Permit No: 147-97-TV (R2) 

U013 Emissions Points: 

ID Description 

E13A Gasoline Tank #1 

E13B Gasoline Tank #2 

El3C Gasoline Tank #3 

E13D Two (2) Fueling 

Stations 

Plant ID: 0072 

U013 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

7.15 Stage I vapor recovery system N/A 

7.15 Stage I vapor recovery system N/A 

7.15 Stage I vapor recovery system N/A 

See Comment 2 ORVR Equipped Vehicles N/A and 3 

U013 Control Equipment: There are no control devices associated with Emission Unit U013. 

SCH Page 94 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U013 Specific Conditions: 

S 1. Standards (Regulation 2.16, section 4.1.1) 

a. VOC 

1. Storage tanks, Emission Points E13A through E13C, shall be equipped 

with the following: (Regulation 7.15, section 3.1) 

b. TAC 

a) A submerged fill pipe; (Regulation 7.15, section 3.1.1) 

b) Ifthe gasoline storage tank is equipped with a separate gauge well, 

a gauge well drop tube shall be installed which extends to within 

six inches of the bottom of the tank; (Regulation 7.15, section 

3.1.2) 

c) Vent line restrictions on the affected facility; and (Regulation 7.15, 

section 3 .1.3) 

d) Vapor balance system and vapor tight connections on the liquid fill 

and vapor return hoses. The cross-sectional area of the vapor return 

hose and any other vapor return passages in the circuit connecting 

the vapor space in the service station tank to that of the truck tank 

must be at least 50% of the liquid fill hose cross-sectional area for 

each tank and free of flow restrictions to achieve acceptable 

recovery. The vapor balance equipment must be maintained 

according to the manufacturer's specifications. The type, size and 

design of the vapor balance system are subject to the approval of 

the District. (Regulation 7.15, section 3 .1.4) 

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.) (See 

Comment 1) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. VOC 

Storage tanks: To demonstrate ongoing compliance with Regulation 1.05, Section 

4, the owner or operator shall monitor the quantity of gasoline used to fuel 

vehicles. 

a) The owner or operator shall monthly: 

Page 95 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

1) Check the storage tank fill points for tightness; 

2) If a two point vapor recovery system on the storage tank, check 

rubber gaskets for tears, verify spring loaded valves properly 

operate and tank refill caps have rubber gaskets in good condition; 

replace any damaged parts; and 

b) The owner or operator shall annually: 

Verify pressure vacuum valve on vent pipe is operating properly annually 

and replace any damaged part. 

c) The owner or operator must complete all repairs within 5 working days. 

b. TAC 

See Comment 1. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

a. VOC 

1. The owner or operator shall record total monthly gasoline throughput and 

make these records available to the District upon request. 

ii. The owner or operator shall maintain records of the monthly and annual 

inspections. These records shall contain the date and time of the 

inspection; who performed the inspection; and the results of the 

inspection. 

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. (See Comment 

1) 

S4. Reporting (Regulation 2.16, section. 4.1.9 .3) 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

There are no routine reporting requirements for this equipment. (See Comment 1) 

SCH Page 96 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U013 Comments 

1. The emissions from a motor vehicle fueling or refueling process and process equipment 

for gasoline and other liquid fuels are de minimis under STAR. (Regulation 5.01, section 

1.6.6.) 

2. The District reviewed a letter dated January 18,2007 regarding the current applicability of 

Stage II Vapor Recovery. EPA has provided guidance that vehicle production plants 

doing initial fueling of vehicle comply with vapor recovery requirements by means of 

ORVR requirements for compliant vehicles. The District concurs that the external vapor 

recovery system as required by the applicable Title V operating permit for LAP is not 

required for fueling vehicles with ORVR. 

3. Regulation 6.40 does not apply to the initial fueling of new motor vehicles at a motor 

vehicle assembly facility per section 2.1.2. 

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

U014 and U022 Emission Unit Description: Paint Equipment Cleaning Operations 

U014 and U022 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

6.18 

Standards of Performance for Solvent Metal 

1 though 4 Cleaning Equipment 

7.25 

Standards of Performance for New Source Using 1 through 5 Volatile Organic Compounds 

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

U014 and U022 Emission Points: 

U014 and U022 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

Paint Equipment 7.25 See Specific Conditions S 1.a. 

E14A N/A Cleaning Booth 40 CPR 63 Subpart lUI Section 63.3094 

Paint Equipment 7.25 See Specific Conditions S 1.a. 

E22A Purging and Plant N/A 

Cleaning 40 CPR 63 Subpart lUI Section 63.3094 

Solvent Metal 

See Specific Conditions S 1.a.iii N/A Cleaning 6.18 N/A 

Equipment 

U014 and U022 Control Devices: There are no control devices associated with Emission Unit 

U014 and U022. 

SCH Page 99 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U014 and U022 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

i. Applicator Paint Purging: The automatic spray applicators will incorporate 

a purge paint and solvent recovery system that will collect the purged 

materials. 

ii. The owner or operator of a cold cleaner to clean non-paint or non-sealer 

related equipment using volatile organic compounds (VOC) shall, install, 

maintain, and operate the control equipment as follows: 

The cold cleaner shall be equipped with a tightly fitting cover that is free 

of cracks, holes, or other defects. If the solvent is agitated or heated, then 

the cover shall be designed so that it can be easily operated with 1 hand. 

(Regulation 6.18, section 4.1.1) 

The cold cleaner shall be equipped with a drainage facility that is designed 

so that the solvent that drains off parts removed from the cleaner will 

return to the cold cleaner. The drainage facility may be external if the 

District determines that an internal type cannot fit into the cleaning 

system. (Regulation 6.18, section 4.1.2) 

A permanent, conspicuous label summarizing the operating requirements 

specified in Specific Condition S l.b. shall be installed on or near the cold 

cleaner. (Regulation 6.18, section 4.1.3) 

If used, the solvent spray shall be a fluid stream, not a fine, atomized, or 

shower type spray, at a pressure that does not cause excessive splashing. 

Flushing of parts using a flexible hose or other flushing device shall be 

performed only within the freeboard area of the cold cleaner. Solvent flow 

shall be directed downward to avoid turbulence at the air-solvent interface 

and to prevent solvent from splashing outside of the cold cleaner. 

(Regulation 6.18, section 4.1.4) 

Work area fans shall be located and positioned so that they do not blow 

across the opening ofthe cold cleaner. (Regulation 6.18, section 4.1.6) 

The solvent-containing portion of the cold cleaner shall be free of all 

liquid leaks. Auxiliary cold cleaner equipment such as pumps, water 

separators, steam traps, or distillation units shall not have any visible 

liquid leaks, visible tears, or cracks. (Regulation 6.18, section 4.1.8) 

The owner or operator shall observe at all times the following operating 

Page 100 of130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

b. TAC 

requirements: (Regulation 6.18, section 4.2) 

Waste solvent shall neither be disposed of nor transferred to another party 

in a manner such that more than 20% by weight of the waste solvent can 

evaporate. Waste solvent shall be stored only in a covered container. A 

covered container may contain a device that allows pressure relief, but 

does not allow liquid solvent to drain from the container. (Regulation 6.18, 

section 4.2 .1) 

The solvent level in the cold cleaner shall not exceed the fill line. 

(Regulation 6.18, section 4.2.2) 

The cold cleaner cover shall be closed whenever a part is not being 

handled in the cold cleaner. (Regulation 6.18, section 4.2.3) 

Parts to be cleaned shall be racked or placed into the cold cleaner in a 

manner that will minimize drag-out losses. (Regulation 6.18, section 4.2.4) 

Cleaned parts shall be drained for at least 15 seconds or until dripping 

ceases, whichever is longer. Parts having cavities or blind holes shall be 

tipped or rotated while the part is draining. During the draining, tipping, or 

rotating, the parts shall be positioned so that the solvent drains directly 

back to the cold cleaner. (Regulation 6.18, section 4.2.5) 

A spill during solvent transfer shall be cleaned immediately, and the wipe 

rags or other sorbent material shall be immediately stored in a covered 

container for disposal or recycling, unless enclosed storage of these items 

is not allowed by fire protection authorities. (Regulation 6.18, section 

4.2.6) 

Sponges, fabric, wood, leather, paper products, and other absorbent 

material shall not be cleaned in a cold cleaner. (Regulation 6.18, section 

4.2.7) 

The owner or operator shall not operate a cold cleaner used to clean nonpaint or non-sealer related equipment using a solvent with a vapor 

pressure that exceeds 1.0 mm Hg (0.019 psi) measured at 20°C (68°F). 

(Regulation 6.18, section 4.3.2) 

The owner or operator shall not allow any TAC em1sswns to exceed 

environmentally acceptable levels whether specifically established by modeling or 

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

c. HAP 

Page 101 of130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

1. The owner or operator shall follow the work practices specified in 40 CFR 

63 Subpart IIII, Specific Condition Sl.b and c. to minimize VOC 

emissions from purge and cleaning operations. 

11. See LAP Ford Motor Company MACT Standards Section. 

S2. Monitoring (Regulation 2.16, section 4.1.9.1.2) 

a. VOC 

See Specific Condition S 1.a. 

b. TAC 

See Specific Condition S3.b. 

c. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

a. VOC 

1. See Specific Condition S l.a. 

ii. The owner or operator shall maintain records that include the following 

for each purchase: (Regulation 6.18, section 4.4.2) 

b. TAC 

1) The name and address of the solvent supplier, 

2) The date of the purchase, 

3) The type of the solvent, and 

4) The vapor pressure of the solvent measured in mm Hg at 20 a C 

(68°F). 

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 Ford Motor Company MACT Recordkeeping Section. 

S4. Reporting (Regulation 2.16, section 4.1.9 .2) 

SCH Page 102 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

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 Ford Motor Company MACT Reporting Requirements. 

U014 and U022 Comments 

1. Specific Conditions involving work practice standards only have no monitoring, record 

keeping and reporting requirements, as such would be impractical. 

2. The aqueous cold cleaners that contain no VOCs are not subject to Regulation 6.18. 

SCH Page 103 of130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U015 Emission Unit Description: Sealer Deck 

U015 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

7.59 Standards of Performance for New Source Using 1 through 5 Volatile Organic Compounds 

40 CFR63 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 

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 

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 104 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

U015 Emission Points: 

ID Description 

E15A Sealer Application 

N/A Sealers and Deadeners 

(other than glass bonding) 

Plant ID: 0072 

U015 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

7.59 3.5 lbs/gal N/A 

Section 40 CFR 63.3090 (c) 

40 CFR 63 or 63.3091 (c) N/A Subpart IIII 0.01lb VOC per lb of 

adhesive and sealer material 

U015 Control Devices: There are no control devices associated with Emission Unit U015. 

SCH Page 105 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U015 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 of VOC from 

any affected facility resulting from the coating of metallic surfaces in 

excess of 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) 

11. 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 Ford Motor Company MACT Standards Section. 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

a. VOC 

See Specific Condition S3 .a. 

b. TAC 

See Specific Condition S3.b. 

c. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

1. The owner or operator of an affected facility subject to this regulation 

shall maintain records that include, but not be limited to, the following: 

Page 106 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

b. TAC 

(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. 

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 Ford Motor Company MACT Recordkeeping Section. 

S4. Reporting (Regulation 2.16, section 4.1.9.3) 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

SCH Page 107 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

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 Ford Motor Company MACT Reporting Requirements. 

Page 108of130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U016 Emission Unit Description: Final Repair Spray Booth; infrared curing, and spot repair 

bays for repairing coating on vehicles 

U016 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 

Operations 1 through 3 

40 CFR60 General Provisions 63.1 through 63.16 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 109 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 1,3,4and5 Hazardous Air Pollutants 

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 110 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

U016 Emission Points: 

ID Description 

E16A Final Repair 

Booth 

E16B Final Repair 

Oven 

SCH 

Plant ID: 0072 

U016 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR 60 Subpart MM 

See Specific Conditions S 1.a. 

6.17 and 7.01 

<20% 

7.08 

2.34lb/hr 

a. 0.6 lbs HAP/GACS C16A 

Or 

b. 1.1 lbs HAPs/GACS 

40 CFR 63 Subpart IIII (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) final repair) 

40 CFR 60 Subpart MM 

6.17 and 7.01 

See Specific Conditions S 1.a. 

<20% 

7.08 

< 300 ppm 

a. 0.6 lbs HAP/GACS N/A 

Or 

b. 1.1 lbs HAPs/GACS 

40 CFR 63 Subpart IIII (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) final repair) 

Page 111 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U016 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR 60 Subpart MM 

See Specific Conditions S 1.a 

6.17 and 7.01 

<20% 

7.08 

2.34 lb/hr 

E16C Final Repair a. 0.6 lbs HAP/GACS N/A Spot Paint Or 

b. 1.1 lbs HAPs/GACS 

40 CFR 63 Subpart IIII (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) final repair) 

U016 Control Devices: 

ID Description 

Performance StackiD Indicator 

C16A Fabric Filter N/A Sl87 and S188 

SCH Page 112 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U016 Specific Conditions 

1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

i. The owner or operator shall be subject to the emission limit of 4.8 lbs 

VOC/gal (0.58 kg/1) of coating, less water and exempt solvents. (40 

CFR60.3092, Regulation 7.01 section 7.2 and Regulation 6.1, section 3.4) 

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 Final Repair Booth 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 Company 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 

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.) 

Page 113 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

S2. Monitoring (Regulation 2.16, section 4.1.9.1.2) 

SCH 

a. VOC 

i. 

ii. 

Where: 

Monitor ongoing compliance by calculating monthly, a daily a volume 

weighted 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) 

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: 

n V. C. 

VOC = s _I _I 

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. 

111. Meet the standards specified in 40 CFR 60.392, as calculated, using the 

prescribed transfer efficiency of 40 CFR 60.393( c )(l)(i)(C) for the 

monthly weighted average mass ofVOC emitted per volume of applied 

coating solids. 

b. PM 

The owner or operator shall follow good operating practices for the particulate 

filters, including monthly inspection, routine maintenance as recommended by the 

manufacturer, and prompt repair of any defects. 

Page 114 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

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 

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: 

1) Record monthly the daily quantity and type of paint withdrawn from the 

topcoat paint circulation system for use in the final repair operation using 

the methodology specified in S2.a. 

2) Monthly, determine the daily VOC emissions based on the topcoat and 

final repair records. 

3) As an altemative to daily material usage records, the owner or operator 

may utilize an appropriate material usage factor determined to be 

acceptable by the District. (See Comment 3) 

4) 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. 

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 115 of130 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 1.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 

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 4.1.9.2) 

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 with 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. 

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) The owner or operator shall notifY the Administrator 30 days in 

advance of any test by Method 25. 

Page 116 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

b. PM 

1. Any deviation from the requirement to perform monthly visible 

inspections of the booth PM filter system; 

11. The dates that filters were replaced or a declaration that there were no 

filters replaced during the reporting period; and 

111. See General Permit Reporting Requirements. 

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) 

f. 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. 

U016 Comment 

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 District has deemed 0.5% as an appropriate material usage factor for Emission Unit 

U016. 

SCH Page 117 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U023 Emission Unit Description: Phosphate Operation 

U023 Applicable Regulations: 

District Only Enforceable Regulations 

Regulation Title Applicable Sections 

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 ofToxic Air Contaminants 1 through 6 

U023 Emission Points: 

U023 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard 

E1000 Phosphate 5.01 See Specific Conditions S3. 

El001 Phosphate Dump 5.01 See Specific Conditions S3. 

Tank 

U023 Control Devices: There are no control devices associated with Emission Unit 

U023. 

Device 

N/A 

N/A 

SCH Page 118 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

U023 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

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) 

TAC 

See Specific Condition S3. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

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 .2) 

SCH 

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. 

Page 119 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

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

U025 Applicable Regulations: 

FEDERALLY ENFORCEABLE REGULATIONS 

Regulation Title Applicable Sections 

7.08 Standards of Performance for New Indirect Heat 1 through 4 Exchangers 

Reasonable Available Control Technology 

6.42 Requirements for Major Volatile Organic 1.2, and 2 through 5 

Compound 

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 

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 

U025 Emission Points: 

U025 Emission Points 

ID Description Applicable Regulation Control Device 

5.21 

E25 Direct Heat Exchangers 6.42 N/A 

7.08 

U025 Control Devices: There are no control devices associated with Emission Unit 

U025. 

SCH Page 120 of 130 03-31-2011 
Permit No: 14 7-97-TV (R2) Plant ID: 0072 

U025 Specific Conditions 

Sl. Standards (Regulation 2.03, section 5.1) 

a. PM 

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) 

b. Opacity 

The owner or operator shall not allow visible emissions to equal or exceed 20% 

opacity. (Regulation 7.08, section 3.1.1) 

c. 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. 

ii. The owner or operator shall not allow NOx emissions to exceed 300 ppm 

by volume expresses as N02 . (Regulation 7.08, section 4.1.) (See 

Comment 4) 

d. 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 2.03, section 5.1) 

a. PM 

There are no monitoring requirements for PM compliance. (See Comment 1) 

b. Opacity 

See Comment 2. 

c. NOx 

See Specific Condition S3.c. 

d. TAC 

SCH Page 121 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

See Comment 3. 

Plant ID: 0072 

S3. Record Keeping (Regulation 2.03, section 5.1) 

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. PM 

There are no record keeping requirements for PM compliance for this equipment. 

(See Comment 1) 

b. Opacity 

There are no record keeping requirements for Opacity compliance for this 

equipment. (See Comment 2) 

c. NOx 

1. 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. 

ii. See Comment 4. 

d. TAC 

See Comment 3. 

S4. Reporting (Regulation 2.03, section 5.1) 

SCH 

a. PM 

See Comment 1. 

b. Opacity 

See Comment 2. 

c. NOx 

1. The owner or operator shall report the monthly and 12 consecutive month 

plant-wide NOx emissions for each month in the report period. 

11. See PAL Reporting Requirements. 

Page 122 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

d. 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. 

U025 Comments 

1. The District has performed a one-time PM compliance demonstration for the space 

heater, 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 space heater with respect to PM 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. STAR Regulation 5.01, section 1.6.7 states the TACs from natural combustion are De 

Minimis. 

4. The District performed a onetime compliance demonstration for NOx and the 300 ppm 

standard cannot be exceeded uncontrolled. 

SCH Page 123 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Ford LAP Plant-wide 

Permit Shield 

The owner or operator is hereby granted a permit shield that shall apply as long as the owner or 

operator demonstrates ongoing compliance with all conditions of this permit. Compliance with 

the conditions of this permit shall be deemed compliance with all applicable requirements of the 

regulations cited in this permit as of the date of issuance, pursuant to Regulation 2.16, section 

4.6.1. 

Off-permit Documents 

Document 

Rule Effectiveness Plan 10 April1995 

Alternative Operating Scenarios 

The owner or operator did not request to operate under any alternative operating scenarios in its 

Title V permit application. 

Insignificant Activities 

Description Quantity Basis 

Internal combustion Various Regulation 2.02, Section 2.2 engines fixed or mobile 

Presses extruding Various Regulation 2.02, Section 2.3.1 metal/mineral/wood 

Brazing, soldering or Various Regulation 2.02, Section 2.3.4 welding equipment 

Woodworking, except for 

conveying, hogging, or Various Regulation 2.02, Section 2.3 .5 

burning wood/sawdust 

Lab venting and exhaust 

systems (non radioactive Various Regulation 2.02, Section 2.3.11 

materials) 

Ventilation systems- Various Regulation 2.02, Section 2.3.12 bakeries & restaurants 

Washing or drying 

fabricated metal or glass; Various Regulation 2.02, Section 2.3 .15 non VOC use; no oil or 

solid fuel 

Residential/domestic Various Regulation 2.02, Section 2.3.12 equipment 

Portable diesel or gasoline Various Regulation 2.02, Section 2.3.23 

storage tanks 

SCH Page 124 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Insignificant Activities 

Description Quantity Basis 

Diesel fuel storage tanks Various Regulation 2.02, Section 2.3.25 (emergency use only) 

Closed pressure storage 2 Regulation 2.02, Section 2.3.26 vessels 

Portable tote tanks for raw Tote tanks are kept closed when not in use. Emissions from tanks material shipment of Various 

solvent - based coatings are negligible, and are accounted for by process material balance. 

Backup generators for 

emergency power.(< 500 2 Generators normal use is very low and HP <500 HP. 

hrs/year) 

Wastewater Pretreatment 1 Emissions insignificant system. 

Fluid Fill (hydraulic fluids, Emissions insignificant due to low vapor pressure of materials oil, anti-freeze) and Various 

Lubricating operations. used. 

Miscellaneous maintenance 

procedures including 

lubrication, grinding, Various Negligible emissions 

cleaning, woodworking, 

etc. 

Direct heat exchangers <1 Various Regulation 2.02, Section 2.1.1 MMBtu/hr 

a. Insignificant Activities are only those activities or processes falling into the 

general categories defined in District Regulation 2.02, Section 2, and not 

associated with a specific operation or process for which there is a specific 

regulation. Equipment associated with a specific operation or process (Emission 

Unit) shall be listed with the specific process even though there may be no 

applicable requirements. Information contained in the permit and permit 

summary shall clearly indicate that those items identified with negligible 

emissions have no applicable requirements. 

SCH 

b. Activities identified in District Regulation 2.02, Section 2, may not require a 

permit and may be insignificant with regard to application disclosure 

requirements but may still have generally applicable requirements that continue to 

apply to the source. 

c. For all insignificant activities that emit regulated air pollutants for which the 

company has accepted a plant-wide synthetic minor limit, the company shall 

maintain sufficient records to calculate the emissions and report those emissions 

in the quarterly compliance reports and the annual emissions inventory report. 

d. The Insignificant Activities table is correct as of the date the permit was proposed 

for review by the USEP A, Region 4. The company shall submit an updated list of 

Page 125 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

insignificant activities annually with the Title V compliance certification pursuant 

to District Regulation 2.16, section 4.3.5.3.6. 

e. In lieu of recording annual throughputs for each Insignificant Activity, the owner 

or operator may elect to report the Potential To Emit quantity listed in the 

Insignificant Activities table as the annual emission for each piece of equipment, 

since the emissions from the source's Insignificant Activities are minor. 

Page 126 of 130 03-31-2011 
Permit No: 147-97-TV (R2) 

Ford Louisville Assembly Plant 

Compliance Assurance Monitoring (CAM) Plan 

PROCESS/OPERATIONAL RESTRICTION(S) 

Plant ID: 0072 

1. The thermal oxidizer used to control VOC emissions from the coating operations shall be 

operated to maintain a combustion chamber temperature of no more than 50 degrees 

Fahrenheit below the average combustion temperature during the most recent acceptable 

performance test and shall have a minimum design retention time of 0.5 seconds. The 

minimum temperature requirement may be based upon a 3 hour average. 

(64.6( c)(1)(i),(ii)) 

2. The carbon adsorber used to control VOC emissions from the coating operations shall be 

operated to maintain a desorption gas inlet temperature of no more than 15 degrees 

Fahrenheit below the average desorption gas inlet temperature during the most recent 

acceptable performance test. The minimum temperature requirement may be based upon 

a 3 hour average. (64.6(c)(1)(i),(ii)) 

3. When relying on add-on control devices to demonstrate compliance with the emission 

requirements of this permit (i.e., control efficiency credit), the permittee may use nonzero control efficiencies for any period of time in which a deviation or excursion 

(including a deviation during startup, shutdown, or malfunction) from an operating limit 

occurs. If compliance with the emission limits is achieved, then no enforceable deviation 

or excursion will have occurred. (64.6(b)) 

MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. 

1. 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. ( 64.6( c )(1 )(i),(ii)) 

2. Temperature measurements of the concentrator desorption gas inlet shall be made and 

recorded at least once every 15 minutes during operation of the associated coating 

operations. ( 64.6( c )(1 )(i),(ii)) 

3. If coating operations can continue operating during a control device bypass, the bypass 

shall be monitored such that the valve or closure method cannot be opened without 

creating an alarm condition for which a record shall be made. Records of the bypass line 

that was open and the length of time the bypass was open during operation of the 

associated coating operations shall be kept on file. (64.3(a)(2)) 

4. The CAM O&M plan shall be updated as necessary to reflect any necessary changes. All 

records and activities associated with the O&M plan shall be kept on file for a period of 

SCH Page 127 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

at least five years. (64.6(c)(l)(i),(ii), 64.7(e)) 

REPORTING 

1. Each quarterly report for monitoring and deviations shall identify the number, duration 

and cause of any excursions of these requirements and the corrective actions taken. If 

there were no excursions in the reporting period, then this report shall include a statement 

that there were no excursions. (40 CFR 64.9(a)(2)(i)) 

OTHER REQUIREMENT(S) 

For the purposes of Compliance Assurance Monitoring (CAM), excursions will be 

defined as follows: (64.6(c)(2)) 

a. A temperature excursion is defined as a confirmed three-hour period during which 

the average fails to meet the specified temperature requirements. 

b. A monitoring excursion is defined as a failure to properly monitor as required. 

c. A monitoring excursion can also be defined as failure to properly implement 

and/or maintain the O&M plan. 

Elements of an O&M plan- CAM 

General - Keep records of maintenance inspections which include the dates of the inspections 

and the dates and reasons for repairs if made. The following items shall be addressed in an 

O&M Plan for each respective control device used to demonstrate compliance with applicable 

VOC emissions limits. 

RTO's 

• Validation of operation of each thermocouple a minimum of once every 12 months or 

thermocouple replacement. 

• *Perform a heat exchange/heat transfer media inspection a minimum of once every 18 

months, or 

• *Perform an inspection of the valve seals condition once every 18 months and verify 

valve timing/synchronization through visual observation (or through an alarm system) 

once every 18 months. 

Carbon Adsorbor 

• Validation of operation of each thermocouple a minimum of once every 12 months or 

thermocouple replacement. 

• Perform semi-annual observations to confirm that the carbon adsorbor is rotating (if a 

rotary carbon adsorbor) and that the desorption fan is operating. 

• *Perform internal observation of adsorbent materials for contamination and erosion a 

minimum of once every 18 months. 

SCH Page 128 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

• Observe and record the pressure drop across the carbon adsorbor a minimum of once 

every calendar quarter. 

* This requirement is satisfied if a performance test (i.e., stack test) has been performed. 

SCH Page 129 of 130 03-31-2011 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Attachment A: 

Processes Added/Removed/Modified from Compliance 

Ford Motor Company Louisville Assembly Plant 

This sheet covers the period from _______ to ______ _ 

Emission Point 

(Note 1) 

Equipment 

Description 

(Note 1) 

Change Category 

(Note 1) 

Equipment 

Action (Note 2) 

Date of Action 

(Note 3) 

Note 1: 

Note 2: 

Note 3: 

SCH 

Description of equipment being added/removed/modified including emission 

point identification and category of change. This log shall include any 

equipment/process that is added or removed from the calculation of annual 

emtsswns. 

Any equipment being added, removed, or modified form the emissions must be 

listed. 

If equipment is being added, list date of commencement of operation (including 

startup). If equipment is being removed, list date of removal from installation. 

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

Louisville Metro Air Pollution Control District 

850 Barret Ave., Louisville, Kentucky 40204 

March 31, 2011 

Title V Statement of Basis 

Company: Ford Motor Company-Louisville Assembly Plant 

Plant Location: 2000 Fern Valley Road, Louisville, Kentucky 40213 

Plant ID: 0072 

Date Application Received: 07 August 2008 Application Number: 11042 

Date of Proposed Permit: 03/31/2011 

District Engineer: Shannon Clemons Hosey Permit No: 147-97-TV (R2) 

Plant ID: 0072 SIC Code: 3711 NAICS: 336112 AFS: 00072 

Introduction: 

This permit will be issued pursuant to: (1) Regulation 2.16, (2) Title 40 of the Code of Federal 

Regulations Part 70, and (3) Title V of the Clean Air Act Amendments of 1990. Its purpose is to 

identify and consolidate existing District and Federal air requirements and to provide methods of 

determining continued compliance with these requirements. 

Jefferson County is classified as an attainment area for lead (Pb ), sulfur dioxide (S02), nitrogen 

dioxide (N02), carbon monoxide (CO), 1 hr and 8 hr ozone (03), and particulate matter less than 

10 microns (PM10); and is a non-attainment area for particulate matter less than 2.5 microns 

(PM2.s). 

Application Type/Permit Activity: 

[ ] Initial Issuance 

[ ] Permit Revision 

[ ] Administrative 

[ ] Minor 

[ ] Significant 

[ ] Permit Renewal 

[X] Construction 

Compliance Summary: 

[X] Compliance certification signed 

[ ] Source is out of compliance 

[ ] Compliance schedule included 

[X] Source is operating in compliance 
Permit No: 147-97-TV (R2) Plant ID: 0072 

I. Source Information 

SCH 

1. Product Description: Manufacture of automobiles. 

2. Process Description: Vehicle bodies are assembled and primed in the body shop. 

A variety of sealers are applied to the bodies which are then painted. Wax is 

applied to certain body parts. Next, windshields and back lights are installed, then 

a structural adhesive is used to bond glass to the bodies. 

3. Site Determination: There are no other facilities that are contiguous or adjacent 

and under common control. 

4. Emission Unit Summary: 

Emission Unit Equipment Description 

U002-U004 Five (5) Boilers 

U008 Volatile Organic Liquid Storage Tanks 

U009 Glass Installation 

UOlO E-Coat Operation 

UOll Guidecoat Operation 

U012 Topcoat Operation 

U013 Plant-wide Product Fueling 

U014/U022 Paint Equipment Cleaning Operation 

U015 Sealer Deck 

U016 Final Repair Spray Booth 

U023 Phosphate Operation 

U025 Twelve (12) Direct Heat Exchangers 

5. Fugitive Sources: There are no fugitive emissions. 

6. Permit Revisions: 

2 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Public 

Revision Issue Notice Attachment 

No. Date Date Type N o./Page No. Description 

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

Issuance 

R1 9/17/2010 7/19/2010 Initial/ Entire Permit 5 year Renewal; 

Renewal Incorporate PAL, 

STAR TAC 

requirements, RO 

change, DRE for 

E-coat control 

device change 

and 112(1) Part 1 

& 2 applications. 

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

Revision and 50 include permit 

229-96-0, add 

NOxRACT 

language and 

correct Methanol 

Tank Vapor 

Pressure 

7. Emission Summary: 

Pollutant that triggered 

Actual Emissions (tpy) Major Source Status 

Pollutant 2008 Data (based on PTE) 

co 32.02 Yes 

NOx 38.11 Yes 

so2 0.23 No 

PM 3.77 No 

voc 273.0 Yes 

Single HAP > 1 tpy 

SCH 3 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Pollutant that triggered 

Actual Emissions (tpy) Major Source Status 

Pollutant 2008 Data (based on PTE) 

Methanol 2.43 Yes 

Xylene 9.1 Yes 

Toluene 1.93 Yes 

Ethylbenzene 1.84 Yes 

Total HAPs 21.78 Yes 

8. Applicable Requirements: 

[X] PSD 

[ ] NSR 

[X] NSPS [X] SIP [X] MACT 

[ ] NESHAPS [X] District-Origin [ ] Other 

9. Future MACT Requirements: The federal regulation 40 CFR 63, Subpart 

DDDDD has been vacated since June 8, 2007, therefore the boiler MACT 

requirements will not be included in this permit. 

10. Referenced Federal Regulations in Permit: 

40 CFR 63 Subpart IIII 

40 CFR 63 Subpart De 

40 CFR 63 Subpart EEEE 

40 CFR 60 Subpart MM 

40 CFR 63 Subpart ZZZZ 

National Emission Standards for Hazardous 

Air Pollutants - Surface Coating of 

Automobile and Light Duty Trucks 

Standards ofPerformance for Small 

Industrial-Commercial-Institutional Steam 

Generating Units 

Organic Liquids Distribution Operations 

National Emission Standards of 

Performance for Automobile and Light Duty 

Truck Surface Coating Operations 

National Emissions Standards for Hazardous 

Air Pollutants for Stationary Reciprocating 

Internal Combustion Engines 

II. Regulatory Analysis 

1. Acid Rain Requirements: The source is not subject to the Acid Rain Program. 

SCH 4 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

2. Stratospheric Ozone Protection Requirements: Title VI of the CAAA regulates 

ozone depleting substances and requires a phase-out of their use. This rule applies 

to any facility that manufactures, sells, distributes, or otherwise uses any of the 

listed chemicals. This source does not manufacture, sell, or distribute any of the 

listed chemicals. The source's use of listed chemicals is that in fire extinguishers, 

chillers, air conditioners and other HV AC equipment. 

3. Prevention of Accidental Releases 112(r): The source does not manufacture, 

process, use, store, or otherwise handle one or more of the regulated substances 

listed in 40 CFR Part 68, Subpart F, and District Regulation 5.15, Chemical 

Accident Prevention Provisions, in a quantity in excess of the corresponding 

specified threshold amount. 

4. Basis of Regulation Applicability 

a. Plant-wide 

The source is subject to a plant-wide PAL limit of 1316 tons of VOC 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 21.2 tons of PM during 

any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 21.2 tons of PMw 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 17.2 tons of PM2.s 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 99 tons ofNOx during 

any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 39.33 tons of S02 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 151.4 tons of CO 

during any consecutive 12-month period. 

Regulations 5.01, 5.21, and 5.23 (STAR Program) establishes 

requirements for environmental acceptability of toxic air contaminants 

(TACs) and the requirement to comply with all applicable emission 

standards. 

5 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

PIPE 

E02A 

E04A 

E04B 

E05 

SCH 

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.) 

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 ofnatural gas. (Regulation 5.01, section 1.6.7) 

b. Emission Unit U002-U004- Five Boilers 

1. Equipment: 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

Boilers with heat generating capacities greater 

6.07 than 1 mmbtu/hr, modified before April9,1972, 

146 MMBtu/hr 1954 are subject to Regulation 6.07 for PM and S02. 

Boilers emitting large amounts ofNOx are 

6.42 subject to Regulation 6.42 for major nitrogen 

oxides emitting facilities. 

7.06 Boilers with heat generating capacities greater 

6.42 than 1 mmbtu/hr, modified after April9,1972, are 

63.6 MM Btu/hr 1995 subject to Regulation 7.06 for PM and S02. 

40 CFR60 

Subpart DC Boilers emitting large amounts ofNOx are 7.06 subject to Regulation 6.42 for major nitrogen 

6.42 oxides emitting facilities. 

63.6 MMBtu/hr 1995 

Standards ofPerformance for Small Industrial- 40 CFR60 

Subpart DC Commercial-Institutional Steam Generating 

Units 

Boilers with heat generating capacities greater 

7.06 than 1 mmbtu/hr, modified after April9,1972, are 

33.5 MM Btu/hr subject to Regulation 7.06 for PM and S02. 

each 1996 

40 CFR60 Standards ofPerformance for Small IndustrialSubpart DC Commercial-Institutional Steam Generating 

Units 

6 of 36 03-31-2010 
PermitNo: 147-97-TV(R2) PlantiD: 0072 

SCH 

11. Standards/Operating Limits 

a. PM 

i. See Permit 245-09-C (R1) PAL limits. 

11. The emission standard for PM is determined in 

accordance with Regulation 6.07, section 3.1 and 

7.06, section 4.1.4 

b. Opacity 

Regulation 6.07, section 3.2 and 7.06, section 5.1.1 

establishes an opacity standard of less than 20%. 

c. S02 

1. See Permit 245-09-C (R1) PAL limits. 

ii. For Emission Point E02A the emission standard for 

S02 is determined in accordance with Regulation 

6.07, section 4.1. 

iii. For Emission Point E04A, E04B and E05 the 

emission standard for so2 is determined m 

accordance with Regulation 7 .06, section 5 .1.1. 

IV. Emission Points E04A, E04B and E05 are subject to 

40 CFR 60, Subpart De. However, there is no S02 

emission standard for natural gas fired boilers in 

Subpart De. 

d. NOx 

Regulation 6.42 requires the owner or operator shall not 

allow the NOx emissions to exceed 99 tons during any 

consecutive 12-month period in order to avoid NOx RACT. 

111. Monitoring 

a. PM 

Maintain records of monthly natural gas and/or other fuel 

usage. 

7 of 36 03-31-2010 
Permit No: 147-97-TV (R2) 

b. 

Plant ID: 0072 

Opacity 

Regulation 6.07 and 7.06 does not require any specific 

monitoring requirements for opacity, however, Regulation 

2.16, section 4.1.9.1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions 

of the permit. 

c. S02 

Regulation 6.07 and 7.06 does not require any specific 

monitoring requirements for S02, however, Regulation 

2.16, section 4.1.9 .I. requires sufficient monitoring to 

assure compliance with the terms and conditions of the 

permit. 

d. NOx 

Maintain records of monthly fuel usage, and use AP-42 

emission factors and/or fuel analysis data, to calculate 

monthly emissions. 

iv. Record Keeping 

SCH 

a. PM 

See PM Monitoring. 

b. Opacity 

Regulation 6.07 and 7.06 does not require any specific 

record keeping requirements for opacity, however, 

Regulation 2.16, section 4.1.9.2. requires sufficient record 

keeping to assure compliance with the terms and conditions 

of the permit. 

c. S02 

40 CFR 60, Subpart De requires records of the amount of 

fuel combusted each month. Regulation 6.07 and 7.06 does 

not require any specific record keeping requirements for 

S02, however, Regulation 2.16, section 4.1.9.2. requires 

8 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

PIPE 

E08A Methanol 

Tank 

SCH 

sufficient record keeping to assure compliance with the 

terms and conditions of the permit. 

d. NOx 

The source shall calculate and record the monthly and 12 

consecutive month plant-wide NOx emissions for each 

month in the report period. 

v. Reporting 

a. PM 

Regulation 2.16, section 4.1.9 .3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. The source shall report any 

deviations from the permit. 

b. Opacity 

Regulation 2.16, section 4.1.9.3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. 

c. S02 

There are no periodic compliance reporting requirements 

for S02. 

d. NOx 

Regulation 2.16, section 4.1.9.3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. 

c. Emission Unit U008- Volatile Organic Liquid Storage Tanks 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

6,000 2002 7.12 VOC storage tanks greater than 

250 gallon capacity are subject 

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

PIPE 

E08G UG Solvent 

Tank 

E08M Anti-Freeze 

Tank 

E08NPower 

Steering Fluid Tank 

E080 Brake Fluid 

Tank 

E08P Diesel Fuel 

Tank 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

10,000 1986 7.12 

to Regulation 7.12 for VOC 

which were installed after April 

19, 1972. 

20,000 1990 7.12 

20,000 1990 7.12 

6,000 1980 7.12 

20,000 After 1972 7.12 

11. Standards/Operating Limits 

voc 

1) Regulation 7.12, section 3.3 requires submerged fill if the 

materials have an as stored vapor pressure of 1.5 psia or 

greater. Regulation 7.12 applies due to the size of the tanks, 

however, since the vapor pressure as stored is less than 1.5 

psia there are no applicable emission or equipment 

standards. 

2) See Permit 245-09-C (R1) PAL limits 

111. Monitoring 

voc 

The source is required to monitor and 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. 

IV. Record Keeping 

voc 

The source shall maintain records of the material stored in each 

storage vessel. If the contents of the storage vessels are changed, a 

10 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

record shall be made of the new contents, the new vapor pressure, 

and the date of the change in service. 

v. Reporting 

voc 

There are no Emission Unit specific compliance reporting 

requirements for the tanks. The source is required to report the 

throughput for purposes of demonstrating ongoing compliance 

with the plant-wide PAL VOC emission limit. 

d. Emission Unit U009- Glass Installation 

PIPE 

E009 Glass, Windshield, 

and Back Lights 

Installation 

SCH 

1. Equipment: 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

The glass installation operation 

N/A 1994 7.59 

is subject to the VOC emission 

standard in Regulation 7.59 and 

was installed after September 

1, 1976. 

11. Standards/Operating Limits 

voc 

1) Regulation 7.59, section 3.1.3 requires the source shall not 

cause or allow the emission of VOC 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. 

2) See Permit 245-09-C (Rl) PAL limits 

111. Monitoring 

voc 

11 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Regulation 2.16, section 4.1.9 .I. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

IV. Record Keeping 

voc 

1) Regulation 7.59, section 6.1 and Regulation 2.16, section 

4.1.9.2. requires sufficient record keeping to assure 

compliance with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9 .2. requires the source to 

monitor the plant-wide VOC emissions during each 

consecutive 12-month period to assure the emissions of 

VOC remain below the plant-wide PAL limit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9.3. requires sufficient reporting 

requirements to assure compliance with the terms and conditions 

of the permit. 

e. Emission Unit UOlO- E-Coat Operation 

1. Equipment 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

40 CFR 63 Subpart Subpart IIII Hazardous Air 

IIII Pollutants: Surface Coating of 

E 1 OA E-Coat Dip N/A 1996 Automobiles and Light. 

Tank 

40 CFR 60 Subpart 

MM 

40 CFR 63 Subpart Subpart MM establishes standards 

for National Emission Standards of 

IIII Performance for Automobile and 

E10B E-Coat Oven N/A 1988 Light Duty Truck Surface Coating 40 CFR 60 Subpart 

MM Operations. 

SCH 12 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

E10C E-Coat Oven 

(3'd Pass) 

E10D E-Coat Dump 

Metal AST 

E 17 A E-Coat Scuff 

Booth 

SCH 

40 CFR 63 Subpart 

IIII 

N/A 1996 

40 CFR 60 Subpart 

MM 

40 CFR 63 Subpart 

IIII 

N/A 1996 

40 CFR 60 Subpart 

MM 

For Regulation 7.08 the scuff 

NIA 1989 booth is subject to PM emission 

7.08 standard and was installed after 

September 1, 1976. 

ii. Standards/Operating Limits 

a. VOC 

1) The E-Coat Operation is subject is subject to 40 

CPR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CPR 

60, Subpart MM - National Emission Standards of 

Performance for Automobile and Light Duty Truck 

Surface Coating Operations section 60.392 emission 

limits. 

2) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3.1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

c. Opacity 

Regulation 7 .08, section 3 .1.2. establishes an opacity 

standard of less than 20%. 

13 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

iii. Monitoring 

a. VOC 

40 CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Truck Surface 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

iv. Record Keeping 

a. VOC 

40 CFR Part 60, Subpart MM - National Emission 

Standards of Performance for Automobile and Light Duty 

Truck Surface Coating Operations sections 60.3095 and 40 

CFR Part 63 - Surface Coating of Automobiles and Light 

Duty Trucks establishes record keeping requirement. 

Regulation 2.16, section 4.1.9.2 establishes record keeping 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

See PM Monitoring. 

14 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9 .3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

f. Emission Unit UOll- Guidecoat Operation 

i. Equipment: 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

EllA Guidecoat Subpart IIII Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

Paint Booth and Air N/A 1988 IIII Automobiles and Light-Duty Supply Hose Trucks 

SCH 15 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Subpart NIM National Emission 

40 CFR 60 Subpart Standards ofPerformance for 

MNI Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

E11B Touchup and N/A 1988 September 1, 1976. 

Blackout Booth The guidecoat operation is subject 

7.59 to the VOC emission standard in 

Regulation 7.59 and was installed 

after September 1, 1976. 

40 CFR 63 Subpart Subpart IIII Hazardous Air 

III! Pollutants: Surface Coating of 

EllC Guidecoat 40 CFR 60 Subpart Automobiles and Light-Duty 

Ovens (1st and znd N/A 1988 MM Trucks 

Pass) 

7.08 Subpart MM National Emission 

Standards of Performance for 

40 CFR 63 Subpart Automobile and Light Duty Truck 

Surface Coating Operations IIII establishes standards. 

EllD Guidecoat N/A 1988 

40 CFR 60 Subpart 

Oven (3'd Pass) MM For Regulation 7.08 the equipment 

is subject to PM emission standard 

7.08 and was installed after September 

1, 1976. 

40 CFR 63 Subpart Subpart !III Hazardous Air 

III! Pollutants: Surface Coating of 

Automobiles and Light-Duty 

Trucks 

E11E/E12G 

Guidecoat/Topcoat N/A 1988 Subpart MM National Emission 

Paint Kitchen 40 CFR 60 Subpart Standards ofPerformance for 

MM Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

ElSA Guidecoat N/A 1989 7.08 

booth is subject to PM emission 

Scuff Booth standard and was installed after 

September 1, 197 6. 

SCH 16 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

ii. Standards/Operating Limits 

a. VOC 

1) The Guidecoat Operation is subject to 40 CFR Part 

63, Subpart IIII - Surface Coating of Automobiles 

and Light-Duty Tmcks and 40 CFR 60, Subpart 

MM - National Emission Standards of Performance 

for Automobile and Light Duty Tmck Surface 

Coating Operations section 60.392 emission limits. 

2) Regulation 7.59, section 3.1.3 requires the source 

shall not cause or allow the emission of VOC from 

any affected facility resulting from the coating of 

metallic surfaces in excess of 0.42 kg ofVOC/1 (3.5 

lb of VOC/gal) of coating, excluding water and 

exempt solvents, as applied for extreme 

performance coatings. 

3) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7 .08, 

section 3 .1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

c. Opacity 

Regulation 7 .08, section 3 .1.2. establishes an opacity 

standard of less than 20%. 

iii. Monitoring 

a. VOC 

40 CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Tmck Surface 

17 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

IV. Record Keeping 

SCH 

a. VOC 

1) 40 CPR Part 60, Subpart MM -National Emission 

Standards of Performance for Automobile and Light 

Duty Truck Surface Coating Operations sections 

60.3095 and 40 CPR Part 63 - Surface Coating of 

Automobiles and Light-Duty Trucks establishes 

record keeping requirement. Regulation 2.16, 

section 4.1.9.2 establishes record keeping 

requirements to assure ongoing compliance with the 

terms and conditions of the permit. 

2) Regulation 7.59, section 6.1 and Regulation 2.16, 

section 4.1.9.2. requires sufficient record keeping to 

assure compliance with the terms and conditions of 

the permit. 

b. PM 

See PM Monitoring. 

c. Opacity 

18 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9 .3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity. 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

g. Emission Unit U012- Topcoat Operation 

1. Equipment: 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

E12A North Main September 1, 1976. 

The topcoat operation is subject to Enamel Booth and N/A 1985 the VOC emission standard in Air Supply 7.59 Regulation 7.59 and was installed 

after September 1, 1976. 

40 CFR 63 Subpart Subpart IIII Hazardous Air 

IIII Pollutants: Surface Coating of 

SCH 19 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Automobiles and Light-Duty 

Trucks 

Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

Automobile and Light Duty Truck MM Surface Coating Operations 

establishes standards. 

Subpart Illi Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

IIII Automobiles and Light-Duty 

Trucks 

E12B North Main N/A 1985 Enamel Oven Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

MM Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

Subpart IIII Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

E12C South Main N/A 1985 IIII Automobiles and Light-Duty 

Enamel Booth Trucks 

Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

Automobile and Light Duty Truck MM Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

E12D Air Supply and September 1, 1976. 

Oven N/A 1985 Subpart MM establishes standards 

for National Emission Standards of 

40 CFR 60 Subpart Performance for Automobile and 

MM Light Duty Truck Surface Coating 

Operations. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

E12F Air Supply September 1, 1976. 

N/A 1985 House and Oven Subpart MM establishes standards 

40 CFR 60 Subpart for National Emission Standards of 

Performance for Automobile and MM Light Duty Truck Surface Coating 

Operations. 

SCH 20 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

E11E/E12G 

Guidecoat/Topcoat 

Kitchen 

E12H Topcoat Scuff 

Booth 

E12I TuTone/Repair 

Scuff Booth 

SCH 

Subpart MM establishes standards 

for National Emission Standards of 

N/A 1988 40 CFR 60 Subpart Performance for Automobile and MM Light Duty Truck Surface Coating 

Operations. 

For Regulation 7.08 the scuff 

N/A 1985 7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

For Regulation 7.08 the scuff 

N/A 1985 7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

ii. Standards/Operating Limits 

a. VOC 

1) The Topcoat Operation is subject is subject to 40 

CPR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CPR 

60, Subpart MM - National Emission Standards of 

Performance for Automobile and Light Duty Truck 

Surface Coating Operations section 60.392 emission 

limits. 

2) Regulation 7.59, section 3.1.3. requires the source 

shall not cause or allow the emission of VOC from 

any affected facility resulting from the coating of 

metallic surfaces in excess of0.42 kg ofVOC/1 (3.5 

lb of VOC/gal) of coating, excluding water and 

exempt solvents, as applied for extreme 

performance coatings. 

3) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3 .1.2. The equation to calculate the emission 

21 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

limits is E 

tons/hr. 

3.59P0

·

62, where P is expressed in 

2) See Permit 245-09-C (Rl) PAL limits 

c. Opacity 

Regulation 7 .08, section 3 .1.2. establishes an opacity 

standard of less than 20%. 

iii. Monitoring 

a. VOC 

40 CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Truck Surface 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9.1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

iv. Record Keeping 

a. VOC 

1) 40 CFR Part 60, Subpart MM -National Emission 

Standards of Performance for Automobile and Light 

Duty Truck Surface Coating Operations sections 

60.3095 and 40 CFR Part 63 - Surface Coating of 

22 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Automobiles and Light-Duty Trucks establishes 

record keeping requirement. Regulation 2.16, 

section 4.1.9 .2 establishes record keeping 

requirements to assure ongoing compliance with the 

terms and conditions of the permit. 

2) Regulation 7.59, section 6.1 and Regulation 2.16, 

section 4.1.9.2. requires sufficient record keeping to 

assure compliance with the terms and conditions of 

the permit. 

3) Regulation 2.16, section 4.1.9 .1 requires the source 

to monitor the plant-wide VOC emissions during 

each consecutive 12-month period to assure the 

emissions of VOC remain below the plant-wide 

PAL limit. 

b. PM 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

SCH 

a. VOC 

Regulation 2.16, section 4.1.9 .3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

23 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

g. Emission Unit U013 -Plant-wide Product Fueling 

PIPE 

E13A Gasoline 

Tank#1 

EBB Gasoline 

Tank#2 

E13C Gasoline 

Tank#3 

E13D Two Fueling 

Stations with Vapor 

Recovery 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

Standards of Performance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

Standards ofPerformance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

Standards ofPerformance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

N/A 1994 7.25 OR VR Equipped Vehicles 

11. Standards/Operating Limits 

voc 

Regulation 7.15 requires that storage tanks shall be equipped with 

the following: 

a. A submerged fill pipe; 

b. If the gasoline storage tank is equipped with a separate 

gauge well, a gauge well drop tube shall be installed which 

extends to within six inches of the bottom of the tank; 

c. Vent line restrictions on the affected facility; and 

24 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

d. Vapor balance system and vapor tight connections on the 

liquid fill and vapor return hoses. The cross-sectional area 

of the vapor return hose and any other vapor return 

passages in the circuit connecting the vapor space in the 

service station tank to that of the truck tank must be at least 

50% of the liquid fill hose cross-sectional area for each 

tank and free of flow restrictions to achieve acceptable 

recovery. The vapor balance equipment must be 

maintained according to the manufacturer's specifications. 

The type, size and design of the vapor balance system are 

subject to the approval of the District. 

111. Monitoring 

voc 

Regulation 7.15 does not require any specific monitoring 

requirements for VOC, however, Regulation 2.16, section 4.1.9.1. 

requires sufficient monitoring to assure ongoing compliance with 

the terms and conditions of the permit. 

iv. Record Keeping 

voc 

Regulation 7.15 does not require any specific record keeping 

requirements for VOC, however, Regulation 2.16, section 4.1.9.2. 

requires sufficient record keeping to assure ongoing compliance 

with the terms and conditions of the permit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9.3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

25 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

h. Emission Unit U014/U022- Paint Equipment Cleaning Operation 

PIPE 

E14 Paint 

Equipment 

Cleaning Booth 

E22APaint 

Equipment Purging 

and Plant Cleaning 

Solvent Metal 

Cleaning 

Equipment 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

This regulation applies to 

each existing auto and truck 

manufacturing facility which 

N/A 1985 7.25 was in being or had a 

construction permit issued by 

the District before June 13, 

1979 

This regulation applies to 

each existing auto and truck 

manufacturing facility which 

N/A 1976 7.25 was in being or had a 

construction permit issued by 

the District before June 13, 

1979 

Standards ofPerformance for 

Gasoline Transfer to New 

N/A N/A 6.18 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

ii. Standards/Operating Limits 

voc 

1) The source shall follow the procedure below to minimize 

VOC emissions from purge and cleaning operations under 

Regulation 7.25, section 3. 

2) For all cold solvent parts washers, the source shall comply 

with the standards of Regulation 6.18, sections 4.1 through 

4.3. 

111. Monitoring 

voc 

Regulation 2.16, section 4.1.9 .1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

IV. Record Keeping 

26 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

voc 

Regulation 2.16, section 4.1.9.2. requires sufficient record keeping 

to assure ongoing compliance with the terms and conditions of the 

permit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9 .3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

i. Emission Unit U015- Sealer Deck 

PIPE 

ElSA Sealer 

Application 

Sealers and 

Deadeners (other 

than glass bonding) 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

The sealer operation is 

subject to the VOC emission 

N/A 1994 7.59 standard in Regulation 7.59 

and was installed after 

September 1, 1976. 

Subpart IIII establishes 

40 CFR 63 Subpart standards for Hazardous Air 

N/A N/A Pollutants: Surface Coating IIII of Automobiles and LightDuty Trucks 

11. Standards/Operating Limits 

voc 

1) Regulation 7.59, section 3.1.3. requires the source shall not 

cause or allow the emission of VOC from any affected 

facility resulting from the coating of metallic surfaces in 

excess of 3.5 lb VOC/gal of coating, excluding water and 

exempt solvents, as applied for extreme performance 

coatings. 

2) See Permit 245-09-C PAL limits 

27 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

iii. Monitoring 

voc 

Regulation 2.16, section 4.1.9 .1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

iv. Record Keeping 

voc 

1) Regulation 7.59, section 6.1 and Regulation 2.16, section 

4.1.9 .2. requires sufficient record keeping to assure 

compliance with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9.2. requires the source to 

monitor the plant-wide VOC emissions during each 

consecutive 12-month period to assure the emissions of 

VOC remain below the plant-wide PAL limit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9.3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

j. Emission Unit U016- Final Repair Spray Booth; infrared curing, and spot repair 

bays for repairing coating on vehicles 

Installation Applicable 

PIPE Capacity Date Regulation Basis for Applicability 

7.08 For Regulation 7.08 the scuff 

booth is subject to PM 

40 CFR 63 Subpart emission standard and was E16A Final Repair N/A 1982 IIII installed after September 1, 

Booth 1976. 

40 CFR 60 Subpart 

MM 

Subpart IIII establishes 

E16B Final Repair 

N/A 1982 7.08 standards for Hazardous Air 

Oven Pollutants: Surface Coating 

SCH 28 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

PIPE 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

40 CFR 63 Subpart of Automobiles and LightIIII Duty Trucks 

Subpart MM establishes 

40 CFR 60 Subpart 

standards for National 

Emission Standards of 

MM Performance for Automobile 

and Light Duty Truck 

Surface Coating Operations. 

11. Standards/Operating Limits 

a. VOC 

1) TheE-Coat Operation is subject to 40 CPR Part 60, 

Subpart IIII - Surface Coating of Automobiles and 

Light-Duty Trucks. 40 CPR 60, Subpart IIII section 

60.392 emission limits. 

2) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3 .1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

c. Opacity 

Regulation 7.08, section 3.1.2. establishes an opacity 

standard of less than 20%. 

iii. Monitoring 

a. VOC 

29 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

40 CPR Part 60, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks sections 60.392 

establishes monitoring requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

iv. Record Keeping 

SCH 

a. VOC 

1) 40 CPR Part 60, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks sections 

60.395 establishes record keeping requirement. 

Regulation 2.16, section 4.1.9 .2. establishes record 

keeping requirements to assure ongoing compliance 

with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9.2. requires the source 

to monitor the plant-wide VOC emissions during 

each consecutive 12-month period to assure the 

emissions of VOC remain below the plant-wide 

PAL limit. 

b. PM 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

30 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9 .3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions ofthe permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires repmting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

k. Emission Unit U025- Twelve (12) Direct Heat Exchangers 

ID 

E25 

SCH 

U025 Emission Points 

Description Applicable Regulation Control Device 

6.42 

Direct Heat Exchangers 

7.08 

N/A 

ii. Standards/Operating Limits 

a. PM 

The PM limits are calculated per Regulation 7.08, section 

3 .1.2. The equation to calculate the emission limits is E = 

31 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

3.59P0

·

62, where Pis expressed in tons/hr. The maximum 

throughput is less than 1,000 pounds per hour; therefore, 

the PM emission standard is 2.34 lb/hr. 

b. Opacity 

Regulation 7. 08, section 3 .1.1. establishes an opacity 

standard of less than 20%. 

c. NOx 

Per Regulation 6.42, the owner or operator shall not allow 

or cause the plant-wide NOx emissions to equal or exceed 

100 tons during any consecutive 12-month period in order 

to avoid NOx RACT. 

iii. Monitoring 

IV. 

SCH 

a. PM 

There are no compliance monitoring requirements for this 

equipment. The potential uncontrolled PM emissions are 

less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

c. NOx 

a. 

Regulation 7.08 does not require any specific monitoring 

requirements for NOx, however, Regulation 2.16, section 

4.1.9 .1. establishes monitoring requirements to assure 

ongoing compliance with the terms and conditions of the 

permit. 

Record Keeping· 

PM 

32 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

There are no compliance record keeping requirements for 

this equipment. The potential uncontrolled PM emissions 

are less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.2. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. NOx 

Regulation 7.08 does not require any specific record 

keeping requirements for NOx, however, Regulation 2.16, 

section 4.1.9.2. requires sufficient record keeping to assure 

ongoing compliance with the terms and conditions of the 

permit. 

v. Reporting 

SCH 

a. PM 

There are no routine compliance reporting requirements for 

this equipment. The potential uncontrolled PM emissions 

are less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. NOx 

Regulation 7.08 does not require any specific reporting 

requirements for NOx, however, Regulation 2.16, section 

4.1.9 .3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

33 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

III. Other Requirements 

1. Temporary Sources: The source did not request to operate any temporary 

facilities. 

2. Short Term Activities: The source did not report ant short term activities. 

3. Emissions Trading: N/A 

4. Alternative Operating Scenarios: The source did not request to operate under 

any alternative operating scenarios. 

5. Compliance Status: Ford Motor Company-Louisville Assembly Plant is required 

to submit their annual Compliance Certification to the District on or before April 

15th of each calendar year. As of the effective date of Permit 245-09-C (Rl ), there 

are no compliance schedules in effect or progress reports required. 

6. Insignificant Activities 

Insignificant Activities 

Description Quantity Basis 

Internal combustion engines Various Regulation 2.02, Section 2.2 fixed or mobile 

Presses extruding Various Regulation 2.02, Section 2.3.1 metal/mineral/wood 

Brazing, soldering or Various Regulation 2.02, Section 2.3.4 welding equipment 

Woodworking, except for 

conveying, hogging, or Various Regulation 2.02, Section 2.3.5 

burning wood/sawdust 

Lab venting and exhaust 

systems (non radioactive Various Regulation 2.02, Section 2.3 .11 

materials) 

Ventilation systems - Various Regulation 2.02, Section 2.3.12 bakeries & restaurants 

Washing or drying fabricated metal or glass; non Various Regulation 2.02, Section 2.3.15 

VOC use; no oil or solid fuel 

SCH 34 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

Insignificant Activities 

Description Quantity Basis 

ResidentiaVdomestic Various Regulation 2.02, Section 2.3.12 

equipment 

Portable diesel or gasoline Various Regulation 2.02, Section 2.3.23 storage tanks 

Diesel fuel storage tanks Various Regulation 2.02, Section 2.3.25 (emergency use only) 

Closed pressure storage 2 Regulation 2.02, Section 2.3.26 vessels 

Portable tote tanks for raw Tote tanks are kept closed when not in use. Emission from tanks material shipment of solvent Various 

- based coatings are negligible, and are accounted for by process material balance. 

Backup generators for 

emergency power.(< 500 2 Generators normal use is very low and HP <500 HP. 

hrs/year) 

Wastewater Pretreatment 1 Emissions insignificant system. 

Fluid Fill (hydraulic fluids, Emissions insignificant due to low vapor pressure of materials oil, anti-freeze) and Various 

Lubricating operations. used. 

Miscellaneous mainten-ance 

procedures includ-ing Various Negligible emissions lubrication, grinding, 

cleaning, woodworking, etc. 

Direct heat exchangers <1 Various Regulation 2.02, Section 2.1.1 MMBtu/hr 

a. Insignificant Activities are only those activities or processes falling into the 

general categories defined in District Regulation 2.02, Section 2, and not 

associated with a specific operation or process for which there is a specific 

regulation. Equipment associated with a specific operation or process (Emission 

Unit) shall be listed with the specific process even though there may be no 

applicable requirements. Information contained in the permit and permit 

summary shall clearly indicate that those items identified with negligible 

emissions have no applicable requirements. 

b. Activities identified in District Regulation 2.02, Section 2, may not require a 

SCH 35 of 36 03-31-2010 
Permit No: 147-97-TV (R2) Plant ID: 0072 

SCH 

permit and may be insignificant with regard to application disclosure 

requirements but may still have generally applicable requirements that continue to 

apply to the source. 

c. For all insignificant activities that emit regulated air pollutants for which the 

company has accepted a plant-wide synthetic minor limit, the company shall 

maintain sufficient records to calculate the emissions and report those emissions 

in the quarterly compliance reports and the annual emissions inventory report. 

d. The Insignificant Activities table is correct as of the date the permit was proposed 

for review by the USEPA, Region 4. The company shall submit an updated list of 

insignificant activities annually with the Title V compliance certification pursuant 

to District Regulation 2.16, section 4.3.5.3.6. 

e. In lieu of recording annual throughputs for each Insignificant Activity, the owner 

or operator may elect to report the Potential To Emit quantity listed in the 

Insignificant Activities table as the annual emission for each piece of equipment, 

since the emissions from the source's Insignificant Activities are minor. 

36 of 36 03-31-2010 
Louisville Metro Air Pollution Control District 

850 Barret A venue 

Louisville, Kentucky 40204-17 45 

PAL Construction Permit 

Permit No: 245-09-C (R1) 

Effective Date: 03/3112011 Expiration Date: 07/30/2020 

Plant ID: 0072 

Permit Fee: $0 

Permission is hereby given by the Louisville Metro Air Pollution Control District to construct 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 Regulations 2.03 and 2.05 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: 

Administratively Complete: 

Date of Public Notice: 

Shannon Clemons Hosey 

09/20/2005 and 10/06/2008 

06/11/2010 

-(JoJ)J(kL 

Air Pollution Control Officer 
Permit No: 245-09-C (Rl) 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 ................................................................................................... 4 7 

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 

U010 Emission Unit Description: E-Coat Operation ................................................................... 58 

UOlO Applicable Regulations ........................................................................................... 58 

U010 Emission Points .................................................................................. , .................... 59 

UOlO Control Devices ....................................................................................................... 60 

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

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

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

UOll Applicable Regulations ........................................................................................... 68 

UOll 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: 245-09-C (R1) Plant ID: 0072 

U012 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 

U013 Emission Unit Description: Plant-wide Product Fueling ................................................... 93 

U013 Applicable Regualtions ........................................................................................... 93 

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

U013 Control Equipment .................................................................................................. 94 

UO 13 Specific Conditions ................................................................................................. 95 

U013 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 

U014 and U022 Specific Conditions .............................................................................. 100 

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

UO 15 Emission Unit Description: Sealer Deck ......................................................................... 1 04 

U015 Applicable Regulations ......................................................................................... 104 

U015 Emission Points ..................................................................................................... 105 

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

U015 Specific Conditions ............................................................................................... 106 

U016 Emission Unit Description: Final Repair Spray Booth .................................................... 109 

U016 Applicable Regulations ......................................................................................... 109 

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

U016 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 .............................................................................................................................. 130 

SCH Page 3 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

PAL/Title V Permit Revisions/Changes 

Revision Issue Public Attachment 

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

NA 7/30/2010 6/11/2010 Initial Entire Permit PAL, STAR TAC 

requirements, RO 

change, DRE forE-coat 

control device change 

and 112(J) Part 1 & 2 

applications. 

R1 3/31/2011 NA Admin Pages 43 and Revision to include 

Revision 50 permit 229-96-0 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: 245-09-C (R1) 

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 

I - 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 

PAL 

PM 

- New Source Performance Standards 

- Plant-wide Applicability Limit 

- Particulate Matter 

PM10 - 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: 245-09-C (R1) 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: 245-09-C (R1) 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: 245-09-C (Rl) 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. 

11. 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: 245-09-C (R1) 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 of Regulations 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: 245-09-C (R1) 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 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. 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 

April 1 through June 30 

July 1 through September 30 

October 1 through December 31 

Note: 

1

The date for leap years is February 29. 

Page 10 of 130 

Report Due Date 

May 30th 

August 29th 

November 29th 

March 1st! 

03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 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: 245-09-C (R1) 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 ofRegulation 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 CPR 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 2.1 0. 

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: 245-09-C (R1) 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 of the following: 

I Regulation I Title I 

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 Pollution 

1.10 Circumvention 

1.11 Control of Open Burning 

1.14 Control of Fugitive Particulate Emissions 

2.01 General Application 

2.02 Air Pollution 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: 245-09-C (R1) Plant ID: 0072 

Title 

I 2.10 Stack Height Considerations 

2.11 Air Quality Model Usage 

2.16 Title V Operating Pennits 

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: 

ation Title 

1.12 Control ofNuisances 

1.13 Control of Objectionable Odors 

2.08 Emission Fee, Permit Fees and Pennit 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 CPR 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 CPR 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 CPR 82.34 and 40 CPR 82.40, and properly uses equipment approved 

according to 40 CPR 82.36 and 40 CPR 82.38, and complies with 40 CPR 82.42; 

Page 14 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 CFR 82, Subpart A, Appendices A and B, 

except in compliance with 40 CFR 82.34(b ), 40 CFR 82.42, and/or 40 CFR 

82.166. 

d. No person maintaining, serv1cmg, 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 CFR 82.152) for service, 

maintenance, or repair unless the person has been properly trained and certified 

according to 40 CFR 82.161 and unless the person uses equipment certified for 

that type of appliance according to 40 CFR 82.158 and unless the person observes 

the practices set forth in 40 CFR 82.156 and 40 CFR 82.166; 

e. No person may dispose of appliances (except small appliances, as defined in 40 

CFR 82.152) without using equipment certified for that type of appliance 

according to 40 CFR 82.158 and without observing the practices set forth in 40 

CFR 82.156 and 40 

CFR 82.166; 

f. No person may recover refrigerant from small appliances, MV ACs and MV AClike appliances (as defined in 40 CFR 82.152), except in compliance with the 

requirements of 40 CFR 82 Subpart F; 

g. If the permittee manufactures, transforms, imports, or exports, a Class I or II 

substance (listed in 40 CFR 82, Subpart A, Appendices A and B), the permittee is 

subject to all requirements as specified in 40CFR82 Subpart A, Production and 

Consumption Controls. (Regulation 2.16, section 4.1.5) 

Page 15 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 CPR 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: 245-09-C (R1) 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) 1f 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 Sl.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: 245-09-C (Rl) 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: 245-09-C (R1) 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, PMw, PM2.

5, 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: 245-09-C (R1) 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: 245-09-C (Rl) 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. 

1. Capture Equipment Requirements: 

1) Ford Motor shall evaluate changes that involve em1ss10ns directed to 

emission control equipment where compliance with an applicable 

emission limit or standard is dependent upon the use of the control device 

subject to the change for potential impacts to emission control equipment 

capture efficiency. This evaluation shall include the following: 

i. An impact analysis of the change on the capture efficiency; 

ii. 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 I.e. 

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, 

111. Identifies the specific monitoring procedures, and 

iv. 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: 245-09-C (R1) 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. 

ii. Reduce the PAL to reflect newly applicable Federal and/or State 

requirements with compliance dates after the issuance of this 

construction permit. 

iii. Reduce the PAL if the permitting 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: 245-09-C (Rl) 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 of the 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. 

iii. The PAL shall be adjusted to account for any applicable State or 

Federal requirement with a compliance date that occurs during 

effective period of this 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: 245-09-C (R1) 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: 

i. Identify the emissions units contributing to the increase in 

emissions so as to cause Ford Motor emissions to equal or exceed 

the PAL. 

11. Determine the Best Available Control Technology (BACT) 

equivalent controls for each emission unit using current 

technology. 

111. 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: 245-09-C (R1) 

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, 

PMIPM10/PM2.s, CO, S02 and NOx emissions from startups, shutdowns, and 

malfunctions. 

b. The permittee shall determine monthly VOC, PM/PM10/PM25, 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/PM25, CO, SOz 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 infmmation 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: 245-09-C (R1) Plant ID: 0072 

SCH 

n 

VOC Value= S U; Y; (1- C; 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 = U PDaily 

Daily Monthly P 

Monthly 

Where: 

Uoaily =material usage for a particular calendar day 

UMonthiy = recorded material usage for a particular month 

Poaily = 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: 245-09-C (R1) 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 PM2.5 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 = LUiEF(l Ci) i~l 

Where: 

a= PM subscript for total PM, PMw, or PM2.s 

U = material usage 

EF = emission factor 

C = control efficiency 

i = number of operating months 

h. To demonstrate compliance with annual plant-wide PM/PM10/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 CFR Part 51.166 as the permit is issued prior to January 1, 

2011. 

i. 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: 245-09-C (Rl) Plant ID: 0072 

J. The permittee shall keep documentation of any emissiOn 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 

301h, 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. 

11. 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. 

iv. 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: 245-09-C (Rl) Plant ID: 0072 

v1. 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: 

1. The identification of owner and operator, the facility ID, and the permit 

numbers for any applicable permits; 

11. The PAL requirement that experienced the deviation or the exceedance; 

iii. Emissions resulting from the deviation or the exceedance; and 

iv. 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: 245-09-C (R1) Plant ID: 0072 

SCH 

Carbon Adsorber 

South Main Enamel Booth RTO 

South Main Enamel Oven R TO 

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 this 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 of the control devices; and 

2) Confirm the capture efficiencies of the total or partial enclosures by 

Specific Condition S6.b.1) 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: 245-09-C (Rl) 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: 245-09-C (R1) Plant ID: 0072 

Louisville Assembly Plant, Ford Motor Company Maximum Achievable Control 

Technology (MACT) Requirements: 

40 CFR 63 Subpart 1111- Surface Coating of Automobiles and Light Duty Trucks 

Sl. Standards (Regulation 2.16, section 4.1.1) 

SCH 

HAPs 

a. The permittee shall choose to comply with one of the following HAPs limits: 

i. 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 CFR 63.3091(a)) 

11. 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 CFR 63.3091(b)) 

The permittee may choose to comply with the emission limit specified by 

Sl.b. only ifE-Coat meets either ofthe following requirements. (40 CFR 

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). 

111. 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 
Petmit No: 245-09-C (Rl) 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. 

11. 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. 

1v. 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 S l.a 

and Sl.b. above must be minimized by addressing: 

1) Vehicle body wipe pursuant to 40 CPR 63.3094(c)(l)(i); 

2) Coating line purging pursuant to 40 CPR 63.3094(c)(l)(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 CPR 63.3100(c), 40 CPR 

63.4493(b), and (c)), (40 CPR 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: 245-09-C (R1) 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 hour period must not fall below the limit established Wheels and Rotary according to 40 CFR 63.3167(e). Carbon Adsorbers 

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: 245-09-C (R1) 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 CPR 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 CPR 63.3160. (40 CFR 63.3100(e)) 

S3. Recordkeeping (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 

CPR 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 CPR 

Part 63, Subpart IIII and the documentation supporting each notification and 

report as specified in 40 CPR 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 CPR 

63.3130(c)(l)) 

Page 35 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

SCH 

ii. For each deadener material, and NGB Sealers and Adhesives used, the 

mass used in each month and the mass organic HAP content. ( 40 CPR 

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 CPR 63.3163, 40 CPR 63.3173) 

IV. Calculation of the average monthly mass organic HAP content in pounds 

per pound of coating, separately for deadener materials and NGB Sealers 

and Adhesives. ( 40 CPR 63 .3130( c )(5), 40 CPR 63 .3152) 

v. The name, volume, mass fraction organic HAP content and density of 

each cleaning material used. (40 CPR 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 CPR 63.3130(g) through (n). (40 CPR 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.l 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 CPR 

63.3130( 0 )(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. 

111. 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 CPR 63.3160(c)(1) through (3). (40 CPR 63.3160) 

IV. The permittee shall install, operate and maintain each continuous 

parametric monitoring system in accordance with the applicable 

provisions of 40 CPR 63.3168. ( 40 CPR 63 .3168) 

Page 36 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 CPR 

63.3163 and 40 CPR 63.3173 using the method( s) described below: ( 40 

CPR 63.3163,40 CPR 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 CPR 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 CPR 63.3167(a). temperature at or above 

temperature limit. 

a. Collect the temperature 

Concentrators, The average desorption data according to 40 CPR 

Including Zeolite gas inlet temperature in 63.3168(±); 

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 CPR 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 ofthe following: (40 CPR 63.3168(b)(1)) 

1. Flow control position indicator requirements pursuant to 40 CPR 

63 .3168(b )(1 )(i); 

2. Car-seal or lock-and-key valve closures requirements pursuant to 

40 CPR 63 .3168(b )(1 )(ii); 

3. Valve closure monitoring requirements pursuant to 40 CPR 

63.3168(b )(1 )(iii); 

Page 37 of 130 03-31-2011 
Permit No: 245-09-C (R1) 

4. 

Plant ID: 0072 

Automatic shutdown system requirements pursuant to 40 CPR 

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 CPR 63 .3168(b) 

S4. Reporting (Regulation 2.16, section 4.1.1) 

a. The permittee shall submit applicable notifications specified in 40 CPR 63.7 (b) 

and (c), 63.8(f)(4) and 63.9(b) through (e) and (h), as specified in 40 CPR 

63.311 0. ( 40 CPR 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 CPR 63.3120(c). (40 

CPR 63. 3120(c), 40 CPR 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 CPR 63.3150-3152,40 CPR 63.3160-3161, 

40 CPR 63.3163-3168, 40 CPR 63.3170-3171, and 40 CPR 63.3173. (40 CPR 

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 CPR 

63.3151(a)(1) 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 CPR 63.3151(a)(3) and 40 CPR 63.7. (40 CPR 

63.7, 40 CPR 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 CPR 

63.3120(b). (40 CPR 63.3120(b)) 

Page 38 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 CPR Part 63 Subpart EEEE 

and shall ensure compliance with those requirements. (40 CPR 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 CPR §63.2406 and 

Table 1 of 40 CPR 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 ofthe tank and the capacity ofthe tank (in gallons), 

11. The tank contents 

111. The annual average true vapor pressure of the total organic hazardous air pollutant 

in the organic liquid (as defined under 40 CPR §63.2406 and Table 1 of 40 CPR 

Part 63 Subpart EEEE). (40 CPR 63.2343(b)) 

c. These records must be kept up-to-date and available for inspection. (40 CPR 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 CPR 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 CPR 63.2343(b) and 63.2386): 

SCH 

1. Company name and address. 

ii. 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 CPR Part 63 

Subpart EEEE) is below 4.0 psia. 

Page 39 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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. 

11. The permittee installs a new affected storage tank with a capacity equal to or 

greater than 5,000 gallons. 

iii. 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 reporting 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: 245-09-C (R1) 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://vvww.louisvilleky.gov/NR/rdonlyres/121AAADA-9838-4057-ADFC88CD95Al4937/0/BAC Worksheet.pdf 

Page 41 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 

7.06 Standards of Performance for New Indirect Heat 1 through 4 Exchangers 

40 CPR 60 General Provisions 60.1 through 

Subpart A 60.18 

40 CPR 60 Standards of Performance 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: 245-09-C (R1) 

U002 - U004 Emission Points: 

U002- U004 Equipment 

Emission Description Point 

E02A Boiler less than 1 00 MM Btu/hr 

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. 

Two (2) hot water boilers; 33.5 MM Btu/hr 

E05 each, installed 1996; natural gas-fired 

Plant ID: 0072 

Applicable Control 

Regulation ID 

7.06 

5.21 

NA 

6.42 

40 CPR 60 Subpart De 

7.06 

5.21 

N/A 

6.42 

40 CPR 60 Subpart De 

7.06 

5.21 

N/A 

6.42 

40 CPR 60 Subpart DC 

7.06 

N/A 

5.21 

40 CPR 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: 245-09-C (R1) Plant ID: 0072 

U002- U004 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. PM 

1. 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) 

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

Applicability Limit (PAL) 

b. Opacity 

1. For indirect heat exchangers subject to Regulation 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; 

iii. 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) 

1. 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) 

Page 44 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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) 

11. For Emission Points E04A, E04B and E05: 

e. TAC 

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

tons per boiler during March 1 through October 31. 

The owner or operator shall not allow any TAC em1sswns 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) 

40 CFR 60 Subpart DC monitoring requirements for S02 compliance. (See 

Comment 1) 

i. The owner or operator shall keep records of the amount of fuel com busted 

during each month. (40 CFR 60.48c(g)(2)) 

11. 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 

Page 45 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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 

a. PM 

See PAL Repmiing Requirements, there are no additional reporting requirements 

for demonstrating compliance with Regulation 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 7.06. 

Page 46 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

d. NOx 

See PAL Reporting Requirements. 

e. TAC 

See Comment 4. 

S5. Testing (Regulation 2.16, section 4.1.9.3) 

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 this 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. 

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 

SCH Page 47 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

vacated boiler MACT (40 CFR 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 CFR 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 

CFR 60, Subpart Db from being applicable, Ford can only install additional boilers 

totaling less than 100 MM Btu/hr. 

SCH Page 48 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 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: 245-09-C (R1) 

U008 Emission Points: 

ID Description 

6000 gallon 

E08A Methanol Tank 

10,000 gallon UG 

E08G Solvent Tank 

E08M 

20,000 gallon AntiFreeze Tank 

E08N 

20,000 gallon Power 

Steering Fluid Tank 

E080 

6000 gallon Brake 

Fluid Tank 

E08P 

20,000 gallon Diesel 

Fuel Tank 

Plant ID: 0072 

U008 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 

Vapor Pressure < 1.5 psi a N/A 

7.12 

5.21 

Vapor Pressure < 1.5 psi a N/A 

7.12 

5.21 

Vapor Pressure < 1.5 psia N/A 

7.12 

U008 Control Devices: There are no control devices associated with Emission Unit U008. 

SCH Page 50 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 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 

i. 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. 

ii. 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: 245-09-C (R1) 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. 

U008 Comment 

1. Emission points E08M, E08N and E08P are not subject to 40 CFR 60 subpart Kb because 

this subpart does not apply to storage vessels with a capacity greater than or equal to 151 

m3 (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: 245-09-C (R1) 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, and 8 

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: 245-09-C (R1) 

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: 245-09-C (R1) Plant ID: 0072 

U009 Specific Conditions 

Sl. Standards (Regulation 2.16, section 4.1.1) 

a. VOC 

i. The owner or operator shall not cause or allow the emission of VOC 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) 

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

Applicability Limit (PAL). 

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.) 

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: 245-09-C (R1) 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 

i. 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. 

11. 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: 245-09-C (R1) Plant ID: 0072 

iii. 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 Reporting Requirements. 

Page 57 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

UOlO Emission Unit Description: E-Coat Operation 

UOlO 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 CFR 60 General Provisions 60.1 through 60.18 Subpart A 

40 CFR60 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 

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 and2 

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: 245-09-C (R1) 

U010 Emission Points: 

ID Description 

E10A E-CoatDip 

Tank 

EIOB E-Coat Oven 

SCH 

Plant ID: 0072 

U010 Emission Points 

Applicable Allowable Emission/ Equipment Control 

Requirement Standard Device 

(RT) is :2: 0.16, not exceed 1.4 lbs/gal 

40 CFR 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 

RT is< 0.040, not be subject to an N/A 

emission limit 

a. 0.6 lbs HAP/GACS 

Or 

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) E-coat) 

40 CFR 60 

SubpartMM See Specific Condition S 1.a 

6.17 and 7.01 

a. 0.6 lbs HAP/GACS 

Or C10A 

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) E-coat) 

7.08 < 300 ppm 

Page 59 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 

ElOC 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 S 1.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 

UOlO Control Devices: 

ID Description 

Performance Stack ID Indicator 

C10A One (1) Regenerative Thermal Temperature S-041, S-043, S-045 

Oxidizer (RTO) 

C10B One (1) Regenerative Thermal Temperature S-020 to S-022, S-050 

Oxidizer (RTO) 

C17A Dry Panel Filter N/A S-04 7, S-048 

SCH Page 60 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

UOlO 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 

Page 61 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 

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 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, 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). 

n. 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° 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. 

111. 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: 245-09-C (Rl) 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: 

n V C. 

voc = s _l_l 

w v 

i=l I 

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 )(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 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 

Page 63 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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

f. TAC 

1. 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. 

11. Determine and record monthly usage of each material. 

iii. 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. 

VI. Record the afterburner combustion chamber temperature and temperature 

recording 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 ofthe 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 

Page 64 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 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) 

m. 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: 245-09-C (Rl) 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: 245-09-C (R1) 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. 

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 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 only 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: 245-09-C (R1) Plant ID: 0072 

U011 Emission Unit Description: Guidecoat Operation 

U011 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 

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: Surface Coating of Automobiles and 1, 2, 3 ,4, 7 and 8 

Light-Duty Trucks 

SCH Page 68 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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: 245-09-C (R1) 

U011 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 

U011 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 

SubpartMM See Specific Condition S 1.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% 

C10B 7.08 

2.34lb/hr 

7.59 3.5 lbs VOC/gal 

40 CPR 60 

SubpartMM See Specific Condition S 1.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: 245-09-C (Rl) Plant ID: 0072 

UOll Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 

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 C10B 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 1.a 

Guidecoat (Prime) <20% 

E18A 7.08 C18A Scuff Booth 2.34lb/hr 

UOll Control Devices: 

UOll Control Devices 

Performance 

ID Description Indicator StackiD 

C11A Water Wash N/A S-080 to S090 

CIOB 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) 

C18A Dry Panel Filter N/A S-175 to S-178 

SCH Page 71 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

UOll 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 ofVOC from any affected facility resulting from the coating 

of metallic surfaces in excess of 0.42 kg ofVOC/1 (3.5 lb 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: 245-09-C (R1) 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 

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 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 E11B, 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) 

11. 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° 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. 

111. The line shall not be operated unless all control devices are being properly 

operated. 

Page 73 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 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 of VOC in the coating. The 

following equation may be used as an alternate method to demonstrate 

compliance: 

b. PM 

Where: 

n ---¥yCi 

i,J;~i 

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: 245-09-C (Rl) 

f. TAC 

Plant ID: 0072 

1. See Specific Condition S2.a.iii and iv. 

11. See Specific Condition S3.f. 

S3. Record Keeping (Regulation 2.16, section 4.1.9 .2) 

SCH 

a. VOC 

i. For Emission Point E11B, 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. 

ii. The owner or operator shall maintain the following records: ( 40 CPR 

60.395 and 1.05, Section 4) 

1) Record daily the quantity of paint and dilution solvent added to the 

Page 75 ofl30 03-31-2011 
Permit No: 245-09-C (R1) 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 CPR 60.392, as calculated, 

using the prescribed transfer efficiency of 40 CPR 60.393 

(c)(1)(i)(C) for the monthly weighted average mass of VOC 

emitted per volume of applied coating solids. 

111. 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 ofthe 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: 245-09-C (R1) 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 

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. 

ii. 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) 

111. See Specific Conditions S3.a.ii.(5) 

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 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: 245-09-C (Rl) 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 negative 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 insp·ections 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 78 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

There are no reporting requirements for NOx compliance. (See Comment 2) 

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. 

ii. 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) 

iii. See Specific Conditions S4.a.ii. 

U011 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 CPR 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 only to detennine 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: 245-09-C (R1) 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 1,3,4and5 Maintenance Requirements 

7.08 Standards of Performance for New Process 1 through 3 Operations 

7.01 General Provisions 7.2 

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 

SCH Page 80 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 1,3,4and5 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: 245-09-C (R1) 

U012 Emission Points: 

U012 Emission Points 

Description Applicable Allowable Emission/ 

Requirement Equipment Standard 

40 CFR 60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E 12A North Main 2.34lb/hr 

Enamel Booth and a. 0.6 lbs HAP/GACS 

Air Supply Or 

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) 

40 CFR 60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

<20% 

7.08 

E12B North Main < 300 ppm 

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 82 of 130 

Plant ID: 0072 

Control 

Device 

C12A, C12B 

Cl2C, C12H and 

C12G 

Cl2D 

03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 

SubpartMM See Specific Condition S l.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 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 

E12D South Main < 300 ppm C12D 

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 83 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR 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 Cl2F 

Supply House Or 

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) 

40 CFR 60 

SubpartMM See Specific Condition S l.a. 

6.17 and 7.01 

<20% 

7.08 

E12F Tutone/Repair < 300 ppm 

Topcoat Oven c. 0.6 lbs HAP/GACS C12D 

Or 

d. 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) 

SCH Page 84 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U012 Emission Points 

Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR 60 

SubpartMM See Specific Condition S 1.a. 

6.17 and 7.01 

E11E/E12G a. 0.6 lbs HAP/GACS 

Guidecoat/Topcoat Or N/A 

Kitchen b. 1.1 Ibs 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 2.34lb/hr 

E12I TuTone/Repair <20% 

7.08 C20A Scuff Booth 2.34lb/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) 

Cl2C, 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: 245-09-C (R1) Plant ID: 0072 

U012 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

b. 

1. 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 

CFR 60.392) (See Comment 3) 

11. 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) 

iii. See Louisville Assembly Plant, Ford Motor Comgany Plant-wide 

Agplicability Limit CP AL). 

PM 

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

Applicability Limit CPAL). 

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 Comgany 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: 245-09-C (R1) 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° 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. 

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: 245-09-C (Rl) Plant ID: 0072 

SCH 

Where: 

n V C. 

voc = s _l_l 

w v 

i=l I 

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 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 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: 245-09-C (R1) Plant ID: 0072 

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 

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 ofthe 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 inS 1.b.ii. above. 

Page 89 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 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 

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 

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: 245-09-C (R1) 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: 245-09-C (R1) Plant ID: 0072 

There are no reporting requirements for NOx compliance. (See Comment 2) 

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 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 CFR 60 Subpart MM 60.3092 VOC limit. 

4. The reported total lb/hr emissions of each TAC from each piece of equipment during 

each bypass event will be used only 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 T AC 

emissions increase above de minimis values. 

SCH Page 92 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 
Permit No: 245-09-C (Rl) 

U013 Emissions Points: 

ID Description 

El3A Gasoline Tank #1 

El3B Gasoline Tank #2 

El3C Gasoline Tank #3 

El3D Two (2) Fueling 

Stations 

Plant ID: 0072 

U013 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

7.15 Stage I vapor recovery system N/A 

7.15 Stage I vapor recovery system N/A 

7.15 Stage I vapor recovery system N/A 

See Comment 2 ORVR Equipped Vehicles N/A and 3 

U013 Control Equipment: There are no control devices associated with Emission Unit U013. 

SCH Page 94 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U013 Specific Conditions: 

Sl. Standards (Regulation 2.16, section 4.1.1) 

a. VOC 

i. Storage tanks, Emission Points E13A through E13C, shall be equipped 

with the following: (Regulation 7.15, section 3.1) 

b. TAC 

a) A submerged fill pipe; (Regulation 7.15, section 3.1.1) 

b) Ifthe gasoline storage tank is equipped with a separate gauge well, 

a gauge well drop tube shall be installed which extends to within 

six inches of the bottom of the tank; (Regulation 7.15, section 

3.1.2) 

c) Vent line restrictions on the affected facility; and (Regulation 7.15, 

section 3.1.3) 

d) Vapor balance system and vapor tight connections on the liquid fill 

and vapor return hoses. The cross-sectional area of the vapor return 

hose and any other vapor return passages in the circuit connecting 

the vapor space in the service station tank to that of the truck tank 

must be at least 50% of the liquid fill hose cross-sectional area for 

each tank and free of flow restrictions to achieve acceptable 

recovery. The vapor balance equipment must be maintained 

according to the manufacturer's specifications. The type, size and 

design of the vapor balance system are subject to the approval of 

the District. (Regulation 7.15, section 3 .1.4) 

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.) (See 

Comment 1) 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. VOC 

Storage tanks: To demonstrate ongoing compliance with Regulation 1.05, Section 

4, the owner or operator shall monitor the quantity of gasoline used to fuel 

vehicles. 

a) The owner or operator shall monthly: 

Page 95 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

1) Check the storage tank fill points for tightness; 

2) If a two point vapor recovery system on the storage tank, check 

rubber gaskets for tears, verify spring loaded valves properly 

operate and tank refill caps have rubber gaskets in good condition; 

replace any damaged parts; and 

b) The owner or operator shall annually: 

Verify pressure vacuum valve on vent pipe is operating properly annually 

and replace any damaged part. 

c) The owner or operator must complete all repairs within 5 working days. 

b. TAC 

See Comment 1. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

a. VOC 

1. The owner or operator shall record total monthly gasoline throughput and 

make these records available to the District upon request. 

11. The owner or operator shall maintain records of the monthly and annual 

inspections. These records shall contain the date and time of the 

inspection; who performed the inspection; and the results of the 

inspection. 

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. (See Comment 

1) 

S4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

There are no routine reporting requirements for this equipment. (See Comment 1) 

SCH Page 96 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U013 Comments 

1. The emissions from a motor vehicle fueling or refueling process and process equipment 

for gasoline and other liquid fuels are de minimis under STAR. (Regulation 5.01, section 

1.6.6.) 

2. The District reviewed a letter dated January 18,2007 regarding the current applicability of 

Stage II Vapor Recovery. EPA has provided guidance that vehicle production plants 

doing initial fueling of vehicle comply with vapor recovery requirements by means of 

ORVR requirements for compliant vehicles. The District concurs that the external vapor 

recovery system as required by the applicable Title V operating permit for LAP is not 

required for fueling vehicles with ORVR. 

3. Regulation 6.40 does not apply to the initial fueling of new motor vehicles at a motor 

vehicle assembly facility per section 2.1.2. 

SCH Page 97 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U014 and U022 Emission Unit Description: Paint Equipment Cleaning Operations 

U014 and U022 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

6.18 

Standards of Performance for Solvent Metal 

1 though 4 Cleaning Equipment 

7.25 

Standards of Performance for New Source Using 1 through 5 Volatile Organic Compounds 

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 1,2,3,4,7and8 

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 

5.14 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 98 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U014 and U022 Emission Points: 

U014 and U022 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

Paint Equipment 7.25 See Specific Conditions S 1.a. 

E14A N/A Cleaning Booth 40 CPR 63 Subpart IIII Section 63.3094 

Paint Equipment 7.25 See Specific Conditions S l.a. 

E22A Purging and Plant N/A 

Cleaning 40 CPR 63 Subpart IIII Section 63.3094 

Solvent Metal 

See Specific Conditions S 1.a.iii N/A Cleaning 6.18 N/A 

Equipment 

U014 and U022 Control Devices: There are no control devices associated with Emission Unit 

UO 14 and U022. 

SCH Page 99 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U014 and U022 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

1. Applicator Paint Purging: The automatic spray applicators will incorporate 

a purge paint and solvent recovery system that will collect the purged 

materials. 

11. The owner or operator of a cold cleaner to clean non-paint or non-sealer 

related equipment using volatile organic compounds (VOC) shall, install, 

maintain, and operate the control equipment as follows: 

The cold cleaner shall be equipped with a tightly fitting cover that is free 

of cracks, holes, or other defects. If the solvent is agitated or heated, then 

the cover shall be designed so that it can be easily operated with 1 hand. 

(Regulation 6.18, section 4.1.1) 

The cold cleaner shall be equipped with a drainage facility that is designed 

so that the solvent that drains off parts removed from the cleaner will 

return to the cold cleaner. The drainage facility may be external if the 

District determines that an internal type cannot fit into the cleaning 

system. (Regulation 6.18, section 4.1.2) 

A permanent, conspicuous label summarizing the operating requirements 

specified in Specific Condition S I. b. shall be installed on or near the cold 

cleaner. (Regulation 6.18, section 4.1.3) 

If used, the solvent spray shall be a fluid stream, not a fine, atomized, or 

shower type spray, at a pressure that does not cause excessive splashing. 

Flushing of parts using a flexible hose or other flushing device shall be 

performed only within the freeboard area of the cold cleaner. Solvent flow 

shall be directed downward to avoid turbulence at the air-solvent interface 

and to prevent solvent from splashing outside of the cold cleaner. 

(Regulation 6.18, section 4.1.4) 

Work area fans shall be located and positioned so that they do not blow 

across the opening of the cold cleaner. (Regulation 6.18, section 4.1.6) 

The solvent-containing portion of the cold cleaner shall be free of all 

liquid leaks. Auxiliary cold cleaner equipment such as pumps, water 

separators, steam traps, or distillation units shall not have any visible 

liquid leaks, visible tears, or cracks. (Regulation 6.18, section 4.1.8) 

The owner or operator shall observe at all times the following operating 

Page 100ofl30 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

SCH 

b. TAC 

requirements: (Regulation 6.18, section 4.2) 

Waste solvent shall neither be disposed of nor transferred to another party 

in a manner such that more than 20% by weight of the waste solvent can 

evaporate. Waste solvent shall be stored only in a covered container. A 

covered container may contain a device that allows pressure relief, but 

does not allow liquid solvent to drain from the container. (Regulation 6.18, 

section 4.2.1) 

The solvent level in the cold cleaner shall not exceed the fill line. 

(Regulation 6.18, section 4.2.2) 

The cold cleaner cover shall be closed whenever a part is not being 

handled in the cold cleaner. (Regulation 6.18, section 4.2.3) 

Parts to be cleaned shall be racked or placed into the cold cleaner in a 

manner that will minimize drag-out losses. (Regulation 6.18, section 4.2.4) 

Cleaned patis shall be drained for at least 15 seconds or until dripping 

ceases, whichever is longer. Parts having cavities or blind holes shall be 

tipped or rotated while the part is draining. During the draining, tipping, or 

rotating, the parts shall be positioned so that the solvent drains directly 

back to the cold cleaner. (Regulation 6.18, section 4.2.5) 

A spill during solvent transfer shall be cleaned immediately, and the wipe 

rags or other sorbent material shall be immediately stored in a covered 

container for disposal or recycling, unless enclosed storage of these items 

is not allowed by fire protection authorities. (Regulation 6.18, section 

4.2.6) 

Sponges, fabric, wood, leather, paper products, and other absorbent 

material shall not be cleaned in a cold cleaner. (Regulation 6.18, section 

4.2.7) 

The owner or operator shall not operate a cold cleaner used to clean nonpaint or non-sealer related equipment using a solvent with a vapor 

pressure that exceeds 1.0 mm Hg (0.019 psi) measured at 20°C (68°F). 

(Regulation 6.18, section 4.3 .2) 

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.) 

c. HAP 

Page 101 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

1. The owner or operator shall follow the work practices specified in 40 CFR 

63 Subpart IIII, Specific Condition Sl.b and c. to minimize VOC 

emissions from purge and cleaning operations. 

ii. See LAP Ford Motor Company MACT Standards Section. 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

a. VOC 

See Specific Condition S l.a. 

b. TAC 

See Specific Condition S3.b. 

c. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

a. VOC 

1. See Specific Condition S l.a. 

11. The owner or operator shall maintain records that include the following 

for each purchase: (Regulation 6.18, section 4.4.2) 

b. TAC 

1) The name and address of the solvent supplier, 

2) The date ofthe purchase, 

3) The type of the solvent, and 

4) The vapor pressure of the solvent measured in mm Hg at 20oC 

(68°F). 

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 Ford Motor Company MACT Recordkeeping Section. 

S4. Reporting (Regulation 2.16, section 4.1.9.2) 

SCH Page 102 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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 Ford Motor Company MACT Reporting Requirements. 

U014 and U022 Comments 

1. Specific Conditions involving work practice standards only have no monitoring, record 

keeping and reporting requirements, as such would be impractical. 

2. The aqueous cold cleaners that contain no VOCs are not subject to Regulation 6.18. 

SCH Page 103 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U015 Emission Unit Description: Sealer Deck 

U015 Applicable Regulations: 

Federally Enforceable Regulations 

Regulation Title Applicable Sections 

1.05 Compliance with Emission Standards and 1, 3, 4 and 5 Maintenance Requirements 

7.59 Standards of Performance for New Source Using 1 through 5 Volatile Organic Compounds 

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 

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 

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 104 of 130 03-31-2011 
Permit No: 245-09-C (R1) 

U015 Emission Points: 

ID Description 

ElSA Sealer Application 

N/A Sealers and Deadeners 

(other than glass bonding) 

Plant ID: 0072 

U015 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

7.59 3.5 lbs/gal N/A 

Section 40 CFR 63.3090 (c) 

40 CFR 63 or 63.3091 (c) N/A Subpart IIII 0.01 lb VOC per lb of 

adhesive and sealer material 

U015 Control Devices: There are no control devices associated with Emission Unit U015. 

SCH Page 105 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U015 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 of VOC from 

any affected facility resulting from the coating of metallic surfaces in 

excess of 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) 

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

Applicability Limit (PAL). 

b. TAC 

The owner or operator shall not allow any TAC em1sswns 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 Ford Motor Company MACT Standards Section. 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

a. VOC 

See Specific Condition S3.a. 

b. TAC 

See Specific Condition S3.b. 

c. HAP 

See LAP Ford Motor Company MACT Monitoring Section. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

SCH 

a. VOC 

1. The owner or operator of an affected facility subject to this regulation 

shall maintain records that include, but not be limited to, the following: 

Page 106of130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

b. TAC 

(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. 

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 Ford Motor Company MACT Recordkeeping Section. 

S4. Reporting (Regulation 2.16, section 4.1.9.3) 

a. VOC 

See General Permit Reporting Requirements. 

b. TAC 

SCH Page 107 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

SCH 

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 Ford Motor Company MACT Reporting Requirements. 

Page 108 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U016 Emission Unit Description: Final Repair Spray Booth; infrared curing, and spot repair 

bays for repairing coating on vehicles 

U016 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 

Operations 1 through 3 

40 CFR 60 General Provisions 63.1 through 63.16 Subpart A 

40 CFR60 National Emission Standards ofPerformance 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 109 of 130 03-31-2011 
Permit No: 245-09-C (R1) 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 

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 110 of 130 03-31-2011 
Permit No: 245-09-C (Rl) 

U016 Emission Points: 

ID Description 

E16A Final Repair 

Booth 

E16B Final Repair 

Oven 

SCH 

Plant ID: 0072 

U016 Emission Points 

Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CPR 60 Subpart MM 

See Specific Conditions S l.a. 

6.17 and 7.01 

<20% 

7.08 

2.34lb/hr 

a. 0.6 lbs HAP/GACS C16A 

Or 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 Subpart IIII (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) final repair) 

40 CPR 60 Subpart MM 

6.17 and 7.01 

See Specific Conditions S l.a. 

<20% 

7.08 

< 300 ppm 

a. 0.6 lbs HAP/GACS N/A 

Or 

b. 1.1 lbs HAPs/GACS 

40 CPR 63 Subpart IIII (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) final repair) 

Page 111 of130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U016 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard Device 

40 CFR 60 Subpart MM 

See Specific Conditions S 1.a 

6.17and7.01 

<20% 

7.08 

2.34lb/hr 

E16C Final Repair a. 0.6 lbs HAP/GACS N/A Spot Paint Or 

b. 1.1 lbs HAPs/GACS 

40 CFR 63 Subpart IIII (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) final repair) 

U016 Control Devices: 

ID Description 

Performance StackiD Indicator 

C16A Fabric Filter N/A S187 and S188 

SCH Page 112 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U016 Specific Conditions 

1. Standards (Regulation 2.16, section 4.1.1) 

SCH 

a. VOC 

1. The owner or operator shall be subject to the emission limit of 4.8 lbs 

VOC/gal (0.58 kg/1) of coating, less water and exempt solvents. (40 

CFR60.3092, Regulation 7.01 section 7.2 and Regulation 6.1, section 3.4) 

11. 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). 

11. 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 Final Repair Booth 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 Company 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 

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.) 

Page 113 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

S2. Monitoring (Regulation 2.16, section 4.1.9 .1.2) 

SCH 

a. VOC 

1. 

ii. 

Where: 

Monitor ongoing compliance by calculating monthly, a daily a volume 

weighted 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-450/3-88-0 18 (Docket ID No. OAR-2002 

-0093 and Docket ID No. A-2001-22) 

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: 

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. 

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. 

111. 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 

filters, including monthly inspection, routine maintenance as recommended by the 

manufacturer, and prompt repair of any defects. 

Page 114 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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 

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 CPR 60.395 and 1.05, Section 4: 

1) Record monthly the daily quantity and type of paint withdrawn from the 

topcoat paint circulation system for use in the final repair operation using 

the methodology specified in S2.a. 

2) Monthly, determine the 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 an appropriate material usage factor determined to be 

acceptable by the District. (See Comment 3) 

4) 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. 

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. 

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 

Page 115 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

proper operation of the fabric filter has occurred satisfies this compliance 

requirement for the standard specified in S 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 

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 4.1.9.2) 

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 with 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. 

iii. Perform reporting for VOCs for 40 CFR 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) The owner or operator shall notify the Administrator 30 days in 

advance of any test by Method 25. 

Page 116 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

b. PM 

i. Any deviation from the requirement to perform monthly visible 

inspections of the booth PM filter system; 

11. The dates that filters were replaced or a declaration that there were no 

filters replaced during the reporting period; and 

111. See General Permit Reporting Requirements. 

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) 

f. 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. 

U016 Comment 

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 District has deemed 0.5% as an appropriate material usage factor for Emission Unit 

U016. 

SCH Page 117 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U023 Emission Unit Description: Phosphate Operation 

U023 Applicable Regulations: 

District Only Enforceable Regulations 

Regulation Title Applicable Sections 

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 

U023 Emission Points: 

U023 Emission Points 

ID Description Applicable Allowable Emission/ Control 

Requirement Equipment Standard 

E1000 Phosphate 5.01 See Specific Conditions S3. 

E1001 Phosphate Dump 5.01 See Specific Conditions S3. 

Tanlc 

U023 Control Devices: There are no control devices associated with Emission Unit 

U023. 

SCH Page 118of130 

Device 

N/A 

N/A 

03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

U023 Specific Conditions 

S 1. Standards (Regulation 2.16, section 4.1.1) 

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) 

TAC 

See Specific Condition S3. 

S3. Record Keeping (Regulation 2.16, section 4.1.9.2) 

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 4.1.9.2) 

SCH 

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. 

Page 119 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

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

U025 Applicable Regulations: 

FEDERALLY ENFORCEABLE REGULATIONS 

Regulation Title Applicable Sections 

7.08 Standards of Performance for New Indirect Heat 1 through 4 Exchangers 

Reasonable Available Control Technology 

6.42 Requirements for Major Volatile Organic 1.2, and 2 through 5 

Compound 

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 

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 

U025 Emission Points: 

U025 Emission Points 

ID Description Applicable Regulation Control Device 

5.21 

E25 Direct Heat Exchangers 6.42 N/A 

7.08 

U025 Control Devices: There are no control devices associated with Emission Unit 

U025. 

SCH Page 120 of 130 03-31-2011 
Permit No: 245-09-C (Rl) Plant ID: 0072 

U025 Specific Conditions 

Sl. Standards (Regulation 2.03, section 5.1) 

a. PM 

The owner or operator shall not allow PM em1ss10ns to exceed 2.34 lb/hr. 

(Regulation 7.08, section 3.1.2) (See Comment 1) 

b. Opacity 

The owner or operator shall not allow visible emissions to equal or exceed 20% 

opacity. (Regulation 7.08, section 3.1.1) 

c. 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. 

ii. The owner or operator shall not allow NOx emissions to exceed 300 ppm 

by volume expresses as N02• (Regulation 7.08, section 4.1.) (See 

Comment 4) 

d. TAC 

The owner or operator shall not allow any TAC em1sswns 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 2.03, section 5.1) 

a. PM 

There are no monitoring requirements for PM compliance. (See Comment 1) 

b. Opacity 

See Comment 2. 

c. NOx 

See Specific Condition S3.c. 

d. TAC 

SCH Page 121 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

See Comment 3. 

S3. Record Keeping (Regulation 2.03, section 5.1) 

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. PM 

There are no record keeping requirements for PM compliance for this equipment. 

(See Comment 1) 

b. Opacity 

There are no record keeping requirements for Opacity compliance for this 

equipment. (See Comment 2) 

c. NOx 

1. 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. 

ii. See Comment 4. 

d. TAC 

See Comment 3. 

S4. Reporting (Regulation 2.03, section 5.1) 

SCH 

a. PM 

See Comment 1. 

b. Opacity 

See Comment 2. 

c. NOx 

1. The owner or operator shall report the monthly and 12 consecutive month 

plant-wide NOx emissions for each month in the report period. 

11. See PAL Reporting Requirements. 

Page 122 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

d. 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. 

U025 Comments 

1. The District has performed a one-time PM compliance demonstration for the space 

heater, 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 space heater with respect to PM 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. STAR Regulation 5.01, section 1.6.7 states the TACs from natural combustion are De 

Minimis. 

4. The District performed a onetime compliance demonstration for NOx and the 300 ppm 

standard cannot be exceeded uncontrolled. 

SCH Page 123 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

Ford LAP Plant-wide 

Permit Shield 

The owner or operator is hereby granted a permit shield that shall apply as long as the owner or 

operator demonstrates ongoing compliance with all conditions of this permit. Compliance with 

the conditions of this permit shall be deemed compliance with all applicable requirements of the 

regulations cited in this permit as of the date of issuance, pursuant to Regulation 2.16, section 

4.6.1. 

Off-permit Documents 

Document 

Rule Effectiveness Plan 10 April1995 

Alternative Operating Scenarios 

The owner or operator did not request to operate under any alternative operating scenarios in its 

Title V permit application. 

Insignificant Activities 

Description Quantity Basis 

Internal combustion Various Regulation 2.02, Section 2.2 engines fixed or mobile 

Presses extruding Various Regulation 2.02, Section 2.3.1 metal/mineral/wood 

Brazing, soldering or Various Regulation 2.02, Section 2.3.4 welding equipment 

Woodworking, except for 

conveying, hogging, or Various Regulation 2.02, Section 2.3.5 

burning wood/sawdust 

Lab venting and exhaust 

systems (non radioactive Various Regulation 2.02, Section 2.3 .11 

materials) 

Ventilation systems - Various Regulation 2.02, Section 2.3.12 bakeries & restaurants 

Washing or drying 

fabricated metal or glass; Various Regulation 2.02, Section 2.3.15 non VOC use; no oil or 

solid fuel 

Residential/domestic Various Regulation 2.02, Section 2.3.12 equipment 

Portable diesel or gasoline Various Regulation 2.02, Section 2.3.23 

storage tanks 

SCH Page 124 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

Insignificant Activities 

Description Quantity Basis 

Diesel fuel storage tanks Various Regulation 2.02, Section 2.3 .25 (emergency use only) 

Closed pressure storage 2 Regulation 2.02, Section 2.3.26 vessels 

Portable tote tanks for raw Tote tanks are kept closed when not in use. Emissions from tanks material shipment of Various 

solvent - based coatings are negligible, and are accounted for by process material balance. 

Backup generators for 

emergency power.(< 500 2 Generators normal use is very low and HP <500 HP. 

hrs/year) 

Wastewater Pretreatment 1 Emissions insignificant system. 

Fluid Fill (hydraulic fluids, Emissions insignificant due to low vapor pressure of materials oil, anti-freeze) and Various 

Lubricating operations. used. 

Miscellaneous maintenance 

procedures including 

lubrication, grinding, Various Negligible emissions 

cleaning, woodworking, 

etc. 

Direct heat exchangers <1 Various Regulation 2.02, Section 2.1.1 MMBtu/ hr 

a. Insignificant Activities are only those activities or processes falling into the 

general categories defined in District Regulation 2.02, Section 2, and not 

associated with a specific operation or process for which there is a specific 

regulation. Equipment associated with a specific operation or process (Emission 

Unit) shall be listed with the specific process even though there may be no 

applicable requirements. Information contained in the permit and permit 

summary shall clearly indicate that those items identified with negligible 

emissions have no applicable requirements. 

SCH 

b. Activities identified in District Regulation 2.02, Section 2, may not require a 

permit and may be insignificant with regard to application disclosure 

requirements but may still have generally applicable requirements that continue to 

apply to the source. 

c. For all insignificant activities that emit regulated air pollutants for which the 

company has accepted a plant-wide synthetic minor limit, the company shall 

maintain sufficient records to calculate the emissions and report those emissions 

in the quarterly compliance reports and the annual emissions inventory report. 

d. The Insignificant Activities table is correct as of the date the permit was proposed 

for review by the USEP A, Region 4. The company shall submit an updated list of 

Page 125 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

SCH 

insignificant activities annually with the Title V compliance certification pursuant 

to District Regulation 2.16, section 4.3 .5 .3 .6. 

e. In lieu of recording annual throughputs for each Insignificant Activity, the owner 

or operator may elect to report the Potential To Emit quantity listed in the 

Insignificant Activities table as the annual emission for each piece of equipment, 

since the emissions from the source's Insignificant Activities are minor. 

Page 126 of 130 03-31-2011 
Permit No: 245-09-C (R1) 

Ford Louisville Assembly Plant 

Compliance Assurance Monitoring (CAM) Plan 

PROCESS/OPERATIONAL RESTRICTION(S) 

Plant ID: 0072 

1. The thermal oxidizer used to control VOC emissions from the coating operations shall be 

operated to maintain a combustion chamber temperature of no more than 50 degrees 

Fahrenheit below the average combustion temperature during the most recent acceptable 

performance test and shall have a minimum design retention time of 0.5 seconds. The 

minimum temperature requirement may be based upon a 3 hour average. 

(64.6( c)(1)(i),(ii)) 

2. The carbon adsorber used to control VOC emissions from the coating operations shall be 

operated to maintain a desorption gas inlet temperature of no more than 15 degrees 

Fahrenheit below the average desorption gas inlet temperature during the most recent 

acceptable performance test. The minimum temperature requirement may be based upon 

a 3 hour average. (64.6(c)(1)(i),(ii)) 

3. When relying on add-on control devices to demonstrate compliance with the emission 

requirements of this permit (i.e., control efficiency credit), the permittee may use nonzero control efficiencies for any period of time in which a deviation or excursion 

(including a deviation during startup, shutdown, or malfunction) from an operating limit 

occurs. If compliance with the emission limits is achieved, then no enforceable deviation 

or excursion will have occurred. (64.6(b)) 

MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. 

1. 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. ( 64.6( c )(1 )(i),(ii)) 

2. Temperature measurements of the concentrator desorption gas inlet shall be made and 

recorded at least once every 15 minutes during operation of the associated coating 

operations. ( 64.6( c )(1 )(i),(ii)) 

3. If coating operations can continue operating during a control device bypass, the bypass 

shall be monitored such that the valve or closure method cannot be opened without 

creating an alarm condition for which a record shall be made. Records of the bypass line 

that was open and the length of time the bypass was open during operation of the 

associated coating operations shall be kept on file. (64.3(a)(2)) 

4. The CAM O&M plan shall be updated as necessary to reflect any necessary changes. All 

records and activities associated with the O&M plan shall be kept on file for a period of 

SCH Page 127 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

at least five years. (64.6(c)(l)(i),(ii), 64.7(e)) 

REPORTING 

1. Each quarterly report for monitoring and deviations shall identify the number, duration 

and cause of any excursions of these requirements and the corrective actions taken. If 

there were no excursions in the reporting period, then this report shall include a statement 

that there were no excursions. (40 CFR 64.9(a)(2)(i)) 

OTHER REQUIREMENT(S) 

For the purposes of Compliance Assurance Monitoring (CAM), excursiOns will be 

defined as follows: (64.6(c)(2)) 

a. A temperature excursion is defined as a confirmed three-hour period during which 

the average fails to meet the specified temperature requirements. 

b. A monitoring excursion is defined as a failure to properly monitor as required. 

c. A monitoring excursion can also be defined as failure to properly implement 

and/or maintain the O&M plan. 

Elements of an O&M plan - CAM 

General- Keep records of maintenance inspections which include the dates of the inspections 

and the dates and reasons for repairs if made. The following items shall be addressed in an 

O&M Plan for each respective control device used to demonstrate compliance with applicable 

VOC emissions limits. 

RTO's 

• Validation of operation of each thermocouple a minimum of once every 12 months or 

thermocouple replacement. 

• *Perform a heat exchange/heat transfer media inspection a minimum of once every 18 

months, or 

• *Perform an inspection of the valve seals condition once every 18 months and verify 

valve timing/synchronization through visual observation (or through an alarm system) 

once every 18 months. 

Carbon Adsorbor 

• Validation of operation of each thermocouple a minimum of once every 12 months or 

thermocouple replacement. 

• Perform semi-annual observations to confirm that the carbon adsorbor is rotating (if a 

rotary carbon adsorbor) and that the desorption fan is operating. 

• *Perform internal observation of adsorbent materials for contamination and erosion a 

minimum of once every 18 months. 

SCH Page 128 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

• Observe and record the pressure drop across the carbon adsorbor a minimum of once 

every calendar quarter. 

* This requirement is satisfied if a performance test (i.e., stack test) has been performed. 

SCH Page 129 of 130 03-31-2011 
Permit No: 245-09-C (R1) Plant ID: 0072 

Attachment A: 

Processes Added/Removed/Modified from Compliance 

Ford Motor Company Louisville Assembly Plant 

This sheet covers the period from _______ to ______ _ 

Emission Point 

(Note 1) 

Equipment 

Description 

(Note 1) 

Change Category 

(Note 1) 

Equipment 

Action (Note 2) 

Date of Action 

(Note 3) 

Note 1: 

Note 2: 

Note 3: 

SCH 

Description of equipment being added/removed/modified including em1ss10n 

point identification and category of change. This log shall include any 

equipment/process that is added or removed from the calculation of annual 

emissions. 

Any equipment being added, removed, or modified form the emissions must be 

listed. 

If equipment is being added, list date of commencement of operation (including 

startup). If equipment is being removed, list date of removal from installation. 

Page 130of130 03-31-2011 
Louisville Metro Air Pollution Control District 

850 Barret Ave., Louisville, Kentucky 40204 

March 31, 2011 

PAL Construction Statement of Basis 

Company: Ford Motor Company-Louisville Assembly Plant 

Plant Location: 2000 Fern Valley Road, Louisville, Kentucky 40213 

Date Application Received: 07 August 2008 Application Number: 11042 

Date of Draft Permit: 03/31/2011 

District Engineer: Shannon Clemons Hosey Permit No: 245-09-C (R1) 

Plant ID: 0072 SIC Code: 3711 NAICS: 336112 AFS: 00072 

Introduction: 

This permit will be issued pursuant to: (1) Regulation 2.16, (2) Title 40 of the Code of Federal 

Regulations Part 70, and (3) Title V of the Clean Air Act Amendments of 1990. Its purpose is to 

identify and consolidate existing District and Federal air requirements and to provide methods of 

determining continued compliance with these requirements. 

Jefferson County is classified as an attainment area for lead (Pb), sulfur dioxide (S02), nitrogen 

dioxide (N02), carbon monoxide (CO), 1 hr and 8 hr ozone (03), and particulate matter less than 

10 microns (PM10); and is a non-attainment area for particulate matter less than 2.5 microns 

(PM2.s). 

Application Type/Permit Activity: 

[ ] Initial Issuance 

[ ] Permit Revision 

[ ] Administrative 

[ ] Minor 

[ ] Significant 

[ ] Permit Renewal 

[X] Construction 

Compliance Summary: 

[X] Compliance certification signed 

[ ] Source is out of compliance 

[ ] Compliance schedule included 

[X] Source is operating in compliance 
Permit No. 245-09-C (R1) Plant ID 0072 

I. Source Information 

SCH 

1. Product Description: Manufacture of automobiles. 

2. Process Description: Vehicle bodies are assembled and primed in the body shop. 

A variety of sealers are applied to the bodies which are then painted. Wax is 

applied to certain body parts. Next, windshields and back lights are installed, then 

a structural adhesive is used to bond glass to the bodies. 

3. Site Determination: There are no other facilities that are contiguous or adjacent 

and under common control. 

4. Emission Unit Summary: 

Emission Unit Equipment Description 

U002-U004 Five (5) Boilers 

uoos Volatile Organic Liquid Storage Tanks 

U009 Glass Installation 

U010 E-Coat Operation 

UOll Guidecoat Operation 

U012 Topcoat Operation 

U013 Plant-wide Product Fueling 

U014/U022 Paint Equipment Cleaning Operation 

U015 Sealer Deck 

U016 Final Repair Spray Booth 

U023 Phosphate Operation 

U025 Twelve (12) Direct Heat Exchangers 

5. Fugitive Sources: There are no fugitive emissions. 

6. Permit Revisions: 

Page 2 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

Revision Issue Public Attachment 

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

NA 7/30/2010 6111/2010 Initial Entire Permit PAL, STAR TAC 

R1 

SCH 

requirements, RO 

change, DRE forE-coat 

control device change 

and 112(J) Part 1 & 2 

applications. 

3/31/2011 NA Admin Pages 43 and Revision to include 

Revision 50 permit 229-96-0 and 

correct Methanol Tank 

Vapor Pressure 

7. Emission Summary: 

Pollutant that triggered 

Actual Emissions (tpy) Major Source Status 

Pollutant 2008 Data (based on PTE) 

co 32.02 Yes 

NOx 38.11 Yes 

so2 0.23 No 

PM 3.77 No 

voc 273.0 Yes 

Single HAP> 1 tpy 

Methanol 2.43 Yes 

Xylene 9.1 Yes 

Toluene 1.93 Yes 

Ethyl benzene 1.84 Yes 

Total HAPs 21.78 Yes 

8. Applicable Requirements: 

[X] PSD 

[ ] NSR 

[X] NSPS 

[ ] NESHAPS 

[X] SIP 

[X] District-Origin 

[X] MACT 

[ ] Other 

9. Future MACT Requirements: The federal regulation 40 CPR 63, Subpart 

DDDDD has been vacated since June 8, 2007, therefore the boiler MACT 

requirements will not be included in this permit. 

Page 3 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

10. Referenced Federal Regulations in Permit: 

40 CFR 63 Subpart IIII 

40 CFR 63 Subpart De 

40 CFR 63 Subpart EEEE 

40 CFR 60 Subpart MM 

40 CFR 63 Subpart ZZZZ 

National Emission Standards for Hazardous 

Air Pollutants- Surface Coating of 

Automobile and Light Duty Trucks 

Standards of Performance for Small 

Industrial-Commercial-Institutional Steam 

Generating Units 

Organic Liquids Distribution Operations 

National Emission Standards of 

Performance for Automobile and Light Duty 

Truck Surface Coating Operations 

National Emissions Standards for Hazardous 

Air Pollutants for Stationary Reciprocating 

Internal Combustion Engines 

II. Regulatory Analysis 

SCH 

1. Acid Rain Requirements: The source is not subject to the Acid Rain Program. 

2. Stratospheric Ozone Protection Requirements: Title VI of the CAAA regulates 

ozone depleting substances and requires a phase-out of their use. This rule applies 

to any facility that manufactures, sells, distributes, or otherwise uses any of the 

listed chemicals. This source does not manufacture, sell, or distribute any of the 

listed chemicals. The source's use of listed chemicals is that in fire extinguishers, 

chillers, air conditioners and other HV AC equipment. 

3. Prevention of Accidental Releases 112(r): The source does not manufacture, 

process, use, store, or otherwise handle one or more of the regulated substances 

listed in 40 CFR Part 68, Subpart F, and District Regulation 5.15, Chemical 

Accident Prevention Provisions, in a quantity in excess of the corresponding 

specified threshold amount. 

4. Basis of Regulation Applicability 

a. Plant-wide 

The source is subject to a plant-wide PAL limit of 1316 tons of VOC 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 21.2 tons of PM during 

any consecutive 12-month period. 

Page 4 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

SCH 

The source is subject to a plant-wide PAL limit of 21.2 tons of PM10 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 17.2 tons of PM2.s 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 99 tons ofNOx during 

any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 39.33 tons of S02 

during any consecutive 12-month period. 

The source is subject to a plant-wide PAL limit of 151.4 tons of CO 

during any consecutive 12-month period. 

Regulations 5.01, 5.21, and 5.23 (STAR Program) establishes 

requirements for environmental acceptability of toxic air contaminants 

(TACs) and the requirement to comply with all applicable emission 

standards. 

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.) 

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) 

b. Emission Unit U002-U004- Five Boilers 

1. Equipment: 

Page 5 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

PIPE 

E02A 

E04A 

E04B 

E05 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

7.06 

Boiler less than 6.42 

100 MM Btu/hr 40 CFR60 

Boilers with heat generating capacities greater 

than 1 mmbtu/hr, modified after April 9,1972, are Subpart DC subject to Regulation 7.06 for PM and S02. 

7.06 

6.42 Boilers emitting large amounts ofNOx are 63.6 MMBtu!hr 1995 subject to Regulation 6.42 for major nitrogen 40 CFR60 

Subpart DC oxides emitting facilities. 

7.06 Standards ofPerformance for Small Industrial6.42 Commercial-Institutional Steam Generating 

63.6 MM Btu!hr 1995 Units 

40 CFR60 

Subpart DC 

Boilers with heat generating capacities greater 

7.06 than 1 mmbtu/hr, modified after April 9,1972, are 

subject to Regulation 7.06 for PM and S02. 

33.5 MMBtu/hr 1996 

40 CFR60 Standards ofPerformance for Small IndustrialSubpart DC Commercial-Institutional Steam Generating 

Units 

11. Standards/Operating Limits 

a. PM 

i. See Permit 245-09-C (R1) PAL limits. 

11. The emission standard for PM is determined in 

accordance with Regulation 7.06, section 4.1.4 

b. Opacity 

Regulation 7.06, section 5.1.1 establishes an opacity 

standard of less than 20%. 

c. S02 

1. See Permit 245-09-C (R1) PAL limits. 

ii. For Emission Point E04A, E04B and E05 the 

emission standard for so2 is determined m 

accordance with Regulation 7.06, section 5.1.1. 

iii. Emission Points E04A, E04B and E05 are subject to 

Page 6 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

40 CPR 60, Subpart De. However, there is no S02 

emission standard for natural gas fired boilers in 

Subpart De. 

d. NOx 

Regulation 6.42 requires the owner or operator shall not 

allow the NOx emissions to exceed 99 tons during any 

consecutive 12-month period in order to avoid NOx RACT. 

iii. Monitoring 

a. PM 

Maintain records of monthly natural gas and/or other fuel 

usage. 

b. Opacity 

Regulation 7.06 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. S02 

Regulation 7.06 does not require any specific monitoring 

requirements for S02, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

d. NOx 

Maintain records of monthly fuel usage, and use AP-42 

emission factors and/or fuel analysis data, to calculate 

monthly emissions. 

iv. Record Keeping 

a. PM 

See PM Monitoring. 

b. Opacity 

Regulation 7.06 does not require any specific record 

keeping requirements for opacity, however, Regulation 

Page 7 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure compliance with the terms and conditions of the 

permit. 

c. S02 

40 CFR 60, Subpart De requires records of the amount of 

fuel combusted each month. Regulation 7.06 does not 

require any specific record keeping requirements for S02, 

however, Regulation 2.16, section 4.1.9.2. requires 

sufficient record keeping to assure compliance with the 

terms and conditions ofthe permit. 

d. NOx 

The source shall calculate and record the monthly and 12 

consecutive month plant-wide NOx emissions for each 

month in the report period. 

v. Reporting 

a. PM 

Regulation 2.16, section 4.1.9 .3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. The source shall report any 

deviations from the permit. 

b. Opacity 

Regulation 2.16, section 4.1.9 .3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. 

c. S02 

There are no periodic compliance reporting requirements 

for S02. 

d. NOx 

Regulation 2.16, section 4.1.9 .3. requires sufficient 

reporting requirements to assure compliance with the terms 

and conditions of the permit. 

c. Emission Unit U008- Volatile Organic Liquid Storage Tanks 

Page 8 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

PIPE 

E08A Methanol 

Tank 

E08G UG Solvent 

Tank 

E08M Anti-Freeze 

Tank 

E08NPower 

Steering Fluid Tank 

E080 Brake Fluid 

Tank 

E08P Diesel Fuel 

Tank 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

6,000 2002 7.12 

10,000 1986 7.12 

20,000 1990 7.12 VOC storage tanks greater than 

250 gallon capacity are subject 

to Regulation 7.12 for VOC 

20,000 1990 7.12 which were installed after April 

19, 1972. 

6,000 1980 7.12 

20,000 After 1972 7.12 

ii. Standards/Operating Limits 

voc 

1) Regulation 7 .12, section 3.3 requires submerged fill if the 

materials have an as stored vapor pressure of 1.5 psia or 

greater. Regulation 7.12 applies due to the size of the tanks, 

however, since the vapor pressure as stored is less than 1.5 

psia there are no applicable emission or equipment 

standards. 

2) See Permit 245-09-C (R1) PAL limits 

111. Monitoring 

voc 

The source is required to monitor and 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. 

lV. Record Keeping 

voc 

The source shall maintain records of the material stored in each 

storage vessel. If the contents of the storage vessels are changed, a 

Page 9 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

record shall be made of the new contents, the new vapor pressure, 

and the date of the change in service. 

v. Reporting 

voc 

There are no Emission Unit specific compliance reporting 

requirements for the tanks. The source is required to report the 

throughput for purposes of demonstrating ongoing compliance 

with the plant-wide PAL VOC emission limit. 

d. Emission Unit U009- Glass Installation 

PIPE 

E009 Glass, Windshield, 

and Back Lights 

Installation 

SCH 

1. Equipment: 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

The glass installation operation 

N/A 1994 7.59 

is subject to the VOC emission 

standard in Regulation 7.59 and 

was installed after September 

1, 1976. 

ii. Standards/Operating Limits 

voc 

1) Regulation 7.59, section 3.1.3 requires the source shall not 

cause or allow the emission of VOC 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. 

2) See Permit 245-09-C (R1) PAL limits 

111. Monitoring 

voc 

Regulation 2.16, section 4.1.9 .1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

iv. Record Keeping 

Page 10 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

voc 

1) Regulation 7.59, section 6.1 and Regulation 2.16, section 

4.1.9 .2. requires sufficient record keeping to assure 

compliance with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9.2. requires the source to 

monitor the plant-wide VOC emissions during each 

consecutive 12-month period to assure the emissions of 

VOC remain below the plant-wide PAL limit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9.3. requires sufficient reporting 

requirements to assure compliance with the terms and conditions 

of the permit. 

e. Emission Unit UOlO- E-Coat Operation 

1. Equipment 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

40 CFR 63 Subpart 

IIII 

E10A E-Coat Dip N/A 1996 Tank 

40 CFR 60 Subpart 

MM 

Subpart IIII Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

IIII Automobiles and Light. 

E 1 OB E-Coat Oven N/A 1988 

40 CFR 60 Subpart 

MM 

40 CFR 63 Subpart Subpart MM establishes standards 

IIII for National Emission Standards of 

E 1 OC E-Coat Oven N/A 1996 Performance for Automobile and 

(3'd Pass) 40 CFR 60 Subpart Light Duty Truck Surface Coating 

MM Operations. 

40 CFR 63 Subpart 

E10D E-Coat Dump IIII 

Metal AST N/A 1996 

40 CFR 60 Subpart 

MM 

SCH Page 11 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

E 17 A E-Coat Scuff 

Booth 

SCH 

For Regulation 7.08 the scuff 

N/A 1989 booth is subject to PM emission 

7.08 standard and was installed after 

September 1, 1976. 

11. Standards/Operating Limits 

a. VOC 

1) The E-Coat Operation is subject is subject to 40 

CPR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CPR 

60, Subpart MM - National Emission Standards of 

Performance for Automobile and Light Duty Truck 

Surface Coating Operations section 60.392 emission 

limits. 

2) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3.1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

c. Opacity 

Regulation 7.08, section 3.1.2. establishes an opacity 

standard of less than 20%. 

iii. Monitoring 

a. VOC 

40 CPR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CPR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Truck Surface 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Page 12 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

SCH 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9.1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure 

compliance with the terms and conditions of the permit. 

iv. Record Keeping 

a. VOC 

40 CPR Part 60, Subpart MM - National Emission 

Standards of Performance for Automobile and Light Duty 

Truck Surface Coating Operations sections 60.3095 and 40 

CPR Part 63 - Surface Coating of Automobiles and Light 

Duty Trucks establishes record keeping requirement. 

Regulation 2.16, section 4.1.9.2 establishes record keeping 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9.3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

Page 13 of34 03-31-2011 
Permit No. 245-09-C (R1) 

b. 

Plant ID 0072 

PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

f. Emission Unit UOll- Guidecoat Operation 

1. Equipment: 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

Subpart IIII Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

illi Automobiles and Light-Duty 

EllA Guidecoat 

Trucks 

Paint Booth and Air N/A 1988 Subpart MM National Emission 

Supply Hose 

40 CFR 60 Subpart Standards of Performance for 

MM Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

EllB Touchup and N/A 1988 September 1, 1976. 

Blackout Booth The guidecoat operation is subject 

7.59 to the VOC emission standard in 

Regulation 7.59 and was installed 

after Stj)tember 1, 1976. 

40 CFR 63 Subpart Subpart Illi Hazardous Air IIII Pollutants: Surface Coating of 

E 11 C Guidecoat 40 CFR 60 Subpart Automobiles and Light-Duty Ovens (1st and 2nd N/A 1988 MM Trucks 

Pass) 

7.08 Subpart MM National Emission 

Standards of Performance for 

40 CFR 63 Subpart Automobile and Light Duty Truck 

E liD Guidecoat N/A 

IIII Surface Coating Operations 

Oven (3 rd Pass) 1988 establishes standards. 

40 CFR 60 Subpart 

MM 

SCH Page 14 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

PIPE 

E11E/E12G 

Guidecoat/Topcoat 

Paint Kitchen 

E 18A Guidecoat 

Scuff Booth 

SCH 

Capacity Installation Applicable Basis for Applicability Date Regulation 

For Regulation 7.08 the equipment 

is subject to PM emission standard 

7.08 and was installed after September 

1, 1976. 

40 CFR 63 Subpart Subpart IIII Hazardous Air 

IIII Pollutants: Surface Coating of 

Automobiles and Light-Duty 

Trucks 

N/A 1988 Subpart MM National Emission 

40 CFR 60 Subpart Standards ofPerformance for 

MM Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

NIA 1989 booth is subject to PM emission 

7.08 standard and was installed after 

September 1, 1976. 

11. Standards/Operating Limits 

a. VOC 

1) The Guidecoat Operation is subject to 40 CFR Part 

63, Subpart IIII - Surface Coating of Automobiles 

and Light-Duty Trucks and 40 CFR 60, Subpart 

MM -National Emission Standards of Performance 

for Automobile and Light Duty Truck Surface 

Coating Operations section 60.392 emission limits. 

2) Regulation 7.59, section 3.1.3 requires the source 

shall not cause or allow the emission ofVOC from 

any affected facility resulting from the coating of 

metallic surfaces in excess of0.42 kg ofVOC/1 (3.5 

lb ofVOC/gal) of coating, excluding water and 

exempt solvents, as applied for extreme 

performance coatings. 

3) See Permit 245-09-C (Rl) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3.1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

Page 15 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

2) See Permit 245-09-C (Rl) PAL limits 

c. Opacity 

Regulation 7.08, section 3.1.2. establishes an opacity 

standard of less than 20%. 

111. Monitoring 

a. VOC 

40 CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Truck Surface 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .I. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .I. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

IV. Record Keeping 

a. VOC 

1) 40 CFR Part 60, Subpart MM -National Emission 

Standards of Performance for Automobile and Light 

Duty Truck Surface Coating Operations sections 

60.3095 and 40 CFR Part 63 - Surface Coating of 

Automobiles and Light-Duty Trucks establishes 

record keeping requirement. Regulation 2.16, 

section 4.1.9 .2 establishes record keeping 

requirements to assure ongoing compliance with the 

terms and conditions of the permit. 

Page 16 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

2) Regulation 7.59, section 6.1 and Regulation 2.16, 

section 4.1.9 .2. requires sufficient record keeping to 

assure compliance with the terms and conditions of 

the permit. 

b. PM 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9.3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

tenns and conditions of the permit. 

g. Emission Unit U012- Topcoat Operation 

Page 17 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

1. Equipment: 

PIPE Capacity Installation Applicable Basis for Applicability Date Regulation 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

The topcoat operation is subject to 

7.59 the VOC emission standard in 

Regulation 7.59 and was installed 

E12A North Main after September 1, 1976. 

Enamel Booth and N/A 1985 Subpart IIII Hazardous Air 

Air Supply 40 CFR 63 Subpart Pollutants: Surface Coating of 

IIII Automobiles and Light-Duty 

Trucks 

Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

Automobile and Light Duty Truck MM Surface Coating Operations 

establishes standards. 

Subpart IIII Hazardous Air 

40 CFR 63 Subpart Pollutants: Surface Coating of 

IIII Automobiles and Light-Duty 

Trucks 

E12B North Main N/A 1985 Enamel Oven Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

MM Automobile and Light Duty Truck 

Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

Subpart IIII Hazardous Air 

E12C South Main 

40 CFR 63 Subpart Pollutants: Surface Coating of 

N/A 1985 IIII Automobiles and Light-Duty 

Enamel Booth Trucks 

Subpart MM National Emission 

40 CFR 60 Subpart Standards of Performance for 

Automobile and Light Duty Truck MM Surface Coating Operations 

establishes standards. 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

El2D Air Supply and September 1, 1976. 

Oven N/A 1985 Subpart MM establishes standards 

40 CFR 60 Subpart 

for National Emission Standards of 

Performance for Automobile and 

MM Light Duty Truck Surface Coating 

Operations. 

SCH Page 18 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

E12F Air Supply 

House and Oven 

E11E/E12G 

Guidecoat/Topcoat 

Kitchen 

E12H Topcoat Scuff 

Booth 

E12I TuTone/Repair 

Scuff Booth 

SCH 

For Regulation 7.08 the scuff 

7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

N/A 1985 

Subpart MM establishes standards 

40 CFR 60 Subpart for National Emission Standards of 

Performance for Automobile and MM Light Duty Truck Surface Coating 

Operations. 

Subpart MM establishes standards 

for National Emission Standards of 

N/A 1988 40 CFR 60 Subpart Performance for Automobile and MM Light Duty Truck Surface Coating 

Operations. 

For Regulation 7.08 the scuff 

N/A 1985 7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. · 

For Regulation 7.08 the scuff 

N/A 1985 7.08 

booth is subject to PM emission 

standard and was installed after 

September 1, 1976. 

ii. Standards/Operating Limits 

a. VOC 

1) The Topcoat Operation is subject is subject to 40 

CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 

60, Subpart MM - National Emission Standards of 

Performance for Automobile and Light Duty Truck 

Surface Coating Operations section 60.392 emission 

limits. 

2) Regulation 7.59, section 3.1.3. requires the source 

shall not cause or allow the emission of VOC from 

any affected facility resulting from the coating of 

metallic surfaces in excess of 0.42 kg ofVOC/1 (3.5 

lb of VOC/gal) of coating, excluding water and 

exempt solvents, as applied for extreme 

performance coatings. 

Page 19 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

3) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3.1.2. The equation to calculate the emission 

limits is E = 3.59P062, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

c. Opacity 

Regulation 7 .08, section 3 .1.2. establishes an opacity 

standard of less than 20%. 

iii. Monitoring 

a. VOC 

40 CFR Part 63, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks and 40 CFR 60, 

Subpart MM National Emission Standards of 

Performance for Automobile and Light Duty Truck Surface 

Coating Operations sections 60.392 establishes monitoring 

requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

iv. Record Keeping 

a. VOC 

Page 20 of34 03-31-2011 
Permit No. 245-09-C (R1) 

1) 

2) 

3) 

b. PM 

Plant ID 0072 

40 CFR Part 60, Subpart MM -National Emission 

Standards of Performance for Automobile and Light 

Duty Truck Surface Coating Operations sections 

60.3095 and 40 CFR Part 63 - Surface Coating of 

Automobiles and Light-Duty Trucks establishes 

record keeping requirement. Regulation 2.16, 

section 4.1.9 .2 establishes record keeping 

requirements to assure ongoing compliance with the 

terms and conditions of the permit. 

Regulation 7.59, section 6.1 and Regulation 2.16, 

section 4.1.9 .2. requires sufficient record keeping to 

assure compliance with the terms and conditions of 

the permit. 

Regulation 2.16, section 4.1.9 .1 requires the source 

to monitor the plant-wide VOC emissions during 

each consecutive 12-month period to assure the 

emissions of VOC remain below the plant-wide 

PAL limit. 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9.2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

SCH 

a. VOC 

Regulation 2.16, section 4.1.9.3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions ofthe permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

Page 21 of34 03-31-2011 
Permit No. 245-09-C (R1) 

SCH 

Plant ID 0072 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

Page 22 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

g. Emission Unit U013 -Plant-wide Product Fueling 

PIPE 

El3A Gasoline 

Tank#1 

E 13B Gasoline 

Tank #2 

El3C Gasoline 

Tank #3 

El3D Two Fueling 

Stations with Vapor 

Recovery 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

Standards ofPerformance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

Standards of Performance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

Standards ofPerformance for 

Gasoline Transfer to New 

20,000 gallons 1990 7.15 Service Station Storage 

Tanks (Stage I Vapor 

Recovery) 

N/A 1994 7.25 OR VR Equipped Vehicles 

11. Standards/Operating Limits 

voc 

Regulation 7.15 requires that storage tanks shall be equipped with 

the following: 

a. A submerged fill pipe; 

b. If the gasoline storage tank is equipped with a separate 

gauge well, a gauge well drop tube shall be installed which 

extends to within six inches of the bottom of the tank; 

c. Vent line restrictions on the affected facility; and 

d. Vapor balance system and vapor tight connections on the 

liquid fill and vapor return hoses. The cross-sectional area 

of the vapor return hose and any other vapor return 

passages in the circuit connecting the vapor space in the 

service station tank to that of the truck tank must be at least 

50% of the liquid fill hose cross-sectional area for each 

tank and free of flow restrictions to achieve acceptable 

recovery. The vapor balance equipment must be 

maintained according to the manufacturer's specifications. 

The type, size and design of the vapor balance system are 

subject to the approval of the District. 

111. Monitoring 

Page 23 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

voc 

Regulation 7.15 does not require any specific monitoring 

requirements for VOC, however, Regulation 2.16, section 4.1.9.1. 

requires sufficient monitoring to assure ongoing compliance with 

the terms and conditions of the permit. 

IV. Record Keeping 

voc 

Regulation 7.15 does not require any specific record keeping 

requirements for VOC, however, Regulation 2.16, section 4.1.9.2. 

requires sufficient record keeping to assure ongoing compliance 

with the terms and conditions of the permit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9 .3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

h. Emission Unit U014/U022- Paint Equipment Cleaning Operation 

Installation Applicable 

PIPE Capacity Date Regulation Basis for Applicability 

This regulation applies to 

each existing auto and truck 

E14 Paint manufacturing facility which 

Equipment N/A 1985 7.25 was in being or had a 

Cleaning Booth construction permit issued by 

the District before June 13, 

1979 

This regulation applies to 

each existing auto and truck 

E22APaint manufacturing facility which 

Equipment Purging N/A 1976 7.25 was in being or had a 

and Plant Cleaning construction permit issued by 

the District before June 13, 

1979 

Standards ofPerformance for 

Solvent Metal Gasoline Transfer to New 

Cleaning N/A N/A 6.18 Service Station Storage 

Equipment Tanks (Stage I Vapor 

Recovery) 

SCH Page 24 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

11. Standards/Operating Limits 

voc 

1) The source shall follow the procedure below to minimize 

VOC emissions from purge and cleaning operations under 

Regulation 7.25, section 3. 

2) For all cold solvent patis washers, the source shall comply 

with the standards of Regulation 6.18, sections 4.1 through 

4.3. 

111. Monitoring 

voc 

Regulation 2.16, section 4.1.9.1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

IV. Record Keeping 

voc 

Regulation 2.16, section 4.1.9 .2. requires sufficient record keeping 

to assure ongoing compliance with the terms and conditions of the 

permit. 

v. Reporting 

voc 

Regulation 2.16, section 4.1.9 .3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

i. Emission Unit U015- Sealer Deck 

Installation Applicable 

PIPE Capacity Date Regulation Basis for Applicability 

The sealer operation is 

E15A Sealer 

subject to the VOC emission 

N/A 1994 7.59 standard in Regulation 7.59 

Application and was installed after 

September 1, 1976. 

SCH Page 25 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

PIPE 

Sealers and 

Deadeners (other 

than glass bonding) 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

Subpart Illi establishes 

40 CFR 63 Subpart standards for Hazardous Air 

N/A N/A Pollutants: Surface Coating IIII of Automobiles and LightDuty Trucks 

ii. Standards/Operating Limits 

voc 

1) Regulation 7.5 9, section 3 .1.3. requires the source shall not 

cause or allow the emission of VOC from any affected 

facility resulting from the coating of metallic surfaces in 

excess of 3.5 lb VOC/gal of coating, excluding water and 

exempt solvents, as applied for extreme performance 

coatings. 

2) See Permit 245-09-C (R1) PAL limits 

iii. Monitoring 

voc 

Regulation 2.16, section 4.1.9.1. requires sufficient monitoring to 

assure ongoing compliance with the terms and conditions of the 

permit. 

tv. Record Keeping 

voc 

1) Regulation 7.59, section 6.1 and Regulation 2.16, section 

4.1.9 .2. requires sufficient record keeping to assure 

compliance with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9.2. requires the source to 

monitor the plant-wide VOC emissions during each 

consecutive 12-month period to assure the emissions of 

VOC remain below the plant-wide PAL limit. 

v. Reporting 

voc 

Page 26 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

Regulation 2.16, section 4.1.9.3. establishes reporting requirements 

to assure ongoing compliance with the terms and conditions of the 

permit. 

j. Emission Unit U016- Final Repair Spray Booth; infrared curing, and spot repair 

bays for repairing coating on vehicles 

PIPE 

E16A Final Repair 

Booth 

E16B Final Repair 

Oven 

SCH 

Installation Applicable 

Capacity Date Regulation Basis for Applicability 

7.08 For Regulation 7.08 the scuff 

booth is subject to PM 

40 CFR 63 Subpart emission standard and was 

N/A 1982 IIII installed after September 1, 

1976. 

40 CFR 60 Subpart 

MM 

Subpart IIII establishes 

7.08 standards for Hazardous Air 

Pollutants: Surface Coating 

40 CFR 63 Subpart of Automobiles and LightIIII Duty Trucks 

N/A 1982 Subpart MM establishes 

standards for National 

40 CFR 60 Subpart Emission Standards of 

MM Performance for Automobile 

and Light Duty Truck 

Surface Coating Operations. 

ii. Standards/Operating Limits 

a. VOC 

1) TheE-Coat Operation is subject to 40 CPR Part 60, 

Subpart IIII - Surface Coating of Automobiles and 

Light-Duty Trucks. 40 CPR 60, Subpart IIII section 

60.392 emission limits. 

2) See Permit 245-09-C (R1) PAL limits 

b. PM 

1) The PM limits are calculated per Regulation 7.08, 

section 3 .1.2. The equation to calculate the emission 

limits is E = 3.59P0

·

62, where P is expressed in 

tons/hr. 

2) See Permit 245-09-C (R1) PAL limits 

Page 27 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

c. Opacity 

Regulation 7.08, section 3.1.2. establishes an opacity 

standard of less than 20%. 

m. Monitoring 

a. VOC 

40 CFR Part 60, Subpart lUI - Surface Coating of 

Automobiles and Light-Duty Trucks sections 60.392 

establishes monitoring requirements. 

b. PM 

Regulation 7.08 does not require any specific monitoring 

requirements for PM, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure ongoing 

compliance with the terms and conditions of the permit. 

c. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

IV. Record Keeping 

a. VOC 

1) 40 CFR Part 60, Subpart IIII - Surface Coating of 

Automobiles and Light-Duty Trucks sections 

60.395 establishes record keeping requirement. 

Regulation 2.16, section 4.1.9.2. establishes record 

keeping requirements to assure ongoing compliance 

with the terms and conditions of the permit. 

2) Regulation 2.16, section 4.1.9.2. requires the source 

to monitor the plant-wide VOC emissions during 

each consecutive 12-month period to assure the 

emissions of VOC remain below the plant-wide 

PAL limit. 

b. PM 

Page 28 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

See PM Monitoring. 

c. Opacity 

Regulation 7.08 does not require any specific record 

keeping requirements for opacity, however, Regulation 

2.16, section 4.1.9 .2. requires sufficient record keeping to 

assure ongoing compliance with the terms and conditions 

of the permit. 

v. Reporting 

a. VOC 

Regulation 2.16, section 4.1.9.3. establishes reporting 

requirements to assure ongoing compliance with the terms 

and conditions of the permit. 

b. PM 

Regulation 7.08 does not require any specific reporting 

requirements for PM, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions ofthe permit. 

c. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

k. Emission Unit U025- Twelve (12) Direct Heat Exchangers 

U025 Emission Points 

ID Description Applicable Regulation Control Device 

6.42 

E25 Direct Heat Exchangers N/A 

7.08 

11. Standards/Operating Limits 

a. PM 

SCH Page 29 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

The PM limits are calculated per Regulation 7.08, section 

3.1.2. The equation to calculate the emission limits is E = 

3.59P0

·

62, where P is expressed in tons/hr. The maximum 

throughput is less than 1,000 pounds per hour; therefore, 

the PM emission standard is 2.34 lb/hr. 

b. Opacity 

Regulation 7 .08, section 3 .1.1. establishes an opacity 

standard of less than 20%. 

c. NOx 

Per Regulation 6.42, the owner or operator shall not allow 

or cause the plant-wide NOx emissions to equal or exceed 

100 tons during any consecutive 12-month period in order 

to avoid NOx RACT. 

111. Monitoring 

IV. 

SCH 

a. PM 

There are no compliance monitoring requirements for this 

equipment. The potential uncontrolled PM emissions are 

less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9 .1. requires sufficient monitoring to assure compliance 

with the terms and conditions of the permit. 

c. NOx 

a. 

Regulation 7.08 does not require any specific monitoring 

requirements for NOx, however, Regulation 2.16, section 

4.1.9 .1. establishes monitoring requirements to assure 

ongoing compliance with the terms and conditions of the 

permit. 

Record Keeping 

PM 

Page 30 of34 03-31-2011 
Permit No. 245-09-C (R1) Plant ID 0072 

There are no compliance record keeping requirements for 

this equipment. The potential uncontrolled PM emissions 

are less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific monitoring 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.2. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. NOx 

Regulation 7.08 does not require any specific record 

keeping requirements for NOx, however, Regulation 2.16, 

section 4.1.9 .2. requires sufficient record keeping to assure 

ongoing compliance with the terms and conditions of the 

permit. 

v. Reporting 

a. PM 

There are no routine compliance reporting requirements for 

this equipment. The potential uncontrolled PM emissions 

are less than the applicable emission standard. 

b. Opacity 

Regulation 7.08 does not require any specific reporting 

requirements for opacity, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

c. NOx 

Regulation 7.08 does not require any specific reporting 

requirements for NOx, however, Regulation 2.16, section 

4.1.9.3. requires reporting to assure compliance with the 

terms and conditions of the permit. 

III. Other Requirements 

SCH 

1. Temporary Sources: The source did not request to operate any temporary 

facilities. 

Page 31 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

2. Short Term Activities: The source did not report ant short term activities. 

3. Emissions Trading: N/A 

4. Alternative Operating Scenarios: The source did not request to operate under 

any alternative operating scenarios. 

5. Compliance Status: Ford Motor Company-Louisville Assembly Plant is required 

to submit their annual Compliance Certification to the District on or before April 

15th of each calendar year. As ofthe effective date ofPermit 245-09-C (Rl), there 

are no compliance schedules in effect or progress reports required. 

6. Insignificant Activities 

Insignificant Activities 

Description Quantity Basis 

Internal combustion engines Various Regulation 2.02, Section 2.2 fixed or mobile 

Presses extruding Various Regulation 2.02, Section 2.3.1 metal/mineral/wood 

Brazing, soldering or Various Regulation 2.02, Section 2.3.4 welding equipment 

Woodworking, except for 

conveying, hogging, or Various Regulation 2.02, Section 2.3.5 

burning wood/sawdust 

Lab venting and exhaust 

systems (non radioactive Various Regulation 2.02, Section 2.3 .11 

materials) 

Ventilation systems - Various Regulation 2.02, Section 2.3.12 bakeries & restaurants 

Washing or drying fabricated metal or glass; non Various Regulation 2.02, Section 2.3.15 

VOC use; no oil or solid fuel 

Residential/domestic Various Regulation 2.02, Section 2.3.12 equipment 

Portable diesel or gasoline Various Regulation 2.02, Section 2.3.23 

storage tanks 

Diesel fuel storage tanks Various Regulation 2.02, Section 2.3.25 (emergency use only) 

Closed pressure storage 2 Regulation 2.02, Section 2.3.26 vessels 

SCH Page 32 of34 03-31-2011 
Permit No. 245-09-C (Rl) Plant ID 0072 

Insignificant Activities 

Description Quantity Basis 

Portable tote tanks for raw Tote tanks are kept closed when not in use. Emission from tanks material shipment of solvent Various are negligible, and are accounted for by process material balance. - based coatings 

Backup generators for 

emergency power.(< 500 2 Generators normal use is very low and HP <500 HP. 

hrs/year) 

Wastewater Pretreatment 1 Emissions insignificant system. 

Fluid Fill (hydraulic fluids, Emissions insignificant due to low vapor pressure of materials oil, anti-freeze) and Various used. Lubricating operations. 

Miscellaneous mainten-ance 

procedures includ-ing Various Negligible emissions lubrication, grinding, 

cleaning, woodworking, etc. 

Direct heat exchangers <1 Various Regulation 2.02, Section 2.1.1 MMBtu/hr 

SCH 

a. Insignificant Activities are only those activities or processes falling into the 

general categories defined in District Regulation 2.02, Section 2, and not 

associated with a specific operation or process for which there is a specific 

regulation. Equipment associated with a specific operation or process (Emission 

Unit) shall be listed with the specific process even though there may be no 

applicable requirements. Information contained in the permit and permit 

summary shall clearly indicate that those items identified with negligible 

emissions have no applicable requirements. 

b. Activities identified in District Regulation 2.02, Section 2, may not require a 

permit and may be insignificant with regard to application disclosure 

requirements but may still have generally applicable requirements that continue to 

apply to the source. 

c. For all insignificant activities that emit regulated air pollutants for which the 

company has accepted a plant-wide synthetic minor limit, the company shall 

maintain sufficient records to calculate the emissions and report those emissions 

in the quarterly compliance reports and the annual emissions inventory report. 

d. The Insignificant Activities table is correct as of the date the permit was proposed 

for review by the USEP A, Region 4. The company shall submit an updated list of 

insignificant activities annually with the Title V compliance certification pursuant 

to District Regulation 2.16, section 4.3.5.3.6. 

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Permit No. 245-09-C (R1) Plant ID 0072 

SCH 

e. In lieu of recording annual throughputs for each Insignificant Activity, the owner 

or operator may elect to report the Potential To Emit quantity listed in the 

Insignificant Activities table as the annual emission for each piece of equipment, 

since the emissions from the source's Insignificant Activities are minor. 

Page 34 of34 03-31-2011