Page: 1 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 Mi chigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).Lacks Enterprises Staff Report

Page: 2 TABLE OF CONTENTS

January 22, 2007 STAFF REPORT 3

March 6, 2007 STAFF REPORT ADDENDUM 8Lacks Enterprises Staff Report

Page: 3 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 52 nd 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, 2007Lacks Enterprises Staff Report

Page: 4 Source Description

The applicant manufactures exterior plastic automotive parts. The stationary source consists of five (5) buildings, 52 nd Paint East, 52 nd Paint West, 52 nd Mold, Barden Plating, and Barden Distribution. The 52 nd
Paint East facility primarily consists of one (1) main coating line that applies a prime, base and clear coat to the exterior plastic automotive par t as required by the customer. The 52 nd 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 52 nd Paint East and Paint West are recirculating booths with the emissions captur ed and destroyed in regenerative thermal oxidizers.

The 52 nd 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 (NO

x ) 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.Lacks Enterprises Staff Report

Page: 5 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 Maximu m 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 FGBRIM ICRONI 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 439-96Lacks Enterprises Staff Report

Page: 6 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.Lacks Enterprises Staff Report

Page: 7 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 deter mination for ROP approval/disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditi ons, and resolution of any objections by the

USEPA.Lacks Enterprises Staff Report

Page: 8 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 12 th 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.Lacks Enterprises Staff Report

Page: 9 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