Page 1 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 Mi chigan 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

Page 2 TABLE OF CONTENTS

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

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

Page 3 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, 2007Lacks Enterprises Inc. Staff Report

Page 4 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 facilit ies 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 resistan t. 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 (NO

x ) 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.Lacks Enterprises Inc. Staff Report

Page 5 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-dichlo ro-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.Lacks Enterprises Inc. Staff Report

Page 6 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 deter mination 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 conditi ons, and resolution of any objections by the

USEPA.Lacks Enterprises Inc. Staff Report

Page 7 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 Pe rmit (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. Staff Report

Page 8 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.