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Michigan Department Of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT RO Permit Number 

N0895 STAFF REPORT MI-ROP-N0895-2007

Lacks Enterprises Inc. 

SRN: N0895 

Located at 

4260 Airlane Road SE, Kentwood, Michigan, 49512 

 

Permit Number: MI-ROP-N0895-2007 

Staff Report Date: April 30, 2007 

This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution 

Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 

451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), 

Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions 

of the Renewable Operating Permit (ROP). 
Lacks Enterprises Inc. 

Staff Report 

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TABLE OF CONTENTS 

April 30, 2007 STAFF REPORT ................................................................................................................3

June 1, 2007 STAFF REPORT ADDENDUM ............................................................................................7
Lacks Enterprises Inc. 

Staff Report 

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Michigan Department Of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT RO Permit Number 

N0895 

April 30, 2007 STAFF REPORT 

MI-ROP-N0895-2007 

Purpose

Major stationary sources of air pollutants, and some non-major sources, are required to obtain and 

operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s 

Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to 

the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a 

stationary source’s applicable requirements and compliance with them by consolidating all state and 

federal air quality requirements into one document. 

This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the 

draft permit terms and conditions including citations of the underlying applicable requirements, an 

explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any 

determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the 

stationary source. 

General Information

Stationary Source Mailing Address: Lacks Enterprises Inc. 

4260 Airlane Road SE 

Kentwood, Michigan 49512 

Source Registration Number (SRN): N0895 

Standard Industrial Classification (SIC) Code: 3417 

Number of Stationary Source Sections: 1 

Is Application for a Renewal or Initial Issuance? Renewal 

Application Number: 200600012 

Responsible Official: Mr. Bill Nieboer, Director of Operations 

616-554-2300 

AQD Contact: David L. Morgan, Environmental Quality Analyst 

616-356-0009 

Date Permit Application Submitted: January 19, 2006 

Date Application Was Administratively Complete: January 23, 2006 

Is Application Shield In Effect?: Yes 

Date Public Comment Begins: April 30, 2007 

Deadline for Public Comment: May 30, 2007 
Lacks Enterprises Inc. 

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Source Description

The applicant manufactures exterior plastic automotive parts. The stationary source consists of four 

facilities, the Airlane North and South plating facilities, Airwest Mold, Airlane Northwest Molding, and 

Airwest Assembly. The Airlane North and South facilities primarily conduct decorative chrome plating on 

plastic parts. The process consists of pretreatment, alkaline cleaning, acid dipping, and strike plating of 

copper, copper electroplating, nickel electroplating, and chromium electroplating. Electroless copper, 

conditioner, and rack stripping are controlled by wet scrubbers while the chrome plating and etching are 

controlled by composite mesh pad scrubbers. 

The Airlane Northwest and Airwest Mold facilities conduct plastic injection molding using acrylonitrile, 

butadiene, styrene (ABS) copolymer and ABS blended with a polycarbonate called HIPP (high impact 

plastic) that is more temperature and impact resistant. The injection molding processes are exempt from 

New Source Review (NSR) permitting and Rule 210 pursuant to Rule 212(3). 

The Airwest Assembly consists of several adhesive and ink coating booths. 

The following table lists stationary source-wide emission information as reported in the Michigan Air 

Emissions Reporting System for 2006 submittal. 

TOTAL STATIONARY SOURCE EMISSIONS – Criteria Pollutants 

Pollutant Tons per Year 

Carbon Monoxide (CO) 1.4 

Nitrogen Oxides (NOx) 6.8 

Volatile Organic Compounds (VOCs) 26.8 

Individual Hazardous Air Pollutants (HAPS) ** Pounds per Year 

Total Chromium 6 

Formaldehyde 1,507 

Methanol 49,866 

Total Hazardous Air Pollutants (HAPs) 51,379 

**As listed pursuant to Section 112(b) of the Clean Air Act. 

See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are 

subject to process-specific emission limits or standards. 

Regulatory Analysis

The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are addressed in the non-applicable requirement part of the Staff Report and 

Part E of the ROP. 

The stationary source is located in Kent County, which is currently designated as non-attainment for 

ozone. As of June 15, 2004, Kent County has been designated by the U.S. Environmental Protection 

Agency (USEPA) as a basic non-attainment area with respect to the 8-hour ozone standard. However in 

November 2006, the USEPA published the intention to reclassify Kent County as being in attainment 

with the applicable ozone standard. 
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The stationary source is considered a major source of Hazardous Air Pollutant (HAP) emissions because 

the potential to emit of any single HAP, regulated by the Clean Air Act, Section 112, is greater than 10 

tons per year and the potential to emit of all HAPs combined is greater than 25 tons per year. 

The stationary source is subject to the Maximum Achievable Control Technology (MACT) Standards for 

Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing 

Tanks, 40 CFR Part 63, Subpart N and the General Provisions under 40 CFR Part 63, Subpart A.

Tables FGN-1 and FGS-1 are subject to toxic air contaminant requirements under Rule 225. 

Formaldehyde, total chromium, nickel and 1,3-dichloro-2-propanol required modeling and emission limits 

are based upon the secondary initial risk screening levels for the stationary source. 

All cold cleaners under FGCOLDCLEANERS are subject to Rule 707. 

The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all 

applicable requirements and are consistent with the DEQ's "Procedure for Evaluating Periodic Monitoring 

Submittals." 

The stationary source is not subject to the federal Compliance Assurance Monitoring rule under Title 40 

of the Code of Federal Regulations, Part 64, because all emission units at the source either do not have 

a control device or those with a control device do not have potential pre-control emissions over the major 

source thresholds. 

Please refer to Parts B, C and D in the enclosed draft ROP for detailed regulatory citations for the 

stationary source. Part A contains regulatory citations for general conditions. 

Source-wide Permit to Install (PTI)

Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established 

pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a 

footnote designation in the integrated ROP/PTI document. PTIs that are being incorporated through this 

current permit action into the Source-wide PTI are listed in Appendix 6 of the permit. 

The following table lists all individual PTIs that were incorporated into previous ROP/Source-wide PTIs 

and subsequently voided. 

PTI Number 

383-98 285-01 267-05 267-05A 

Equivalent Requirements:

This permit does not include any equivalent requirements or significant changes pursuant to 

R 336.1212(5). Equivalent requirements are enforceable applicable requirements that are equivalent to 

the applicable requirements contained in the original New Source Review permit or Consent 

Order/Judgment. 
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Non-applicable Requirements

Part E of the draft ROP lists requirements that are not applicable to this source as determined by the 

AQD, if any were proposed in the application. These determinations are incorporated into the permit 

shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to 

Rule 213(6)(a)(ii). 

Processes in Application Not Identified in Draft RO Permit

The following table lists processes that were included in the ROP application as exempt devices under 

Rule 212(4). These processes are not subject to any process-specific emission limits or standards in 

any applicable requirement. 

Exempt 

Emission Unit ID 

Description of 

Exempt Emission Unit 

RO Permit 

Exemption 

NSR Permit 

Exemption 

EUAIRMAKEUPUNIT Campus (4 buildings) natural 

gas usage, air make-up units 

and natural gas fired boilers 

R 336.1212(4) R 336.1282(b) 

EUPLASTICINJMOLD PLASTIC INJECTION 

MOLDING 

R 336.1212(3) R 336.1286(b) 

Draft RO Permit Terms/Conditions Not Agreed to by Applicant

This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree 

upon pursuant to R 336.1214(2). 

Compliance Status

The AQD finds that the stationary source is expected to be in compliance with all applicable 

requirements as of the date of issuance of this ROP. 

Action Taken by the Department

The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public 

and affected states have had an opportunity to comment on the AQD proposed action and draft permit. 

In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the 

draft permit and related material. The AQD is not required to accept recommendations that are not 

based on applicable requirements. The delegated decision maker for the AQD is Heidi G. Hollenbach, 

Grand Rapids District Supervisor. The final determination for ROP approval/disapproval will be based on 

the contents of the permit application, a judgment that the stationary source will be able to comply with 

applicable emission limits and other terms and conditions, and resolution of any objections by the 

USEPA. 
Lacks Enterprises Inc. 

Staff Report 

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Michigan Department of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT ROP Number 

N0895

June 1, 2007 STAFF REPORT ADDENDUM 

MI-ROP-N0895-2007

Purpose

A Staff Report dated April 30, 2007, was developed in order to set forth the applicable requirements and 

factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by 

R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments 

received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In 

addition, this addendum describes any changes to the draft ROP resulting from these pertinent 

comments. 

General Information

Responsible Official: Mr. Bill Nieboer, Director of Operations 

616-554-2300 

AQD Contact: David L. Morgan, Environmental Quality Analyst 

616-356-0009 

Summary of Pertinent Comments

No comments were received from the general public, however, Lacks Enterprises made several 

comments. A summary of the significant comments and responses to them follow below: 

FGN-1, Condition III.6 

Comment: The applicant commented that the requirement to keep all doors and windows closed at all 

times during operations was never a requirement for the North Plater, it was only required for the South 

Plater in order to help control fugitive emissions which resulted in odors. 

Response: This condition can be considered an obsolete condition and will be removed from the permit. 

Since odors are covered under General Provision No. 12 of the ROP, this condition will be removed. 

FGS-1, Condition III.6 – 

Comment: The applicant commented that the requirement to keep all doors and windows closed at all 

times during operation of the South Plater was added to air use Permit to Install 383-98 to address 

fugitive emission from the nickel plating tanks which were a source of odors from the facility. In 2004, 

the company installed new air make-up units and a 40,000 CFM exhaust system on the nickel plating 

tanks to mitigate fugitive emissions and odors from the building. The company requested that this 

requirement be removed. 

Response: This condition can be considered an obsolete condition. Since odors are covered under 

General Provision No. 12 of the ROP, this condition will be removed. 
Lacks Enterprises Inc. 

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Changes to the April 30, 2007 Draft ROP

FGN-1, Condition III.6 – This condition has been removed from the ROP. 

FGS-1, Condition III.6 – This condition has been removed from the ROP.