)(1)(ii); 

3) Coating system flushing pursuant to 40 CPR 63.3094(c)(l)(iii); 

4) Cleaning of spray booth grates pursuant to 40 CPR 

63 .3094( c )(1 )(iv); 

5) Cleaning of spray booth walls pursuant to 40 CPR 

63.3094( c )(1)(v); 

6) Cleaning of spray booth equipment pursuant to 40 CPR 

63.3094(c )(1)(vi); 

7) Cleaning of external spray booth areas pursuant to 40 CPR 

63.3094( c)(1)(vii); 

8) Additional housekeeping measures pursuant to 40 CPR 

63 .3094( c )(1 )(viii). 

The permittee may choose to comply with an alternative to the work 

practice standard, after receiving prior approval from the US EPA in 

accordance with 40 CPR 63.6(g). (40 CFR 63.3100(c), 40 CPR 

63.4493(b), and (c)), (40 CFR 63.094(d)) 

c. Revisions to the work practice plan likewise do not represent revisions to the 

facility's Renewable Operating Permit. Copies of the current work practice plan 

and any earlier plan developed within the past five years are required to be made 

available for inspection and copying by the LMAPCD upon request. ( 40 CPR 

63.3094)(e)(f)) 

d. For any coating operation(s) for which HAP emission reductions due to the use of 

add-on control equipment are relied upon to demonstrate compliance with the 

Page 33 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

emission limits above, the permittee shall meet the operating limits specified in 

Table 1 of 40 CFR 63 Subpart IIII as identified below. The operating limits in 

Table 1 apply to the emission capture and add-on control systems on the coating 

operations. The permittee must establish the operating limits during the 

performance test according to the requirements in 40 CFR 63.3167. The 

operating limits shall be met at all times after they are established, except for 

periods of startup, shutdown and malfunction. (40 CFR 63.3093, 40 CFR 

63.3100(b), (d) and Table 1) 

Add-On Control Operating Limit Device 

The average combustion temperature in any 3-hour 

Thermal Oxidizer period must not fall below the combustion temperature 

limit established according to 40 CFR 63.3167(a). 

Concentrators, The average desorption gas inlet temperature in any 3- Including Zeolite 

Wheels and Rotary hour period must not fall below the limit established 

Carbon Adsorbers according to 40 CFR 63.3167(e). 

S2. Monitoring (Regulation 2.16, section 4.1.1) 

SCH 

a. For any coating operation(s) for which HAP emission reductions due to the use of 

add-on control equipment are relied upon to demonstrate compliance with the 

emission limits above, the permittee shall develop and implement a written 

startup, shutdown and malfunction plan (SSMP) in accordance with 40 CFR 

63.6(e)(3) and submit to the District. This plan must address the startup, 

shutdown and corrective actions in the event of a malfunction of any emission 

capture system or add-on control device upon which compliance with any of the 

emission limits above depends. The SSMP must also address any coating 

operation equipment that may cause increased emissions or that would affect 

capture efficiency if the process equipment malfunctions, such as conveyors that 

move parts among enclosures. (40 CFR 63.3100(±)) 

b. For any coating operation(s) for which HAP emission reductions due to the use of 

add-on control equipment are relied upon to demonstrate compliance with the 

emission limits above, the permittee shall operate and maintain all affected 

emission units including any emission capture system or add-on control device 

upon which compliance with any of the emission limits above. At all times, 

including periods of startup, shutdown, and malfunction, the owner or operator 

must operate and maintain any affected source, including associated air pollution 

control equipment and monitoring equipment, in a manner consistent with safety 

and good air pollution control practices for minimizing emissions. During a 

period of startup, shutdown, or malfunction, this general duty to minimize 

emissions requires that the owner or operator reduce emissions from the affected 

source to the greatest extent which is consistent with safety and good air pollution 

control practices. The general duty to minimize emissions during a period of 

Page 34 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

startup, shutdown, or malfunction does not require the owner or operator to 

achieve emission levels that would be required by the applicable standard at other 

times if this is not consistent with safety and good air pollution control practices, 

nor does it require the owner or operator to make any further efforts to reduce 

emissions if levels required by the applicable standard have been achieved. 

Determination of whether such operation and maintenance procedures are being 

used will be based on information available to the Administrator which may 

include, but is not limited to, monitoring results, review of operation and 

maintenance procedures, review of operation and ·maintenance records, and 

inspection ofthe source. (40 CFR 63.3100(d)) 

c. For any coating operation(s) for which HAP emission reductions due to the use of 

add-on control equipment are relied upon to demonstrate compliance with the 

emission limits above, the permittee shall maintain a log detailing the operation 

and maintenance of any emission capture system, add-on control device, or 

continuous parameter monitor upon which compliance with any of the emission 

limits above depends. The log shall cover the period between the compliance date 

specified in 40 CFR 63.3083 and the date when the initial emission capture 

system and add-on control device performance tests have been completed, as 

specified in 40 CFR 63.3160. (40 CFR 63.3100(e)) 

S3. Record keeping (Regulation 2.16, section 4.1.1) 

SCH 

Records required in this section shall be maintained on file for a period of five years. ( 40 

CFR 63.3131) The permittee shall maintain, at a minimum, the following records as of 

the applicable compliance date: 

a. A copy of each notification and report that is submitted to comply with 40 CFR 

Part 63, Subpart IIII and the documentation supporting each notification and 

report as specified in 40 CFR 63.3130(a). (40 CFR 63.3130(a)). 

b. A current copy of information provided by materials suppliers or manufacturers, 

such as manufacturer's formulation data, or test data used to determine the mass 

fraction of organic HAP for each coating, thinner and cleaning material, the 

density for each coating and thinner, and the volume fraction of coating solids for 

each coating. (40 CFR 63.3130(b)). 

c. Monthly records of the following: 

i. For each coating or thinner used in E-Coat, guidecoat, topcoat, glass 

bonding primer, and glass bonding adhesive operations plus all coatings 

and thinners, the volume used in each month, the mass fraction organic 

HAP content, the density, and the volume fraction of solids. ( 40 CFR 

63.3130(c)(1)) 

Page 35 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

ii. For each deadener material, and NOB Sealers and Adhesives used, the 

mass used in each month and the mass organic HAP content. ( 40 CFR 

63.3130(c)(3)) 

111. Calculations of the organic HAP emission rate for E-Coat, guidecoat, and 

topcoat in pounds per gallon of applied coating solids. If permittee 

chooses to comply with the option identified in l.ii, a record of the weight 

fraction of each organic HAP in each material added to E-Coat. These 

calculations and records must include raw data, algorithms, and 

intermediate calculations. If the "Protocol for Determining Daily Volatile 

Organic Compound Emission Rate of Automobile and Light-Duty Truck 

Topcoat Operations," EPA-450/3-88-018 (Docket ID No. OAR-2002 

0093 and Docket ID No. A-2001-22), is used, all data input to this 

protocol must be recorded. If these data are maintained as electronic files, 

the electronic files, as well as any paper copies must be maintained. ( 40 

CPR 63.3130(c)(4), 40 CFR 63.3163,40 CFR 63.3173) 

iv. Calculation of the average monthly mass organic HAP content in pounds 

per pound of coating, separately for deadener materials and NOB Sealers 

and Adhesives. (40 CFR 63.3130(c)(5), 40 CFR 63.3152) 

v. The name, volume, mass fraction organic HAP content and density of 

each cleaning material used. (40 CFR 63.3130(6)(d)- (f)) 

d. Any additional records pertaining to deviations; startup, shutdown or 

malfunctions; emission capture systems; performance testing; capture and control 

efficiency determinations; transfer efficiency determinations; and work practice 

plans for any emission capture system or add-on control device upon which 

compliance with any of the emission limits in I.1 through 4 depends, pursuant to 

40 CFR 63.3130(g) through (n). (40 CFR 63.3130(6)(g)- (n)) 

i. Records pertaining to the design and operation of control and monitoring 

systems for any emission capture system or add-on control device upon 

which compliance with any of the emission limits in SC I.1 through 4 

depends must be maintained on-site for the life of the equipment in a 

location readily available to plant operators and inspectors. ( 40 CFR 

63.3130(o)(6)) 

ii. The permittee shall compile all required records and complete all required 

calculations in a format acceptable to the Louisville Metro Air Pollution 

Control District and make them available by the end of the calendar month 

following each compliance period unless otherwise specified in any 

monitoring/recordkeeping condition. 

iii. The permittee may rely upon the results of capture, destruction or transfer 

efficiency tests that have been previously conducted upon written approval 

from the District. Any such previous tests must meet the criteria identified 

in 40 CFR 63.3160(c)(1) through (3). (40 CFR 63.3160) 

iv. The permittee shall install, operate and maintain each continuous 

parametric monitoring system in accordance with the applicable 

provisions of 40 CFR 63.3168. (40 CFR 63.3168) 

Page 36 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

v. The permittee shall demonstrate continuous compliance with the operating 

limits specified in Table 1 to Subpart IIII of Part 63 for any emission 

capture system or add-on control device upon which compliance with any 

of the emission limits in the above table depends, pursuant to 40 CFR 

63.3163 and 40 CFR 63.3173 using the method( s) described below: ( 40 

CFR 63.3163, 40 CFR 63.3173 and Table 1) 

Add-On Control Operating Limit: Continuous Compliance 

Device: Demonstration Method 

a. Collect the combustion 

The average combustion temperature data according 

temperature in any 3- to 40 CFR 63.3168(c); 

hour period must not fall b. Reduce the data to 3-hour 

Thermal Oxidizer below the combustion block averages; and 

temperature limit c. Maintain the 3-hour 

established according to average combustion 

40 CFR 63.3167(a). temperature at or above 

temperature limit. 

a. Collect the temperature 

Concentrators, The average desorption data according to 40 CFR 

Including Zeolite gas inlet temperature in 63 .3168(f); 

Wheels and any 3-hour period must b. Reduce the data to 3-hour 

Rotary Carbon not fall below the limit block averages; and 

Adsorbers established according to c. Maintain the 3-hour 

40 CFR 63.3167(e). average temperature at or 

above the temperature limit. 

IX. For any coating operation(s) for which HAP emission reductions due to 

the use of add-on control equipment are relied upon to demonstrate 

compliance with the emission limits above, the permittee shall monitor or 

secure the valve or closure mechanism controlling each bypass line for 

each capture system upon which compliance with any of the emission 

limits in the table above depends in a non-bypass mode such that the valve 

or closure mechanism cannot be opened without creating a record that it 

was opened. The method used to monitor or secure the valve or closure 

mechanism must meet one of the following: (40 CFR 63.3168(b)(1)) 

1. Flow control position indicator requirements pursuant to 40 CFR 

63 .3168(b )(1 )(i); 

2. Car-seal or lock-and-key valve closures requirements pursuant to 

40 CFR 63.3168(b)(1)(ii); 

3. Valve closure monitoring requirements pursuant to 40 CFR 

63.3168(b )(I )(iii); 

Page 37 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

4. 

Plant ID: 0072 

Automatic shutdown system requirements pursuant to 40 CFR 

63.3168(b )(1)(iv). 

If any bypass line is opened, a description of why the line was opened and 

the length of time it remained open must be included in the semi-annual 

compliance reports required in 40 CFR 63 .3168(b) 

S4. Reporting (Regulation 2.16, section 4.1.1) 

a. The permittee shall submit applicable notifications specified in 40 CFR 63;7(b) 

and (c), 63.8(±)(4) and 63.9(b) through (e) and (h), as specified in 40 CFR 

63.3110. (40 CFR Part 63, Subparts A and IIII) 

b. For any emission capture system or add-on control device upon which compliance 

with any of the emission limits in the above table depends, for which a startup, 

shutdown, or malfunction occurs during the quarterly reporting period, the 

permittee shall submit a SSMP report as specified in 40 CFR 63.3120(c). (40 

CFR 63. 3120(c), 40 CFR 63.10(d)) 

S5. Testing (Regulation 2.16, section 4.1.1) 

SCH 

a. The permittee shall perform the applicable performance tests and compliance 

demonstrations in accordance with 40 CFR 63.3150-3152,40 CFR 63.3160-3161, 

40 CFR 63.3163-3168, 40 CFR 63.3170-3171, and 40 CFR 63.3173. (40 CFR 

Part 63, Subpart IIII) 

b. The permittee shall determine the mass fraction of each organic HAP for each 

material used according to the procedures established under 40 CFR 

63.3151(a)(l) through (5). The permittee may use US EPA Method ALT-017 as 

an alternative for any material used, after demonstrating that its use as an 

alternative test methodology for that material, has been approved by the US EPA 

pursuant to the requirements of 40 CFR 63.3151(a)(3) and 40 CFR 63.7. (40 CFR 

63.7, 40 CFR 63.3151) 

c. For any emission capture system or add-on control device upon which compliance 

with any of the emission limits in the above table depends, the permittee shall 

submit all performance test reports for emission capture systems and add-on 

control devices, and reports of transfer efficiency tests as required by 40 CFR 

63.3120(b). (40 CFR 63.3120(b)) 

Page 38 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

40 CFR 63 Subpart EEEE- Organic Liquids Distribution Operations (OLD) 

In the event that the permittee changes the materials in an existing affected storage tank that 

contains an organic liquid is equal to or greater than 5,000 gallons in such a way that the annual 

average true vapor pressure of the total organic hazardous air pollutant is above 4.0 psia, the 

permittee shall be subject to additional requirements pursuant to 40 CFR Part 63 Subpart EEEE 

and shall ensure compliance with those requirements. (40 CFR 63.2346) 

a. For each existing affected storage tank that contains an organic liquid with a capacity of 

less than 5,000 gallons, records must be kept of the identity of the tank and the capacity 

of the tank (in gallons). Affected tanks are those tanks that contain organic liquid with a 

HAP content of 5 percent or greater by weight, as defined under 40 CFR §63 .2406 and 

Table 1 of 40 CFR Part 63 Subpart EEEE. 63.2343(a) 

b. For each existing affected storage tank that contains an organic liquid with a capacity of 

more than 5,000 gallons and contains an organic liquid with a HAP content of 5 percent 

or greater by weight, the following records must be kept: 

i. The identity of the tank and the capacity of the tank (in gallons), 

11. The tank contents 

iii. The annual average true vapor pressure of the total organic hazardous air pollutant 

in the organic liquid (as defined under 40 CFR §63.2406 and Table 1 of 40 CFR 

Part 63 Subpart EEEE). (40 CFR 63.2343(b)) 

c. These records must be kept up-to-date and available for inspection. (40 CFR 63.2343) 

d. All compliance records, notifications and reports, and any updates to those records, shall 

be retained for five years with two years of records on site. (40 CFR 63.2394(b) and (c)) 

OLD MACT Reporting Requirements 

a. For each existing affected storage tank that has a capacity of more than 5,000 gallons, the 

permittee must submit an Initial Compliance Report that contains the following 

information (40 CFR 63.2343(b) and 63.2386): 

SCH 

1. Company name and address. 

11. Statement by a responsible official, including the official's name, title and 

signature, certifying that, based on information and belief formed after reasonable 

inquiry, the statements and information in the report are true, accurate and 

complete. 

111. A listing of all existing affected storage tanks greater than 5,000 gallons that 

contain an organic liquid where the annual average true vapor pressure of the total 

organic hazardous air pollutant (as defined under Table 1 of 40 CFR Part 63 

Subpart EEEE) is below 4.0 psia. 

Page 39 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

b. The permittee must submit a subsequent Compliance Report if any of the following 

occurs (40 CFR 63.2343(b)(2)(i)): 

1. The permittee changes the materials in an existing affected storage tank that has a 

capacity equal to or greater than 5,000 gallons in such a way that the annual 

average true vapor pressure of the total organic hazardous air pollutant is above 

4.0 psia. 

ii. The permittee installs a new affected storage tank with a capacity equal to or 

greater than 5,000 gallons. 

111. There are changes to the information reported. 

c. Each subsequent Compliance Report shall be submitted with the next Title V semi-annual 

report. (40 CFR 63.2386(e)) 

40 CFR 63 Subpart ZZZZ- National Emissions Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines 

There are no applicable requirements or notification requirements under Subpart ZZZZ as all of 

the units are considered existing emergency generators less than 500 HP. 

An existing emergency stationary RICE does not have to meet the requirements of this subpart 

and subpart A of this part. No initial notification is necessary. (40 CFR 64.6590(b)(3) 

General Permit Reporting Requirements (Regulation 2.16, section 4.1.9.3) 

The owner or operator shall report quarterly the following: 

a. Emission Unit ID number and Control ID number; 

b. The beginning and ending date of the repmiing period; 

c. Identification of the operating parameters being monitored; 

d. Number, duration, and cause of all exceedances (or a negative declaration, if none); and 

e. Description of the corrective action taken for each exceedance. 

STAR Requirements: 

DISTRICT ONLY ENFORCEABLE REGULATIONS 

Regulation Title Applicable Sections 

5.01 General Provisions 1 through 4 

Methodology for Determining Benchmark 

5.20 Ambient Concentration of a Toxic Air 1 through 6 

Contaminant 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

SCH Page 40 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

DISTRICT ONLY ENFORCEABLE REGULATIONS 

Regulation Title Applicable Sections 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

a. The owner or operator shall submit with the notification of construction for any new 

emission unit the STAR EA Demonstration for all Category 1 through Category 4 TACs 

emitted from that emission unit. 

b. The owner or operator shall submit a plant-wide emissions-based EA Demonstration to 

the District showing compliance with the plant-wide EA goals of 7.5 new and existing, 

3.8 for all new combined, and 1 for each process when a change occurs that increases 

emissions above De minimus or previously modeled values. 

c. If the TAC does not have an established BAC or De minimus value, the owner or 

operator shall calculate and report these values. The following form may be used for 

determining BAC and De minimus values: 

SCH 

http://www.louisvilleky.gov/NR/rdonlyres/121AAADA-9838-4057-ADFC88CD95A1493 7 /0/BAC Worksheet. pdf 

Page 41 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U002- U004 Emission Unit Description: Five Boilers 

U002 - U004 Applicable Regulations: 

FEDERALLY ENFORCEABLE REGULATIONS 

Applicable 

Regulation Title Sections 

6.42 Reasonable Available Control Technology 1.2, and 2 

Requirements for Major Volatile Organic Compound through 5 

6.07 Standards of Performance for Existing Indirect Heat 1 through 4 Exchangers 

7.06 Standards of Performance for New Indirect Heat 1 through 5 Exchangers 

40 CFR 60 General Provisions 60.1 through 

Subpart A 60.18 

40 CFR 60 Standards ofPerformance for Small Industrial- 60.48c Subpart De Commercial-Institutional Steam Generating Units 

District Only Enforceable Regulations 

Regulation Title Applicable 

Sections 

Methodology for Determining Benchmark 

5.20 Ambient Concentration of a Toxic Air 1 through 6 

Contaminant 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

7.02 Federal New Source Performance Standards 1.23, 2 through 5 Incorporated by Reference 

SCH Page 42 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

U002 - U004 Emission Points: 

U002- U004 Equipment 

Emission Description Point 

One (1) powerhouse Wickes boiler; rated at 

E02A 146 MM Btu/hr; installed in 1954; natural 

gas-fired with propane backup. 

One (1) Cleaver-Brooks dock boiler (No. 1); 

E04A rated at 63.6 MM Btu/hr; installed in 1995; 

natural gas-fired with propane backup. 

One (1) Cleaver-Brooks boiler (No.2); 63.6 

E04B MM Btu/hr, installed 1995; natural gas-fired, 

with propane backup. 

E05 

Two (2) hot water boilers; 33.5 MM Btu/hr, 

installed 1996; natural gas-fired 

Plant ID: 0072 

Applicable Control 

Regulation ID 

6.07 

5.21 NA 

6.42 

7.06 

5.21 

N/A 

6.42 

40 CFR 60 Subpart De 

7.06 

5.21 

N/A 

6.42 

40 CFR 60 Subpart DC 

7.06 

5.21 N/A 

40 CFR 60 Subpart DC 

U002 - U004 Control Devices: There are no control devices associated with Emission 

Unit U002 - U004. 

SCH Page 43 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U002- U004 Specific Conditions 

S 1. · Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. PM 

1. For Emission Point E02A: 

The owner or operator shall not cause to be discharged into the 

atmosphere from that affected facility particulate matter in excess of 0.30 

pounds per million BTU actual total heat input. (Regulation 6.07, section 

4.1) (See Comment 1) 

ii. For Emission Points E04A, E04B and E05: 

The owner or operator shall not cause to be discharged into the 

atmosphere from that affected facility particulate matter in excess of 0.29 

pounds per million BTU actual total heat input. (Regulation 7.06, section 

4.1.4) (See Comment 1) 

iii. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL) 

b. Opacity 

1. For indirect heat exchangers subject to Regulation 6.07 and 7.06, the 

owner or operator shall not allow or cause the particulate emissions into 

the open air from any indirect heat exchanger which is greater than twenty 

percent (20%) opacity except for: 

11. For indirect heat exchangers with a heat input capacity of less than 250 

million BTU/hr, a maximum of 40% opacity shall be permissible for not 

more than two consecutive minutes in any 60 consecutive minutes; 

111. For indirect heat exchangers with heat input capacity of less than 250 

million BTU/hr, a maximum of 40% opacity shall be permissible for not 

more than six consecutive minutes in any 60 consecutive minutes during 

cleaning the fire box or blowing soot; or 

IV. For emissions from an indirect heat exchanger during building a new fire 

for the period required to bring the boiler up to operating conditions 

provided the method used is that recommended by the manufacturer and 

the time does not exceed the manufacturer's recommendations. 

(Regulation 7.06, section 4.2) 

Page 44 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

i. The owner or operator shall not cause to be discharged into the 

atmosphere from that affected facility any gases which contain sulfur 

dioxide in excess of 0.99 pounds per million BTU actual total heat input 

for combustion of liquid and gaseous fuels. (Regulation 7 .06, section 

5.1.1) (See Comment 1) 

ii. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit CP AL). 

d. NOx 

1. The owner or operator shall not allow or cause the plant-wide NOx 

emissions to exceed 99 tons during any consecutive 12-month period in 

order to stay below NOx RACT applicability thresholds. (Regulation 

6.42)(See Comment 6) 

11. For Emission Points E04A, E04B and E05: 

The owner or operator shall not allow or cause NOx emission to exceed 37 

tons per boiler during March 1 through October 31. 

iii. For Emission Point E02A: 

e. TAC 

No boiler shall have a monthly capacity factor greater than 10.0% for any 

month during the period March 1 to October 31. The term "monthly 

capacity factor" means the ratio between the actual heat input to a boiler 

from fuel combusted during a month and the potential heat input to a 

boiler form fuel combusted during a month and the potential heat input to 

the boiler had it been operated for 24 hours per day for the number of days 

in the month at the maximum steady state design heat input capacity. 

The owner or operator shall not allow any TAC emissiOns to exceed 

environmentally acceptable levels whether specifically established by modeling or 

derived from default de minimis levels. (Regulation 5.01, section 3.) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. PM 

For emission points E02A, E04A, E04B and E05, the owner or operator shall 

maintain records of monthly natural gas and/or other fuel usage. 

b. Opacity 

There are no monitoring requirements for Opacity compliance. (See Comment 2) 

Page 45 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

c. so2 

40 CPR 60 Subpart DC monitoring requirements for S02 compliance. (See 

Comment 1) 

1. The owner or operator shall keep records of the amount of fuel com busted 

during each month. (40 CFR 60.48c(g)(2)) 

ii. The owner or operator shall monthly calculate the prorated fuel usage of 

the boiler by correlating the design heat input capacity of all natural gas 

fired units at the plant if the individual fuel usage for each boiler is not 

known. (EPA Letter dated March 7, 2002) (See Comment 3) 

d. NOx 

Maintain records of monthly fuel usage, and use AP-42 emission factors and/or 

fuel analysis data, to calculate monthly emissions. 

e. TAC 

See Comment 4. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

a. PM 

See Specific Condition S2.a. 

b. Opacity 

There are no record keeping requirements for Opacity compliance. (See Comment 

2) 

See Specific Condition S2.c. 

d. NOx 

The owner or operator shall calculate and record the monthly and 12 consecutive 

month plant-wide NOx emissions for each month in the report period. 

e. TAC 

See Comment 4. 

S4. Reporting (Regulation 2.16, section 4.1.9.3) 

SCH Page 46 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

a. PM 

See PAL Reporting Requirements, there are no additional reporting requirements 

for demonstrating compliance with Regulation 6.07 and 7.06. 

b. Opacity 

There are no reporting requirements for Opacity compliance. (See Comment 2) 

See PAL Reporting Requirements, there are no additional reporting requirements 

for demonstrating compliance with Regulation 6.07 and 7.06. 

d. NOx 

See PAL Reporting Requirements. 

e. TAC 

See Comment 4. 

S5. Testing (Regulation 2.16, section 4.1.9.3) 

SCH 

a. PM 

There are no testing requirements for PM compliance. 

b. Opacity 

There are no testing requirements for Opacity compliance. 

There are no testing requirements for S02 compliance. 

d. NOx 

Within the initial10-year term of the PAL permit, the owner or operator shall test 

at least once to establish an emission factor for emission points E04A and E04B. 

e. TAC 

There are no testing requirements for TAC compliance. 

Page 47 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U002 - U004 Comments 

1. The District has performed a one-time PM and S02 compliance demonstration for the 

boiler, using AP-42 emission factors and combusting natural gas, and the emission 

standards cannot be exceeded. Therefore, there are no monitoring, record keeping, and 

reporting requirements for this boiler with respect to PM and S02 emission limits. 

2. The District has determined that using a natural gas fired boiler will inherently meet the 

20% opacity standard. Therefore, the company is not required to perform periodic 

monitoring to demonstrate compliance with the opacity standard. 

3. The federal regulation 40 CPR 63, Subpart DDDDD was vacated on June 8, 2007, 

therefore the District has not included the boiler MACT requirements in this permit. The 

company has submitted the Part 1 and Part 2 of the 112j permit application for the 

vacated boiler MACT (40 CPR 63 Subpart DDDDD), dated on March 5, 2009 and May 

8, 2009 respectively. The District is evaluating how to implement this requirement. 

4. The TAC emissions from the combustion of natural gas are considered to be "de minimis 

emissions" by the District. This includes all of the emissions from a process or process 

equipment for which the only emissions are the products of combustion of natural gas, 

such as from a natural gas-fired boiler or turbine, but does not include the other emissions 

from a process or process equipment that are not the products of the combustion of 

natural gas. (Regulation 5.01, section 1.6.7) 

5. In a letter dated March 7, 2002 from EPA Region 4, EPA has identified certain types of 

alternative record keeping requirements for units that are regulated under 40 CPR 60 

Subpart De (Standards of Performance for Small Industrial-Commercial-Institutional 

Steam Generating Units) that can be approved by the District without additional input 

from EPA. 

6. This PAL permit supercedes construction permit #623-94-C and the plant-wide NOx 

limit is replacing the 39.9 tpy PSD/NSR NOx avoidance limit for the two (2) CleaverBrooks boilers (E04A and E04B). 

7. Ford currently has a 146 MM Btu/hr boiler emission point E02A, however to keep 40 

CPR 60, Subpart Db from being applicable, Ford can only install additional boilers 

totaling less than 1 00 MM Btu/hr. 

SCH Page 48 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U008 Emission Unit Description: Volatile Organic Liquid Storage Tanks 

U008 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable 

Sections 

1.05 Compliance with Emission Standards and 1,2,3,4,5 Maintenance Requirements 

7.12 Standard of Performance for New Storage 1 though 5; 7 and 8 Vessels for Volatile Organic Compounds 

District Only Enforceable Regulations 

Regulation Title Applicable 

Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 66 

SCH Page 49 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

UOOS Emission Points: 

ID Description 

6000 gallon 

E08A Methanol Tank 

10,000 gallon UG 

E08G Solvent Tank 

E08M 

20,000 gallon AntiFreeze Tank 

20,000 gallon Power 

E08N Steering Fluid Tank 

6000 gallon Brake 

E080 Fluid Tank 

E08P 

20,000 gallon Diesel 

Fuel Tank 

Plant ID: 0072 

UOOS Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

5.21 

7.12 

Submerged Fill N/A 

5.21 N/A Vapor Pressure < 1.5 psi a 

7.12 

5.21 N/A Vapor Pressure< 1.5 psia 

7.12 

5.21 

7.12 

Vapor Pressure < 1.5 psia N/A 

5.21 

Vapor Pressure< 1.5 psia N/A 

7.12 

5.21 

Vapor Pressure< 1.5 psia N/A 

7.12 

UOOS Control Devices: There are no control devices associated with Emission Unit U008. 

SCH Page 50 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U008 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

a. VOC 

i. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

ii. The owner or operator shall not store materials with an as stored vapor 

pressure of greater than or equal to 1.5 psi a, however if the vapor pressure 

of the VOC, as stored, is equal to or greater than 1.5 psi, as a minimum, it 

shall be equipped with a permanent submerged fill pipe. (Regulation 7.12, 

section 3) 

b. TAC 

The owner or operator shall not allow any TAC emissiOns to exceed 

environmentally acceptable levels whether specifically established by modeling or 

derived from default de minimis levels. (Regulation 5.01, section 3.) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

a. VOC 

See Specific Condition S3 .a.i. 

b. TAC 

See Specific Condition S3.b. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

1. The owner or operator shall maintain records of the material stored in each 

storage vessel. If the contents of the storage vessels are changed, a record 

shall be made of the new contents, the new vapor pressure, and the date of 

the change in service. 

11. The owner or operator shall either maintain monthly records, including 

calculations, from either monthly usage records or ratioed annual 

emissions from the previous year that show the total VOC emissions 

during each calendar month and consecutive 12-month period for this 

emission unit. 

Page 51 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

b. TAC 

The owner or operator shall keep a record of the Material Safety Data Sheet 

(MSDS) for each TAC-containing material in this emission unit. 

S4. Reporting (Regulation 2.16, section 4.1.9 .3) 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

The owner or operator shall submit a plant-wide emissions-based EA 

Demonstration to the District showing compliance with the plant-wide EA goals 

of 7.5 new and existing, 3.8 for all new combined, and 1 for each process when a 

change occurs that increases emissions above De minimus or previously modeled 

values. 

UOOS Comment 

1. Emission points E08M, E08N and E08P are not subject to 40 CPR 60 subpart Kb because 

this subpart does not apply to storage vessels with a capacity greater than or equal to 151 

m

3 (39,890 gallons) storing a liquid with a maximum true vapor pressure less than 3.5 

kilopascals (kPa) (0.51 psi) or with a capacity greater than or equal to 75 m

3 (19,813 

gallons) but less than 151 m 3 (39,890 gallons) storing a liquid with a maximum true 

vapor pressure less than 15.0 kPa (2.18 psi). 

SCH Page 52 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Emission Unit U009: Glass Installation 

U009 Applicable Regulations : 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

Standards of Performance for New 

7.59 Miscellaneous Metal Parts and Products Surface 1 through 7 

Coating Operations 

40 CPR 63 General Provisions 60.1 through 60.18 Subpart A 

40 CPR 63 National Emission Standards for Hazardous Air 

Subpart IIII Pollutants: Surface Coating of Automobiles and 1,2,3,4, 7,and8 

Light-Duty Trucks 

District Only Enforceable Regulations 

Regulation Title Applicable Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.02 Adoption ofNational Emission Standards for 1, 3,4 and 5 Hazardous Air Pollutants 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

SCH Page 53 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

U009 Emission Points: 

ID Description 

Glass, 

E09A Windshield, and 

Back Lights 

Installation 

Plant ID: 0072 

U009 Emission Points 

Applicable Allowable Emission/ Control Stack 

Requirement Equipment Standard Device ID 

5.21 

3.5 lb/gal, less water and N/A S-400 

exempt VOCs, as applied 7.59 

U009 Control Devices: There are no control devices associated with Emission Unit U009. 

SCH Page 54 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U009 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

a. VOC 

1. The owner or operator shall not cause or allow the emission ofVOC from 

any affected facility resulting from the coating of metallic surfaces in 

excess of 0.42 kg of VOC/1 (3.5 lb VOC/gal) of coating, excluding water 

and exempt solvents, as applied for extreme performance coatings. 

(Regulation 7.59, section 3.1.3) 

ii. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

b. TAC 

The owner or operator shall not allow any TAC emtsswns to exceed 

environmentally acceptable levels whether specifically established by modeling or 

derived from default de minimis levels. (Regulation 5.01, section 3.) 

c. HAP 

See LAP MACT Standards Section. 

S2. Monitoring (Regulation 2.16, section 4.1.9.1) 

SCH 

a. VOC 

The owner or operator shall maintain the following monthly records to 

demonstrate ongoing compliance with the VOC content limit and with Regulation 

1.05, section 4: 

1. Calculations of VOC emissions from each facility based on the recorded 

parameters. Calculations of daily usage and VOC emissions from each 

facility based on the recorded parameters by prorating monthly net usage 

based on daily vehicle production. 

11. Determine daily usage of each material and VOC emissions by prorating 

monthly consumption based on daily vehicles produced. 

b. TAC 

See Specific Condition S3.b. 

c. HAP 

Page 55 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

See LAP MACT Monitoring Section. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

The owner or operator shall maintain the required records for a minimum of 5 years and 

make the records readily available to the District upon request. 

a. VOC 

1. An owner or operator of an affected facility subject to this regulation shall 

maintain records that include, but not be limited to, the following: 

(Regulation 7.59, section 6.1) 

1) The regulation and section number applicable to the affected 

facility for which the records are being maintained, 

2) The application method and substrate type (metal, plastic, etc.), 

3) The amount and type of coatings (including catalyst and reducer 

for multi component coatings) and solvent (including exempt 

compounds) used at each point of application during the averaging 

period. The District may specifically authorize the usage record to 

reflect a period longer than the compliance averaging period, with 

the usage prorated for each compliance averaging period by a 

method approved by the District. In this case, the usage record 

period shall not exceed 1 calendar month, 

4) The VOC content as applied in each coating and solvent, 

5) The date, or usage record period, for each application of coating 

and solvent, 

6) The amount of surface preparation, clean-up, wash-up of solvent 

(including exempt compounds) used and the VOC content of each 

material used during the averaging period. The District may 

specifically authorize the usage record to reflect a period longer 

than the compliance averaging period, with the usage prorated for 

each compliance averaging period by a method approved by the 

District. In this case, the usage record period shall not exceed 1 

calendar month. 

ii. The owner or operator shall maintain monthly records, including 

calculations, that show the total plant-wide VOC emissions during each 

calendar month and consecutive 12-month period. 

Page 56 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

111. The owner or operator shall maintain a copy of the Material Safety Data 

Sheet (MSDS) for each VOC containing material used at this plant 

b. TAC 

The owner or operator shall keep a record of the Material Safety Data Sheet 

(MSDS) for each TAC-containing material in this emission unit. 

c. HAP 

See LAP MACT Recordkeeping Section. 

S4. Reporting (Regulation 2.16, section. 4.1.9.3) 

SCH 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

The owner or operator shall submit a plant-wide emissions-based EA 

Demonstration to the District showing compliance with the plant-wide EA goals 

of 7.5 new and existing, 3.8 for all new combined, and 1 for each process when a 

change occurs that increases emissions above De minimus or previously modeled 

values. 

c. HAP 

See LAP MACT Repmiing Requirements. 

Page 57 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U010 Emission Unit Description: E-Coat Operation 

U010 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

7.01 General Provisions 7.2 

7.08 Standards of Performance for New Process 1 through 3 Operations 

40 CPR 60 General Provisions 60.1 through 60.18 Subpart A 

40 CPR 60 National Emission Standards of Performance for 

SubpartMM Automobile and Light Duty Truck Surface 60.390 through 60.397 

Coating Operations 

40 CPR 63 General Provisions 63.1 through 63.16 Subpart A 

40 CPR 63 National Emission Standards for Hazardous Air 

Subpart IIII Pollutants: Surface Coating of Automobiles and 1, 2, 3 ,4, 7 and 8 

Light-Duty Trucks 

District Only Enforceable Regulations 

Regulation Subject Applicable 

Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.02 Adoption ofNational Emission Standards for 1, 3, 4 and 5 Hazardous Air Pollutants 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

5.22 Procedures for Determining the Maximum Ambient 1 through 5 Concentration of a Toxic Air Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

7.02 Federal New Source Performance Standards 1.50, 2 , 3, 4 and 5 Incorporated by Reference 

SCH Page 58 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

UOlO Emission Points: 

U010 Emission Points 

ID Description Applicable Allowable Emission/ Equipment Control 

Requirement Standard Device 

(RT) is 2 0.16, not exceed 1.4 lbs/gal 

40 CPR 60 (0.17 kg/!) 

SubpartMM RT is 2 0.04 and < 0.16, not exceed the 

weight per gallon limit calculated as 

follows: 

0.17 x 350<0 160 -\) kg ofVOC per liter of 

applied coating solids 

6.17 and 7.01 

E10A E-Coat Dip RT is< 0.040, not be subject to an N/A Tank emission limit 

a. 0.6 lbs HAP/GACS 

Or 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) or 

without (b) E-coat) 

40 CPR 60 

SubpartMM See Specific Condition Sl.a 

6.17 and 7.01 

a. 0.6 lbs HAP/GACS 

Or C10A 

E10B E-Coat Oven b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) or 

without (b) E-coat) 

7.08 < 300 ppm 

SCH Page 59 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

UOlO Emission Points 

ID Description Applicable Allowable Emission/ Equipment Control 

Requirement Standard Device 

40 CPR 60 

SubpartMM See Specific Condition S 1.a 

6.17 and 7.01 

40 CPR 63 a. 0.6 lbs HAP/GACS 

Subpart IIII Or 

E10C E-Coat Oven b. 1.1 lbs HAPs/GACS C10B (3rd Pass) 

(the above limits are applicable to a 

group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) or 

without (b) E-coat) 

7.08 < 300 ppm 

40 CPR 60 

SubpartMM See Specific Condition Sl.a 

6.17 and 7.01 

E-Coat a. 0.6 lbs HAP/GACS 

E10D Dump Metal Or NIA 

AST b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) or 

without (b) E-coat) 

E-Coat Scuff· <20% 

E17A Booth 7.08 C17A 

2.34lb/hr 

U010 Control Devices: 

ID Performance 

Description StackiD Indicator 

C10A One (1) Regenerative Thermal Temperature S-041, S-043, S-045 

Oxidizer (RTO) 

C10B One (1) Regenerative Thermal 

Oxidizer (RTO) Temperature S-020 to S-022, S-050 

C17A Dry Panel Filter N/A S-047, S-048 

SCH Page 60 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U010 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

i. The owner or operator shall be subject to the following emission limits ( 40 

CFR 60.392, Regulation 7.01 section 7.2 and Regulation 6.17, section 3): 

1) When the solids turnover ratio (RT) is ;::::: 0.16, not exceed 1.4 

lbs/gal (0.17 kg/1) of applied coating solids. 

2) When the RT is;::::: 0.04 and< 0.16, not exceed the weight per gallon 

limit calculated as follows: 

0.17 x 350(0

·

160 - RT) kg of VOC per liter of applied coating solids. 

3) When the RT is < 0.040, not be subject to an emission limit 

established pursuant to this regulation. 

11. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

b. PM 

1. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

ii. The owner or operator shall not allow PM emissions to exceed 2.34 lb/hr. 

(Regulation 7.08, section 3.1.2) (See Comment 1) 

111. The owner or operator shall not operate the scuff booth unless the 

particulate filters are installed and operating properly. The owner or 

operator shall follow good operating practices for the particulate filters. 

c. Opacity 

The owner or operator shall not allow visible emissions to equal or exceed 20% 

opacity. (Regulation 7.08, section 3.1.1) 

d. HAP 

See LAP Ford Motor Company MACT Standards Section. 

e. NOx 

The owner or operator shall not cause to be discharged into the atmosphere from 

Page 61 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

any affected facility or from any air pollution control equipment installed on any 

affected facility any NOx fumes in excess of 300 ppm by volume expressed as 

N02 • (Regulation 7.08, section 4) (See Comment 2) 

f. TAC 

1. The owner or operator shall not allow any TAC emissions to exceed 

environmentally acceptable levels whether specifically established by 

modeling or derived from default de minimis levels. (Regulation 5.01, 

section 3.) 

ii. The owner or operator shall utilize the control devices at all times the 

surface coating operations are in operation and shall, maintain and operate 

any affected facility including associated air pollution control equipment 

in a manner consistent with good air pollution control practice for 

minimizing emissions. (Regulation 5.21, section 4.7) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. VOC 

i. Monitor ongoing compliance by calculating monthly, the daily volumeweighted average VOC content of the coatings (including resin, pigment, 

and flow control additive) used. Procedures used for this determination 

may be those provided in the "Protocol for Determining Daily Volatile 

Organic Compound Emission Rate of Automobile and Light-Duty Truck 

Topcoat Operations," EPA-450/3-88-018 (Docket ID No. OAR-2002-

0093 and Docket ID No. A-2001-22). 

ii. The owner or operator shall during operation of any coating operation(s) 

for which emission reductions due to the use of add-on control equipment 

are relied upon to demonstrate compliance with the emission limits above, 

maintain the afterburners combustion chamber temperature at :2:: 760° Cor 

other temperature, as determined during the latest stack test, based upon a 

three hour average, and maintain a combustion chamber temperature of no 

more than 28°C (50°F) below the average combustion temperature. In 

addition, the afterburners shall have a minimum residence time of 0.5 

seconds. The temperature shall be recorded using a recorder, which shall 

be calibrated and maintained according to the· manufacturer's 

specifications. Temperature measurements of the thermal oxidizer 

combustion chamber shall be made at least once every 15 minutes and 

recorded during operation of the associated coating operations. 

iii. If necessary for purposes of compliance, this line shall not be operated 

unless all control devices are being properly operated. 

Page 62 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

iv. Use EPA Method 24 to determine the amount ofVOC in the coating. The 

following equation may be used as an alternate method to demonstrate 

compliance: 

Where: 

VOCw = the weighted average coating VOC content, as applied; and less 

water and exempt solvents, expressed in pounds of VOC per 

gallon of coating. 

n = number of different coatings used on a coating line a given month. 

V 1 = the volume of each coating used on a coating line, as applied and 

less water and exempt solvents, a given month. 

C1 the VOC content of each coating used on a coating line, as applied 

and less water and exempt solvents, a given month. 

Vt = total volume of all coatings applied each month on a coating line, 

less water and exempt solvents. 

v. Meet the standards specified in 40 CPR 60.392, as calculated using the 

prescribed transfer efficiency of 40 CPR 60.393(c)(l)(i)(C) for the 

monthly weighted average mass of VOC emitted per volume of applied 

coating solids. 

b. PM 

The owner or operator shall include monthly inspection routine maintenance as 

recommended by the manufacturer, and prompt repair of any defects. 

c. Opacity 

See Specific Condition S2.b. 

d. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

e. NOx 

There are no monitoring requirements for NOx compliance. (See Comment 2) 

Page 63 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

f. TAC 

i. See Specific Condition S2.a.ii and iii. 

ii. See Specific Condition S3.f. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

Perform record keeping for VOCs for 40 CFR 60.395 and 1.05, Section 4: 

i. Record monthly the quantity of resin, pigment, and flow control additive 

added to the electrocoat system. 

ii. Determine and record monthly usage of each material. 

111. Calculations shall incorporate control efficiency where being relied upon 

for compliance purposes and shall include downtime adjustments to 

account for increased emissions during the period the afterburners were 

not operating. If used for compliance, the owner or operator shall also 

maintain records of control device downtimes and bypasses, including the 

date and duration of each occurrence. 

iv. The owner or operator shall continuously record the incinerator 

combustion temperature during coating operations for thermal incineration 

or the gas temperature upstream and downstream of the incinerator 

catalyst bed during coating operations for catalytic incineration. 

v. The owner or operator shall maintain monthly records, including 

calculations that show the total plant-wide VOC emissions during each 

calendar month and consecutive 12-month period. 

v1. Record the afterburner combustion chamber temperature and temperature 

recording frequency from Specific Condition S2.a.ii. 

b. PM 

1. The owner or operator shall keep a record that shows the date and the 

name of the person who inspected the filters and if filters were replaced. 

11. Proper operation of the fabric filter shall be ensured by maintaining 

records of inspections and routine maintenance activities and shall make 

these records available to the District upon request. A demonstration that 

Page 64 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

proper operation of the fabric filter has occurred satisfies this compliance 

requirement for the standard specified inS l.b.ii. above. 

c. Opacity 

See Specific Condition S3.b. 

d. HAP 

See LAP Ford Motor Company MACT Recordkeeping Section. 

e. NOx 

There are no record keeping requirements for NOx compliance. (See Comment 2) 

f. TAC 

i. The owner or operator shall keep a record of the Material Safety Data 

Sheet (MSDS) for each TAC-containing material in this emission unit. 

11. The owner or operator shall maintain records that identify all periods of 

bypassing the control devices while the surface coating operations are in 

operation for a given day. The records shall include the date, duration 

(including start and stop time) of each bypass event, identification of the 

control device and process equipment in operation, and the total lb/hr 

emissions of each TAC from each piece of equipment during each bypass 

event, if that control equipment is required to meet the EA goals. (See 

Comment 3) 

111. See Specific Conditions S3 .a.iii. 

S4. Reporting (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

i. See General Permit Reporting Requirements. 

11. For the control devices, the owner or operator shall clearly identify all 

deviations from permit requirements. If no deviations occur in that 

reporting period then the owner or operator shall report a negative 

declaration including the following information: 

1) Emission Unit number and Control ID number; 

2) The beginning and ending date of the reporting period; 

3) Identification of the operating parameters being monitored; 

4) Number, duration, and cause of all exceedances of the parameters; 

Page 65 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

and 

5) Description of the corrective action taken for each exceedance. 

111. Perform reporting for VOCs for 40 CFR 60.395 and 1.05, Section 4: 

b. PM 

1) The owner or operator shall report the volume weighted average 

mass of VOC per volume of applied coating solids for each 

affected facility. 

2) For thermal incinerators, every three-hour period shall be reported 

during which the average temperature measured is more than 28 

oc less than the average temperature during the most recent control 

device performance test. 

3) For catalytic incinerators, every three-hour period shall be reported 

during which the average temperature immediately before the 

catalyst bed, when the coating system is operational, is more than 

28 oc less than the average temperature immediately before the 

catalyst bed during the most recent control device performance test 

at which destruction efficiency was determined. In addition, every 

three-hour period shall be reported each quarter during which the 

average temperature difference across the catalyst bed when the 

coating system is operational is less than 80 percent of the average 

temperature difference of the device during the most recent control 

device performance test at which destruction efficiency was 

determined. 

4) For thermal and catalytic incinerators, if no such periods occur, the 

owner or operator shall submit a negative report. 

5) The owner or operator shall notify the Administrator 30 days in 

advance of any test by Method 25. 

Any deviation from the requirement to perform monthly visible inspections of the 

scuff booth PM filter system. 

c. Opacity 

See Specific Condition S4.b. 

d. HAP 

See LAP Ford Motor Company MACT Reporting Requirements. 

e. NOx 

There are no reporting requirements for NOx compliance. (See Comment 2) 

Page 66 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

f. TAC 

i. The owner or operator shall submit a plant-wide emissions-based EA 

Demonstration to the District showing compliance with the plant-wide EA 

goals of 7.5 new and existing, 3.8 for all new combined, and 1 for each 

process when a change occurs that increases emissions above De minimus 

or previously modeled values. 

11. Identification of all periods of bypassing the control devices while the 

surface coating operations were in operation during a reporting period. 

The report shall include the date, duration (including start and stop time) 

of each bypass event, and the totallb/hr emissions of each TAC from each 

piece of equipment during each bypass event, if that control equipment is 

required to meet the EA goals. (See Comment 3) 

iii. See Specific Conditions S4.a.ii. 

DOlO Comments 

1. Compliance with this requirement is demonstrated through a mass balance approach or 

engineering estimate. 

2. The District has performed a one-time NOx compliance demonstration using AP-42 

emission factors and combusting natural gas, and the emission standard cannot be 

exceeded. Therefore, there are no monitoring, record keeping, and reporting requirements 

with respect to NOx emission limits. 

3. The reported total lb/hr emissions of each TAC from each piece of equipment during 

each bypass event will be used to determine if each TAC claimed as de minimis pursuant 

to Regulation 5.01 Section 1.6 in Ford Motor Company Louisville Assembly Plant's 

current plant-wide emissions-based EA demonstration continue to meet the de minimis 

criteria specified in Section 1.6.4. Should emissions during a bypass event for a TAC 

claimed to be de minimis exceed the de minimis criteria, Ford Motor Company Louisville 

Assembly Plant shall submit an updated plant-wide emission-based EA Demonstration to 

the District showing compliance with the plant-wide EA goals of 7.5 new and existing, 

3.8 for all new combined, and 1 for each process where the TAC emissions increase 

above de minimis values. 

SCH Page 67 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U011 Emission Unit Description: Guidecoat Operation 

UOll Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1,3,4and5 Maintenance Requirements 

7.01 General Provisions 7.2 

7.08 Standards of Performance for New Process 1 through 3 Operations 

Standards of Performance for New 

7.59 Miscellaneous Metal Parts Products Surface 1 through 7 

Coating Operation 

40 CFR 60 General Provisions 60.1 through 60.18 Subpart A 

40 CFR 60 National Emission Standards of Performance for 

SubpartMM Automobile and Light Duty Truck Surface 60.390 through 60.397 

Coating Operations 

40 CFR 63 General Provisions 63.1 through 63.16 Subpart A 

40 CFR 63 National Emission Standards for Hazardous Air 

Subpart IIII Pollutants: Smface Coating of Automobiles and 1, 2, 3 ,4, 7 and 8 

Light-Duty Trucks 

SCH Page 68 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

District Only Enforceable Regulations 

Regulation Title Applicable Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.02 Adoption ofNational Emission Standards for 1, 3, 4 and 5 Hazardous Air Pollutants 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

7.02 Federal New Source Performance Standards 1.50, 2 , 3, 4 and 5 Incorporated by Reference 

SCH Page 69 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

DOll Emission Points: 

ID Description 

Guidecoat Paint 

EllA Spray Booth and Air 

Supply House 

Touchup and EllB Blackout Booth 

EllC Guidecoat Oven (1st 

and 2nd Pass) 

SCH 

Plant ID: 0072 

DOll Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 

SubpartMM See Specific Condition S l.a 

6.17 and 7.01 

a. 0.6 lbs HAP/GACS 

Or CllA 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Guidecoat) 

<20% ClOB 7.08 

2.34lb/hr 

7.59 3.5 lbs VOC/gal 

40 CPR 60 

SubpartMM See Specific Condition S l.a 

6.17 and 7.01 

a. 0.6 lbs HAP/GACS 

Or 

b. 1.1 lbs HAPs/GACS CllC 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Guidecoat) 

7.08 < 300 ppm 

Page 70 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

UOll Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR60 

SubpartMM See Specific Condition S l.a 

6.17 and 7.01 

40 CPR 63 a. 0.6 lbs HAP/GACS 

Guidecoat Oven (3rd Subpart IIII Or 

EllD b. 1.1 lbs HAPs/GACS ClOB Pass) (the above limits are applicable to a 

group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Guidecoat) 

7.08 < 300 ppm 

EllE/ Guidecoat/Topcoat 1.05 Same as for 7.59 

N/A E12G Paint Kitchen 40 CPR 60.3092 See Specific Condition S l.a 

Guidecoat (Prime) <20% 

ElSA 7.08 Cl8A Scuff Booth 2.34 lb/hr 

UOll Control Devices: 

UOll Control Devices 

ID Description 

Performance 

Indicator Stack ID 

CllA Water Wash N/A S-080 to S090 

ClOB One (1) Regenerative Temperature S-179 to S182 and S-098, S099, 

Thermal Oxidizer (RTO) S0 50 

CllC One (1) Regenerative Temperature S-091 to S-092, S-097 Thermal Oxidizer (RTO) 

Cl8A Dry Panel Filter N/A S-175 to S-178 

SCH Page 71 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U011 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

1. The owner or operator shall be subject to the limit of 1.40 kg VOC/1 (11.7 

lb VOC/gal) of applied coating solids, less water and exempt solvents. ( 40 

CFR 60.392) 

11. The owner or operator shall be subject to the limit of 1.8 kg VOC/1 (15.1 

lb VOC/gal) of applied coating solids, less water and exempt solvents. 

(Regulation 7.01 section 7.2 and Regulation 6.17, section 3 .2) (See 

Comment 3) 

iii. For Emission Point E11B, the owner or operator shall not cause or allow 

the emission of VOC from any affected facility resulting from the coating 

ofmetallic surfaces in excess of0.42 kg ofVOC/1 (3.5lb ofVOC/gal) of 

coating, excluding water and exempt solvents, as applied for extreme 

performance coatings. (Regulation 7.59, section 3.1.3) 

iv. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

b. PM 

i. See Louisville Assembly Plant, Ford Motor Company Plant-wide 

Applicability Limit (PAL). 

ii. The owner or operator shall not allow PM emissions to exceed 2.34 lb/hr. 

(Regulation 7.08, section 3.1.2) (See Comment 1) 

111. The owner or operator shall not operate the scuff booth unless the 

particulate filters are installed and operating properly. The owner or 

operator shall follow good operating practices for the particulate filters. 

c. Opacity 

The owner or operator shall not allow visible emissions to equal or exceed 20% 

opacity. (Regulation 7 .08, section 3 .1.1) 

d. HAP 

See LAP Ford Motor Company MACT Standards Section. 

e. NOx 

Page 72 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

The owner or operator shall not cause to be discharged into the atmosphere from 

any affected facility or from any air pollution control equipment installed on any 

affected facility any NOx fumes in excess of 300 ppm by volume expressed as 

N02 . (Regulation 7.08, section 4) (See Comment 2) 

f. TAC 

i. The owner or operator shall not allow any TAC emissions to exceed 

environmentally acceptable levels whether specifically established by 

modeling or derived from default de minimis levels. (Regulation 5.01, 

section 3.) 

11. The owner or operator shall utilize the control devices at all times the 

surface coating operations are in operation and shall, maintain and operate 

any affected facility including associated air pollution control equipment 

in a manner consistent with good air pollution control practice for 

minimizing emissions. (Regulation 5.21, section 4.7) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1) 

SCH 

a. VOC 

1. For Emission Point EllB, record monthly usage. Determine daily usage 

of each material by prorating monthly consumption based on daily 

vehicles produced. Record the amount of surface preparation, clean up, 

wash-up of solvent (including exempt compounds) used and the VOC 

content of each material used during the averaging period. (Regulation 

7.59, section 3.1.4 and 6.1.6, and 2.16, section 4.1.9.1.2) 

ii. The owner or operator shall during operation of any coating operation(s) 

for which emission reductions due to the use of add-on control equipment 

are relied upon to demonstrate compliance with the emission limits above, 

maintain the afterburners combustion chamber temperature at;:::: 760° C or 

other temperature, as determined during the latest stack test, based upon a 

three hour average, and maintain a combustion chamber temperature of no 

more than 28°C (50°F) below the average combustion temperature. In 

addition, the afterburners shall have a minimum residence time of 0.5 

seconds. The temperature shall be recorded using a recorder, which shall 

be calibrated and maintained according to the manufacturer's 

specifications. Temperature measurements of the thermal oxidizer 

combustion chamber shall be made at least once every 15 minutes and 

recorded during operation of the associated coating operations. 

111. The line shall not be operated unless all control devices are being properly 

operated. 

Page 73 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

iv. Measure capture efficiency pursuant to Regulation 1.05, Section 3, except 

that EPA Method 204F, Volatile Organic Compounds Content in Liquid 

Input Stream (Distillation Approach), shall be used to determine VOC 

input. 

v. Use EPA Method 24 to determine the amount ofVOC in the coating. The 

following equation may be used as an alternate method to demonstrate 

compliance: 

b. PM 

Where: 

VOCw = the daily weighted average coating VOC content, as applied; 

and less water and exempt solvents, expressed in pounds of 

VOC per gallon of coating. 

n = number of different coatings used on a coating line a given day. 

V 1 = the volume of each coating used on a coating line, as applied and 

less water and exempt solvents, a given day. 

C1 the VOC content of each coating used on a coating line, as applied 

and less water and exempt solvents, a given day. 

Vt = total volume of all coatings applied each day on a coating line, less 

water and exempt solvents. 

The owner or operator shall include monthly inspection routine maintenance as 

recommended by the manufacturer, and prompt repair of any defects. 

c. Opacity 

See Specific Condition S2.b. 

d. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

e. NOx 

There are no monitoring requirements for NOx compliance. (See Comment 2) 

Page 74 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

f. TAC 

1. See Specific Condition S2.a.iii and iv. 

ii. See Specific Condition S3 .f. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

1. For Emission Point EllB, the owner or operator of an affected facility 

subject to this regulation shall maintain records that include, but not be 

limited to, the following: (Regulation 7.59, section 6.1) 

1) The regulation and section number applicable to the affected 

facility for which the records are being maintained, 

2) The application method and substrate type (metal, plastic, etc.), 

3) The amount and type of coatings (including catalyst and reducer 

for multi-component coatings) and solvent (including exempt 

compounds) used at each point of application during the averaging 

period. The District may specifically authorize the usage record to 

reflect a period longer than the compliance averaging period, with 

the usage prorated for each compliance averaging period by a 

method approved by the District. In this case, the usage record 

period shall not exceed 1 calendar month, 

4) The VOC content as applied in each coating and solvent, 

5) The date, or usage record period, for each application of coating 

and solvent, 

6) The amount of surface preparation, clean-up, wash-up of solvent 

(including exempt compounds) used and the VOC content of each 

material used during the averaging period. The District may 

specifically authorize the usage record to reflect a period longer 

than the compliance averaging period, with the usage prorated for 

each compliance averaging period by a method approved by the 

District. In this case, the usage record period shall not exceed 1 

calendar month. 

11. The owner or operator shall maintain the following records: (40 CFR 

60.395 and 1.05, Section 4) 

1) Record daily the quantity of paint and dilution solvent added to the 

Page 75 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

guidecoat (primer surfacer). 

2) The owner or operator shall monitor ongoing compliance by 

calculating monthly, a daily volume-weighted average of the 

coatings used. 

3) Combine daily pour records with monthly tank level readings to 

determine monthly paint usage. 

4) Determine daily paint usage of each material by prorating 

consumption based on daily surface area coated. 

5) Determine daily usage and emissions by using calculation 

procedures in Protocol for Determining the Daily Volatile Organic 

Compound Emission Rate of Automobile and Light Truck Topcoat 

Operations, EPA-450/3-88-018. 

6) Calculations shall incorporate control efficiency and shall include 

downtime adjustments to account for increased emissions during 

the period the afterburners were not operating. The owner or 

operator shall also maintain records of control devices downtimes 

and bypasses, including the date and duration of each occurrence. 

7) Report all instances of non-compliance to the District no later than 

(15) days after the occurrence has been confirmed, notwithstanding 

Regulation 1.07. 

8) Meet the standards specified in 40 CFR 60.392, as calculated, 

using the prescribed transfer efficiency of 40 CFR 60.393 

(c)(1)(i)(C) for the monthly weighted average mass of VOC 

emitted per volume of applied coating solids. 

iii. Record the temperature and frequency from Specific Condition S2.a.ii. 

b. PM 

i. The owner or operator shall keep a record that shows the date and the 

name of the person who inspected the filters and if filters were replaced. 

ii. Proper operation of the fabric filter shall be ensured by maintaining 

records of inspections and routine maintenance activities and shall make 

these records available to the District upon request. A demonstration that 

proper operation of the fabric filter has occurred satisfies this compliance 

requirement for the standard specified in S 1.b.ii. above. 

Page 76 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

c. Opacity 

See Specific Condition S3.b. 

d. HAP 

See LAP Ford Motor Company MACT Recordkeeping Section. 

e. NOx 

There are no record keeping requirements for NOx compliance. (See Comment 2) 

f. TAC 

1. The owner or operator shall keep a record of the Material Safety Data 

Sheet (MSDS) for each TAC-containing material in this emission unit. 

11. The owner or operator shall maintain records that identify all periods of 

bypassing the control devices while the surface coating operations are in 

operation for a given day. The records shall include the date, duration 

(including start and stop time) of each bypass event, identification of the 

control device and process equipment in operation, and the total lb/hr 

emissions of each TAC from each piece of equipment during each bypass 

event, if that control equipment is required to meet the EA goals. (See 

Comment 4) 

iii. See Specific Conditions S3.a.ii.(5) 

S4. Reporting (Regulation 2.16, section. 4.1.9 .3) 

SCH 

a. VOC 

i. See General Permit Reporting Requirements. 

ii. For the control devices, the owner or operator shall clearly identify all 

deviations from permit requirements. If no deviations occur in that 

reporting period then the owner or operator shall report a negative 

declaration for the following category: 

1) Emission Unit number and Control ID number; 

2) The beginning and ending date of the reporting period; 

3) Identification of the operating parameters being monitored; 

4) Number, duration, and cause of all exceedances of the parameters; 

and 

5) Description of the corrective action taken for each exceedance. 

Page 77 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

111. Perform record keeping for VOCs for 40 CFR 60.395 and 1.05, Section 4: 

b. PM 

1) The owner or operator shall report the volume weighted average 

mass of VOC per volume of applied coating solids for each 

affected facility. 

2) The owner or operator shall continuously record the incinerator 

combustion temperature during coating operations for thermal 

incineration or the gas temperature upstream and downstream of 

the incinerator catalyst bed during coating operations for catalytic 

incineration. 

3) For thermal incinerators, every three-hour period shall be reported 

during which the average temperature measured is more than 28 

oc less than the average temperature during the most recent control 

device performance test. 

4) For catalytic incinerators, every three-hour period shall be reported 

during which the average temperature immediately before the 

catalyst bed, when the coating system is operational, is more than 

28 oc less than the average temperature immediately before the 

catalyst bed during the most recent control device performance test 

at which destruction efficiency was determined. In addition, every 

three-hour period shall be reported each quarter during which the 

average temperature difference across the catalyst bed when the 

coating system is operational is less than 80 percent of the average 

temperature difference of the device during the most recent control 

device performance test at which destruction efficiency was 

determined. 

5) For thermal and catalytic incinerators, if no such periods occur, the 

owner or operator shall submit a n.egative report. 

6) The owner or operator shall notify the Administrator 30 days in 

advance of any test by Method 25. 

Any deviation from the requirement to perform monthly visible inspections of the 

scuff booth PM filter system. 

c. Opacity 

See Specific Condition S4.b. 

d. HAP 

See LAP Ford Motor Company MACT Repmiing Requirements. 

e. NOx 

Page 78 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

There are no reporting requirements for NOx compliance. (See Comment 2) 

f. TAC 

1. The owner or operator shall submit a plant-wide emissions-based EA 

Demonstration to the District showing compliance with the plant-wide EA 

goals of 7.5 new and existing, 3.8 for all new combined, and 1 for each 

process when a change occurs that increases emissions above De minimus 

or previously modeled values. 

n. Identification of all periods of bypassing the control devices while the 

surface coating operations were in operation during a reporting period. 

The report shall include the date, duration (including start and stop time) 

of each bypass event, and the totallb/hr emissions of each TAC from each 

piece of equipment during each bypass event, if that control equipment is 

required to meet the EA goals. (See Comment 4) 

111. See Specific Conditions S4.a.ii. 

DOll Comments 

1. Compliance with this requirement is demonstrated through a mass balance approach or 

engineering estimate. 

2. The District has performed a one-time NOx compliance demonstration using AP-42 

emission factors and combusting natural gas, and the emission standard cannot be 

exceeded. Therefore, there are no monitoring, record keeping, and reporting requirements 

with respect to NOx emission limits. 

3. If Ford is in compliance with the 40 CFR 60 Subpart MM 60.3092 VOC limit than they 

are in compliance with Regulation 6.17, section 3.3 VOC limit. 

4. The reported total lb/hr emissions of each TAC from each piece of equipment during 

each bypass event will be used to determine if each TAC claimed as de minimis pursuant 

to Regulation 5.01 Section 1.6 in Ford Motor Company Louisville Assembly Plant's 

current plant-wide emissions-based EA demonstration continue to meet the de minimis 

criteria specified in Section 1.6.4. Should emissions during a bypass event for a TAC 

claimed to be de minimis exceed the de minimis criteria, Ford Motor Company Louisville 

Assembly Plant shall submit an updated plant-wide emission-based EA Demonstration to 

the District showing compliance with the plant-wide EA goals of 7.5 new and existing, 

3.8 for all new combined, and 1 for each process where the TAC emissions increase 

above de minimis values. 

SCH Page 79 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U012 Emission Unit Description: Topcoat Operation 

U012 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

7.08 Standards of Performance for New Process 1 through 3 Operations 

7.01 General Provisions 7.2 

40 CFR 60 General Provisions 60.1 through 60.18 Subpart A 

40 CFR 60 National Emission Standards of Performance for 

SubpartMM Automobile and Light Duty Truck Surface 60.390 through 60.397 

Coating Operations 

40 CFR 63 General Provisions 63.1 through 63.16 Subpart A 

40 CFR 63 National Emission Standards for Hazardous Air 

Subpart IIII Pollutants: Surface Coating of Automobiles and 1, 2, 3 ,4, 7 and 8 

Light-Duty Trucks 

SCH Page 80 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

District Only Enforceable Regulations 

Regulation Subject Applicable 

Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.02 Adoption ofNational Emission Standards for 1, 3, 4 and 5 Hazardous Air Pollutants 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

5.22 Procedures for Determining the Maximum Ambient 1 through 5 Concentration of a Toxic Air Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

7.02 Federal New Source Performance Standards 1.50, 2 , 3, 4 and 5 Incorporated by Reference 

SCH Page 81 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

U012 Emission Points: 

U012 Emission Points 

Description Applicable Allowable Emission/ 

Requirement Equipment Standard 

40 CPR 60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12A North Main 2.34lb/hr 

Enamel Booth and a. 0.6 lbs HAP/GACS 

Air Supply Or 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) 

or without (b) Topcoat) 

40 CPR60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12B North Main < 300ppm 

Enamel Oven c. 0.6 lbs HAP/GACS 

Or 

d. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) 

or without (b) Topcoat) 

SCH Page 82 of 130 

Plant ID: 0072 

Control 

Device 

C12A, C12B 

C12C, C12H and 

C12G 

C12D 

03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12C South Main 2.34lb/hr Cl2C, C12E, 

Enamel Booth and Air a. 0.6 lbs HAP/GACS C12H and C12G 

Supply House Or 

b. 1.1 lbs HAPs/GACS 

40 CFR63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Topcoat) 

40 CFR60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12D South Main <300 ppm C12D 

Enamel Oven c. 0.6 lbs HAP/GACS 

Or 

d. 1.1 lbs HAPs/GACS 

40 CFR63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Topcoat) 

SCH Page 83 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12E TuTone/Repair 2.34lb/hr 

Topcoat Booth and Air a. 0.6 lbs HAP/GACS Cl2P 

Supply House Or 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Topcoat) 

40 CPR 60 

SubpartMM See Specific Condition S 1.a. 

6.17and7.01 

<20% 

7.08 

E12P Tutone/Repair < 300 ppm 

Topcoat Oven c. 0.6 lbs HAP/GACS C12D 

Or 

d. 1.1 lbs HAPs/GACS 

40 CPR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with 

(a) or without (b) Topcoat) 

SCH Page 84 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR60 

SubpartMM See Specific Condition Sl.a. 

6.17 and 7.01 

EllE/E12G a. 0.6 lbs HAP/GACS 

Guidecoat/Topcoat Or N/A 

Kitchen b. 1.1 lbs HAPs/GACS 

40 CFR 63 (the above limits are applicable to a 

Subpart IIII group of emissions sources and are 

different depending upon whether 

compliance is demonstrated with (a) 

or without (b) Topcoat) 

E12H Topcoat Scuff <20% 

7.08 C19A Booth 2.34 lb/hr 

E12I TuTone/Repair <20% 

7.08 C20A Scuff Booth 2.34 lb/hr 

U12 Control Devices: 

Description 

Performance 

ID Indicator StackiD 

C12A, C12B 

Water Wash, two (2) Carbon 

Adsorber and two (2) 

C12C, C12H Regenerative Thermal Oxidizer Temperature S- to S090 

and C12G (RTO) 

C12C, C12E, 

Two (2) Regenerative Thermal S-150 to S-174, S- Oxidizer (RTO) ,Water Wash and Temperature 

C12H and C12G Carbon Adsorber 193, S-194 and S-203 

Regenerative Thermal Oxidizer Temperature S-404, S-408, S-409 

C12D (RTO) and S-215 

C12F Water Wash N/A S-110 to S124 and S410 

C19A Dry Panel Filter N/A S-183 and S-184 

C20A Dry Panel Filter N/A S-185 and S-186 

SCH Page 85 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U012 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

b. 

i. The owner or operator shall be subject to the limit of 1.47 kg VOC/1 (12.3 

lb VOC/gal) of applied coating solids, less water and exempt solvents. ( 40 

CPR 60.392) (See Comment 3) 

ii. The owner or operator shall be subject to the limit of 11.3 lb VOC/gal of 

applied coating solids, less water and exempt solvents. (Regulation 7.01 

section 7.2 and Regulation 6.17, section 3.3) 

111. See Louisville Assembly Plant, Ford Motor ComQany Plant-wide 

AQQlicability Limit (PAL). 

PM 

1. See Louisville Assembly Plant, Ford Motor Com12any Plant-wide 

AQQlicability Limit CP AL). 

ii. The owner or operator shall not allow PM emissions to exceed 2.34 lb/hr. 

(Regulation 7.08, section 3.1.2) (See Comment 1) 

111. The owner or operator shall not operate the booths unless the particulate 

filters are installed and operating properly. 

c. Opacity 

The owner or operator shall not allow visible emissions to equal or exceed 20% 

opacity. (Regulation 7.08, section 3.1.1) 

d. HAP 

See LAP Ford Motor ComQany MACT Standards Section. 

e. NOx 

The owner or operator shall not cause to be discharged into the atmosphere from 

any affected facility or from any air pollution control equipment installed on any 

affected facility any NOx fumes in excess of 300 ppm by volume expressed as 

N02. (Regulation 7.08, section 4) (See Comment 2) 

f. TAC 

Page 86 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

1. The owner or operator shall not allow any TAC emissions to exceed 

environmentally acceptable levels whether specifically established by 

modeling or derived from default de minimis levels. (Regulation 5.01, 

.section 3.) 

11. The owner or operator shall utilize the control devices at all times the 

surface coating operations are in operation if the control device reductions 

were used to demonstrate compliance and shall, maintain and operate any 

affected facility including associated air pollution control equipment in a 

manner consistent with good air pollution control practice for minimizing 

emissions. (Regulation 5.21, section 4.7) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. VOC 

1. Monitor ongoing compliance by calculating monthly, a daily volumeweighted average of the coatings used. Procedures used for this 

determination shall be those of "Protocol for Determining Daily Volatile 

Organic Compound Emission Rate of Automobile and Light-Duty Truck 

Topcoat Operations," EPA-450/3-88-018 (Docket ID No. OAR-2002-

0093 and Docket ID No. A-2001-22). 

ii. The owner or operator shall during operation of any coating operation(s) 

for which emission reductions due to the use of add-on control equipment 

are relied upon to demonstrate compliance with the emission limits above, 

maintain the afterburners combustion chamber temperature at~ 760° C or 

other temperature, as determined during the latest stack test, based upon a 

three hour average, and maintain a combustion chamber temperature of no 

more than 28°C (50°F) below the average combustion temperature. In 

addition, the afterburners shall have a minimum residence time of 0.5 

seconds. The temperature shall be recorded using a recorder, which shall 

be calibrated and maintained according to the manufacturer's 

specifications. Temperature measurements of the thermal oxidizer 

combustion chamber shall be made at least once every 15 minutes and 

recorded during operation of the associated coating operations. 

111. If necessary for purposes of compliance, this line shall not be operated 

unless all control devices are being properly operated. 

IV. Use EPA Method 24 to determine the amount ofVOC in the Coating. The 

following equation may be used as an alternate method to demonstrate 

compliance: 

Page 87 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

Where: 

n V. C. 

voc = s-~ -~ w v 

i=l t 

VOCw = the daily weighted average coating VOC content, as applied; 

and less water and exempt solvents, expressed in pounds of 

VOC per gallon of coating. 

n = number of different coatings used on a coating line a given day. 

V1 = the volume of each coating used on a coating line, as applied and 

less water and exempt solvents, a given day. 

C1 the VOC content of each coating used on a coating line, as applied 

and less water and exempt solvents, a given day. 

Vt = total volume of all coatings applied each day on a coating line, less 

water and exempt solvents. 

v. Meet the standards specified in 40 CFR 60.392, as calculated, using the 

prescribed transfer efficiency of 40 CFR 60.393( c )(1 )(i)(C) for the 

monthly weighted average mass of VOC emitted per volume of applied 

coating solids. 

b. PM 

The owner or operator shall follow good operating practices for the particulate 

filers, including monthly inspection, routine maintenance as recommended by the 

manufacturer, and prompt repair of any defects. 

c. Opacity 

See Specific Condition S2.b. 

d. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

e. NOx 

There are no monitoring requirements for NOx compliance. (See Comment 2) 

f. TAC 

Page 88 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

1. See Specific Condition S2.a.ii and iii. 

11. See Specific Condition S3.f. 

S3. Record Keeping (Regulation 2.16, section 4.1.9 .2) 

SCH 

a. VOC 

1. The owner or operator shall maintain the following records: (40 CFR 

60.395 and 1.05, Section 4) 

1) Record daily the quantity and type of paint withdrawn from the 

topcoat paint circulation system for use in the final repair 

operation. 

2) Determine daily VOC emissions based on the topcoat and final 

repair records. 

3) As an alternative to daily material usage records, the owner or 

operator may utilize material usage factor of 0.5% of topcoat 

usage. 

4) Calculations shall incorporate control efficiency and shall include 

downtime adjustments to account for increased emissions during 

the period the afterburners were not operating. The owner or 

operator shall also maintain records of control devices downtimes 

and bypasses, including the date and duration of each occurrence. 

ii. The owner or operator shall continuously record the incinerator 

combustion temperature during coating operations for thermal incineration 

or the gas temperature upstream and downstream of the incinerator 

catalyst bed during coating operations for catalytic incineration 

111. Record the temperature and frequency during operation of any coating 

operation specified in Specific Condition S2.a.ii. 

b. PM 

1. The owner or operator shall keep a record that shows the date and the 

name of the person who inspected the filters and if filters were replaced. 

11. Proper operation of the fabric filter shall be ensured by maintaining 

records of inspections and routine maintenance activities and shall make 

these records available to the District upon request. A demonstration that 

proper operation of the fabric filter has occurred satisfies this compliance 

requirement for the standard specified in S l.b.ii. above. 

Page 89 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

c. Opacity 

See Specific Condition S3.b. 

d. HAP 

See LAP Ford Motor Company MACT Recordkeeping Section. 

e. NOx 

There are no record keeping requirements for NOx compliance. (See Comment 2) 

f. TAC 

1. The owner or operator shall keep a record of the Material Safety Data 

Sheet (MSDS) for each TAC-containing material in this emission unit. 

11. The owner or operator shall maintain records that identify all periods of 

bypassing the control devices while the surface coating operations are in 

operation for a given day. The records shall include the date, duration 

(including start and stop time) of each bypass event, identification of the 

control device and process equipment in operation, and the total lb/hr 

emissions of each TAC from each piece of equipment during each bypass 

event, if that control equipment is required to meet the EA goals. (See 

Comment4) 

iii. See Specific Conditions S3.a.i.(4) 

S4. Reporting (Regulation 2.16, section. 4.1.9 .3) 

SCH 

a. VOC 

1. See General Permit Reporting Requirements. 

11. For the control devices, the owner or operator shall clearly identify all 

deviations from permit requirements. If no deviations occur in that 

reporting period then the owner or operator shall report a negative 

declaration including the following information: 

1) Emission Unit number and Control ID number; 

2) The beginning and ending date of the reporting period; 

3) Identification of the operating parameters being monitored; 

4) Number, duration, and cause of all exceedances of the parameters; 

and 

5) Description of the corrective action taken for each exceedance. 

Page 90 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

111. Perform reporting for VOCs for 40 CPR 60.395 and 1.05, Section 4: 

1) The owner or operator shall report the volume weighted average 

mass of VOC per volume of applied coating solids for each 

affected facility. 

2) For thermal incinerators, every three-hour period shall be reported 

during which the average temperature measured is more than 28 

oc less than the average temperature during the most recent control 

device performance test. 

3) For catalytic incinerators, every three-hour period shall be reported 

during which the average temperature immediately before the 

catalyst bed, when the coating system is operational, is more than 

28 oc less than the average temperature immediately before the 

catalyst bed during the most recent control device performance test 

at which destruction efficiency was determined. In addition, every 

three-hour period shall be reported each quarter during which the 

average temperature difference across the catalyst bed when the 

coating system is operational is less than 80 percent of the average 

temperature difference of the device during the most recent control 

device performance test at which destruction efficiency was 

determined. 

4) For thermal and catalytic incinerators, if no such periods occur, the 

owner or operator shall submit a negative report. 

5) The owner or operator shall notify the Administrator 30 days in 

advance of any test by Method 25. 

IV. Report all instances of non-compliance to the District no later than (15) 

days after the occurrence has been confirmed, notwithstanding Regulation 

1.07. 

b. PM 

Any deviation from the requirement to perform monthly visible inspections of the 

scuff booth PM filter system. 

c. Opacity 

See Specific Condition S4.b. 

d. HAP 

See LAP Ford Motor Company MACT Reporting Requirements. 

e. NOx 

Page 91 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

There are no reporting requirements for NOx compliance. (See Comment 2) 

f. TAC 

1. The owner or operator shall submit a plant-wide emissions-based EA 

Demonstration to the District showing compliance with the plant-wide EA 

goals of 7.5 new and existing, 3.8 for all new combined, and 1 for each 

process when a change occurs that increases emissions above De minimus 

or previously modeled values. 

11. Identification of all periods of bypassing the control devices while the 

surface coating operations were in operation during a reporting period. 

The report shall include the date, duration (including start and stop time) 

of each bypass event, and the totallb/hr emissions of each TAC from each 

piece of equipment during each bypass event, if that control equipment is 

required to meet the EA goals. (See Comment 4) 

111. See Specific Conditions S4.a.ii. 

U012 Comments 

1. Compliance with this requirement is demonstrated through a mass balance approach or 

engineering estimate. 

2. The District has performed a one-time NOx compliance demonstration using AP-42 

emission factors and combusting natural gas, and the emission standard cannot be 

exceeded. Therefore, there are no monitoring, record keeping, and reporting requirements 

with respect to NOx emission limits. 

3. If Ford is in compliance with Regulation 6.17, section 3.3 VOC limit than they are in 

compliance with the 40 CPR 60 Subpart MM 60.3092 VOC limit. 

4. The reported total lb/hr emissions of each T AC from each piece of equipment during 

each bypass event will be used to determine if each TAC claimed as de minimis pursuant 

to Regulation 5.01 Section 1.6 in Ford Motor Company Louisville Assembly Plant's 

current plant-wide emissions-based EA demonstration continue to meet the de minimis 

criteria specified in Section 1.6.4. Should emissions during a bypass event for a TAC 

claimed to be de minimis exceed the de minimis criteria, Ford Motor Company Louisville 

Assembly Plant shall submit an updated plant-wide emission-based EA Demonstration to 

the District showing compliance with the plant-wide EA goals of 7.5 new and existing, 

3.8 for all new combined, and 1 for each process where the TAC emissions increase 

above de minimis values. 

SCH Page 92 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U013 Emission Unit Description: Plant-wide Gasoline Fueling 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

7.15 Standards of Performance for New Process 1 through 6 Operations 

U013 Applicable Regulations: 

District Only Enforceable Regulations 

Regulation Title Applicable Sections 

1.18 Rule Effectiveness 1 through 3 

5.01 General Provisions 1 through 4 

5.14 Hazardous Air Pollutants and Source Categories 1 and 2 

Methodology for Determining Benchmark 

5.20 Ambient Concentration of a Toxic Air 1 through 6 

Contaminant 

5.21 Environmental Acceptability for Toxic Air 1 through 5 Contaminants 

Procedures for Determining the Maximum 

5.22 Ambient Concentration of a Toxic Air 1 through 5 

Contaminant 

5.23 Categories of Toxic Air Contaminants 1 through 6 

SCH Page 93 of 130 03-31-2011