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Michigan Department of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT ROP Number 

N2079 STAFF REPORT MI-ROP-N2079-2007

Lacks Enterprises 

SRN: N2079 

Located at 

4375 52nd Street, Kentwood, Michigan 49512 

 

Permit Number: MI-ROP-N2079-2007 

Staff Report Date: January 22, 2007 

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

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

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

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

of the Renewable Operating Permit (ROP). 
Lacks Enterprises 

Staff Report 

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TABLE OF CONTENTS 

January 22, 2007 STAFF REPORT 3

March 6, 2007 STAFF REPORT ADDENDUM 8
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Michigan Department of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT ROP Number 

N2079

January 22, 2007 STAFF REPORT 

MI-ROP-N2079-2007

Purpose

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

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

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

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

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

federal air quality requirements into one document. 

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

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

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

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

stationary source. 

General Information

Stationary Source Mailing Address: Lacks Enterprises 

4365 52nd Street SE 

Kentwood, MI 49512 

Source Registration Number (SRN): N2079 

Standard Industrial Classification (SIC) Code: 3714 

Number of Stationary Source Sections: 2 

Is Application for a Renewal or Initial Issuance? Renewal 

Application Number: 200500088 

Responsible Official: Bill Nieboer, General Manager 

616-554-2300 

AQD Contact: David L. Morgan, Sr. Environmental Quality 

Analyst 

616-356-0009 

Date Permit Application Submitted: April 1, 2005 

Date Application Was Administratively Complete: April 14, 2005 

Is Application Shield In Effect? Yes 

Date Public Comment Begins: January 22, 2007 

Deadline for Public Comment: February 21, 2007 
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Source Description

The applicant manufactures exterior plastic automotive parts. The stationary source consists of five (5) 

buildings, 52nd Paint East, 52nd Paint West, 52nd Mold, Barden Plating, and Barden Distribution. The 52nd 

Paint East facility primarily consists of one (1) main coating line that applies a prime, base and clear coat 

to the exterior plastic automotive part as required by the customer. The 52nd Paint West facility consists 

of eight (8) robotic booths that apply resist coatings and eleven (11) manual booths that apply top coats 

to exterior plastic automotive parts. All the robotic booths at both the 52nd Paint East and Paint West are 

recirculating booths with the emissions captured and destroyed in regenerative thermal oxidizers. 

The 52nd Mold facility has 24 injection molding machines. The injection molding process is exempt from 

New Source Review (NSR) permitting and Rule 210 pursuant to Rule 212(2). 

The Barden Distribution consists of several coating booths and adhesive booths exempt from New 

Source Review permitting pursuant to Rule 287(a) and Rule 287(c). 

The Barden Plating facility conducts decorative chrome electroplating primarily on plastic automotive 

parts, but also on plumbing fixtures, household appliances and business machines. The process 

consists of pretreatment, alkaline cleaning, acid dipping, and strike plating of copper, copper 

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

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

composite mesh pad scrubbers. 

The following table lists stationary source emission information as reported in Michigan Air Emissions 

Reporting System for 2006 submittal. 

TOTAL STATIONARY SOURCE EMISSIONS 

Pollutant Tons per Year 

Carbon Monoxide (CO) 2.0 

Nitrogen Oxides (NOx) 10.5 

Particulate Matter (PM) 0.9 

Volatile Organic Compounds (VOCs) 148.0 

Chromium VI 0.002 

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

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

subject to process-specific emission limits or standards. 

Regulatory Analysis

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

Part E of the ROP. 

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

(USEPA) as a marginal non-attainment area with respect to the 8-hour ozone standard. 
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The stationary source is subject to Title 40 of the Code of Federal Regulations, Part 70, because the 

potential to emit of VOCs exceeds 100 tons per year. The facility is also considered a major source of 

Hazardous Air Pollutant (HAP) emissions due to potential to emit of any single HAP regulated by the 

Clean Air Act, Section 112 is greater than 10 tons per year and the potential to emit of all HAPs 

combined is greater than 25 tons per year. 

The stationary source is not subject to R 336.1220 for Major Offset Sources. 

The stationary source is subject to the Maximum Achievable Control Technology Standard for Plastic 

Parts Surface Coating promulgated in Title 40 of the Code of Federal Regulations (40 CFR), Part 63, 

Subpart PPPP and for Chromium Electroplating promulgated under 40 CFR Part 63, Subpart N, and the 

General Provisions under 40 CFR Part 63, Subpart A.

FGEASTPAINT is subject to Rule 702 Best Achievable Control Technology (BACT) and toxic air 

contaminant requirements under Rule 225. 

 

FGWESTROBOPAINT, FGWESTMANUAL, and FGWESTMISCSOLVENTS are subject to Rule 632 

requirements for plastic automotive coatings. 

FGCHROME1, FGCHROME2, FGSEMINICKEL, and FGBRIMICRONI are subject to Rule 225. The 

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

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

Submittals." 

The stationary source is subject to the federal Compliance Assurance Monitoring (CAM) rule under Title 

40 of the Code of Federal Regulations, Part 64, because the automated coating booths at the Paint East 

and West facilities have both a control device and potential pre-control emissions of volatile organic 

compounds greater than the major source threshold level. CAM requirements are included in this ROP. 

There are no applicable CAM rule requirements at the Barden Plating facility. 

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

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

Source-wide Permit to Install (PTI)

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

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

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

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

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

and subsequently voided. 

PTI Number 

814-93 80-89C 440-91A 439-96 
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Equivalent Requirements

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

R 336.1212(6). Equivalent requirements are enforceable applicable requirements that are equivalent to 

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

Order/Judgment. 

Non-applicable Requirements

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

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

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

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

Processes in Application Not Identified in Draft ROP

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

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

any applicable requirement. 

Exempt 

Emission Unit ID 

Description of 

Exempt Emission Unit 

ROP 

Exemption 

NSR Permit 

Exemption 

EUAIRMAKEUPUNIT Facility air make-up units R 336.1212(4) R 336.1282(b) 

EUPLASTICMOLD Plastic injection molding 

machines located in 52nd 

Street Mold facility. 

R 336.1212(4) R 336.1286(b) 

EUSML-ASSBLY-OPS Small assembly stations using 

adhesive to assemble plastic 

component parts. Stations are 

located at Paint East and Paint 

West facilities. Adhesive usage 

is less than 2 gallons per day. 

R 336.1212(4) R 336.1287(a) 

Draft ROP Terms/Conditions Not Agreed to by Applicant

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

upon pursuant to Rule 214(2). 

Compliance Status

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

requirements as of the effective date of this ROP. 
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Action taken by the DEQ

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

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

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

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

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

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

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

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

USEPA. 
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Michigan Department of Environmental Quality 

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT ROP Number 

N2079

March 6, 2007 STAFF REPORT ADDENDUM 

MI-ROP-N2079-2007

Purpose

A Staff Report dated January 22, 2007, was developed in order to set forth the applicable requirements 

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

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

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

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

comments. 

General Information

Responsible Official: Bill Nieboer, General Manager 

616-554-2300 

AQD Contact: David L. Morgan, Sr. Environmental Quality Analyst 

616-356-0009 

Summary of Pertinent Comments

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

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

FG-EAST-PAINT, Pages 34 & FGWESTROBOPAINT Page 41 

Comment: The applicant requested that the RTO temperature limit of 1,400°F be based on a one-hour 

average. The applicant provided documentation which showed that an excursion in 40 CFR §64.1 

means a departure from an indicator range established for monitoring, consistent with an averaging 

period. 

Response: The 1,400°F temperature limit for the RTO is considered an instantaneous limit and was 

established in an air use permit pursuant to Rule 201(1)(a). The applicant can choose to have an 

averaging period established for the limit, but this must go through the New Source Review process. 

FGSUBPART PPPP, Requirement IX.1 

Comment: The applicant commented that under 40 CFR Part 63, Subpart PPPP the initial compliance 

period starts with the applicable compliance date and ends on the last day of the 12th month following the 

compliance date. The applicant wanted to make clear that the company has 12 months to demonstrate 

initial compliance with 40 CFR Part 63, Subpart PPPP. 

Response: The AQD agrees that the initial compliance period ends 12 months after the compliance date. 

For simplification, the AQD will remove reference to the compliance dates and require that the permittee 

comply with all applicable provisions of 40 CFR Part 63, Subparts A and PPPP. 
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Changes to the January 22, 2007 Draft ROP

FGSUBPART PPPP, Requirement IX.1 - The phrase, “by the initial compliance date” has been 

removed from the requirement. 

Prepared by David L. Morgan, Environmental Quality Analyst