Page 1 of 116 

Michigan Department of Environmental Quality 

Air Quality Division

EFFECTIVE DATE: April 30, 2007 

ISSUED TO 

Lacks Enterprises, Inc. 

State Registration Number (SRN): N2079 

LOCATED AT 

4375 52nd Street, Kentwood, Michigan 49512 

RENEWABLE OPERATING PERMIT 

Permit Number: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

Administratively Complete ROP Renewal Application 

Due Between October 30, 2010 and October 31, 2011 

This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of 

Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection 

Act, 1994 PA 451, as amended. Pursuant to Michigan Air Pollution Control Rule 210(1), this ROP 

constitutes the permittee’s authority to operate the stationary source identified above in accordance with 

the general conditions, special conditions and attachments contained herein. Operation of the stationary 

source and all emission units listed in the permit are subject to all applicable future or amended rules and 

regulations pursuant to PA 451 and the federal Clean Air Act. 

SOURCE-WIDE PERMIT TO INSTALL 

Permit Number: MI-PTI-N2079-2007 

This Permit to Install (PTI) is issued in accordance with and subject to Section 5505(5) of Article II, 

Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 

PA 451, as amended. Pursuant to Michigan Air Pollution Control Rule 214a, the terms and conditions 

herein, identified by the underlying applicable requirement citation of Rule 201(1)(a), constitute a federally 

enforceable PTI. The PTl terms and conditions do not expire and remain in effect unless the criteria of 

Rule 201(6) are met. Operation of all emission units identified in the PTI is subject to all applicable future 

or amended rules and regulations pursuant to PA 451 and the federal Clean Air Act. 

Michigan Department of Environmental Quality 

______________________________________ 

Heidi G. Hollenbach, Grand Rapids District Supervisor
 ROP No: MI-ROP-N2079-2007

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 2 of 116 

TABLE OF CONTENTS

AUTHORITY AND ENFORCEABILITY......................................................................................................5

Section 1 – 52nd Street Paint East; 52nd Street Paint West; 52nd Street Mold; and Barden 

Distribution................................................................................................................................................6

A. GENERAL CONDITIONS .....................................................................................................................7

Permit Enforceability ...................................................................................................................................7

General Provisions......................................................................................................................................7

Equipment & Design ...................................................................................................................................8

Emission Limits ...........................................................................................................................................8

Testing/Sampling ........................................................................................................................................8

Monitoring/Recordkeeping ..........................................................................................................................9

Certification & Reporting .............................................................................................................................9

Permit Shield.............................................................................................................................................10

Revisions ..................................................................................................................................................11

Reopenings...............................................................................................................................................12

Renewals ..................................................................................................................................................12

Stratospheric Ozone Protection ................................................................................................................12

Risk Management Plan.............................................................................................................................12

Emission Trading ......................................................................................................................................13

Permit To Install (PTI) ...............................................................................................................................13

B. SOURCE-WIDE CONDITIONS...........................................................................................................14

C. EMISSION UNIT CONDITIONS..........................................................................................................17

EMISSION UNIT SUMMARY TABLE .......................................................................................................17

EUPRIMEMANUAL...................................................................................................................................22

EUBASEMANUAL ....................................................................................................................................25

EUCLEARMANUAL ..................................................................................................................................28

D. FLEXIBLE GROUP CONDITIONS .....................................................................................................31

FLEXIBLE GROUP SUMMARY TABLE ...................................................................................................31

FGEASTPAINT .........................................................................................................................................33

FGWESTROBOPAINT .............................................................................................................................39

FGWESTMANUAL....................................................................................................................................44

FGWESTMISCSOLVENT.........................................................................................................................48

FGSUBPART PPPP .................................................................................................................................52

FGRULE290 .............................................................................................................................................59

FGRULE287(c) .........................................................................................................................................62

FGCOLDCLEANERS................................................................................................................................64

E. NON-APPLICABLE REQUIREMENTS...............................................................................................67

APPENDICES...........................................................................................................................................68

Appendix 1-1: Abbreviations & Acronyms................................................................................................68

Appendix 1-2. Schedule of Compliance...................................................................................................69

Appendix 1-3. Monitoring Requirements..................................................................................................69

Appendix 1-4. Recordkeeping..................................................................................................................69

Appendix 1-4.A .........................................................................................................................................70
 ROP No: MI-ROP-N2079-2007

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 3 of 116 

Appendix 1-4.B .........................................................................................................................................71

Appendix 1-4.C .........................................................................................................................................72

Appendix 1-5. Testing Procedures...........................................................................................................73

Appendix 1-6. Permits to Install ...............................................................................................................73

Appendix 1-7. Emission Calculations.......................................................................................................73

Appendix 1-8. Reporting ..........................................................................................................................73

Appendix 1-9. Operation and Maintenance Plan ......................................................................................74

Section 2 - Barden Plating .....................................................................................................................75

A. GENERAL CONDITIONS ...................................................................................................................76

Permit Enforceability .................................................................................................................................76

General Provisions....................................................................................................................................76

Equipment & Design .................................................................................................................................77

Emission Limits .........................................................................................................................................77

Testing/Sampling ......................................................................................................................................77

Monitoring/Recordkeeping ........................................................................................................................78

Certification & Reporting ...........................................................................................................................78

Permit Shield.............................................................................................................................................79

Revisions ..................................................................................................................................................80

Reopenings...............................................................................................................................................81

Renewals ..................................................................................................................................................81

Stratospheric Ozone Protection ................................................................................................................81

Risk Management Plan.............................................................................................................................81

Emission Trading ......................................................................................................................................82

Permit To Install (PTI) ...............................................................................................................................82

B. SOURCE-WIDE CONDITIONS...........................................................................................................83

C. EMISSION UNIT CONDITIONS..........................................................................................................84

EMISSION UNIT SUMMARY TABLE .......................................................................................................84

EUCONDITIONER....................................................................................................................................87

EUELECTROLESSNI ...............................................................................................................................89

EUELECTROLESSCU..............................................................................................................................91

D. FLEXIBLE GROUP CONDITIONS .....................................................................................................94

FLEXIBLE GROUP SUMMARY TABLE ...................................................................................................94

FGCHROME1 ...........................................................................................................................................95

FGNEUTCATACC ....................................................................................................................................98

FGCOPPER............................................................................................................................................100

FGSEMINICKEL .....................................................................................................................................102

FGBRIMICRONI .....................................................................................................................................104

FGCHROME2 .........................................................................................................................................106

FGSTRIPTANKS ....................................................................................................................................111

E. NON-APPLICABLE REQUIREMENTS.............................................................................................113

APPENDICES.........................................................................................................................................114

Appendix 2-1: Abbreviations & Acronyms..............................................................................................114

Appendix 2-2. Schedule of Compliance.................................................................................................115

Appendix 2-3. Monitoring Requirements................................................................................................115

Appendix 2-4. Recordkeeping................................................................................................................115
 ROP No: MI-ROP-N2079-2007

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 4 of 116 

Appendix 2-5. Testing Procedures.........................................................................................................115

Appendix 2-6. Permits to Install .............................................................................................................115

Appendix 2-7. Emission Calculations.....................................................................................................115

Appendix 2-8. Reporting ........................................................................................................................116

Appendix 2-9. Operation and Maintenance Plan ....................................................................................116
 ROP No: MI-ROP-N2079-2007

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 5 of 116 

AUTHORITY AND ENFORCEABILITY 

For the purpose of this permit, the permittee is defined as any person who owns or operates an 

emission unit at a stationary source for which this permit has been issued. The department is defined in 

Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her 

designee. 

The permittee shall comply with all specific details in the permit terms and conditions and the cited 

underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable 

and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most 

stationary sources for which an ROP has been issued. These general conditions are included in Part A 

of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units 

which are represented as a flexible group, or the entire stationary source which is represented as a 

Source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices. 

In accordance with Rule 213(2)(a), all underlying applicable requirements will be identified for each ROP 

term or condition. All terms and conditions that are included in a Permit to Install (PTI), are streamlined 

or subsumed, or are state-only enforceable will be noted as such. 

In accordance with Section 5507 of Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural 

Resources and Environmental Protection Act, 1994 PA 451, as amended, the permittee has included in 

the ROP application a compliance certification, a schedule of compliance, and a compliance plan. For 

applicable requirements with which the source is in compliance, the source will continue to comply with 

these requirements. For applicable requirements with which the source is not in compliance, the source 

will comply with the detailed schedule of compliance requirements that are incorporated as an appendix 

in this ROP. Furthermore, for any applicable requirements effective after the date of issuance of this 

ROP, the stationary source will meet the requirements on a timely basis, unless the underlying applicable 

requirement requires a more detailed schedule of compliance. 

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law. 

This permit does not relieve the permittee from any responsibilities or obligations imposed on the 

permittee, at this source, under Consent Order No. 29-2006, entered on September 27, 2006, between 

the MDEQ and the permittee. 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 6 of 116 

Section 1 – 52nd Street Paint East; 52nd Street Paint West; 52nd Street Mold; 

and Barden Distribution 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 7 of 116 

A. GENERAL CONDITIONS 

Permit Enforceability 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5))

• Those conditions that are hereby incorporated in a state-only enforceable Source-wide Permit to Install (PTI) 

pursuant to Rule 201(2)(d) are designated by Footnote 1. (R 336.1213(5)(a), R 336.1214a(5))

• Those conditions that are hereby incorporated in federally enforceable Source-wide PTI No. MI-PTI-N2079-2007 

pursuant to Rule 201(2)(c) are designated by Footnote 2. (R 336.1213(5)(b), R 336.1214a(3))

General Provisions 

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of 

Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 

1994 PA 451, as amended (Act 451), and is grounds for enforcement action, for ROP revocation or revision, or 

for denial of the renewal of the ROP. All terms and conditions of this ROP that are designated as federally 

enforceable are enforceable by the Administrator of the United States Environmental Protection Agency (EPA) 

and by citizens under the provisions of the federal Clean Air Act (CAA). Any terms and conditions based on 

applicable requirements which are designated as “state only” are not enforceable by the EPA or citizens 

pursuant to the CAA. (R 336.1213(1)(a))

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or 

reduce the permitted activity in order to maintain compliance with the conditions of this ROP. 

(R 336.1213(1)(b))

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit 

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make 

changes, at the permittee’s own risk, pursuant to Rules 215 and 216. (R 336.1213(1)(c))

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation 

of credentials and other documents as may be required by law and upon stating the authority for and purpose 

of the investigation, to perform any of the following activities (R 336.1213(1)(d)): 

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity is 

conducted or where records must be kept under the conditions of the ROP. 

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

ROP. 

c. Inspect, at reasonable times, any of the following: 

i. Any stationary source. 

ii. Any emission unit. 

iii. Any equipment, including monitoring and air pollution control equipment. 

iv. Any work practices or operations regulated or required under the ROP. 

d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the ROP or applicable requirements. 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 8 of 116 

5. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to 

determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies 

of any records that are required to be kept as a term or condition of this ROP. For information which is claimed 

by the permittee to be confidential, consistent with the requirements of 1976 PA 442, MCL §15.231 et seq., and 

known as the Freedom of Information Act, the person may also be required to furnish the records directly to the 

EPA together with a claim of confidentiality. (R 336.1213(1)(e))

6. A challenge by any person, the Administrator of the EPA, or the department to a particular condition or a part of 

this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other 

condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of 

Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

Equipment & Design 

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370)

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance 

with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

Emission Limits 

11. Except as provided in subrules 2, 3, and 4 of Rule 301, a person shall not cause or permit to be discharged into 

the outer air from a process or process equipment a visible emission of a density greater than the most 

stringent of Rule 301(1)(a) or (b) unless otherwise specified in this ROP. The grading of visible emissions shall 

be determined in accordance with Rule 303. (R 336.1301(1) in pertinent part): 

a. A 6-minute average of 20% opacity, except for one 6-minute average per hour of not more than 27% 

opacity. 

b. A limit specified by an applicable federal new source performance standard. 

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or in reaction with other air contaminants, either of the following: 

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.1 

(R 336.1901(a)) 

b. Unreasonable interference with the comfortable enjoyment of life and property.1 (R 336.1901(b)) 

Testing/Sampling 

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner’s or operator’s expense, in accordance with Rule 1001 and Rule 1003, under 

any of the conditions listed in Rule 1001(1). (R 336.2001)

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and 

Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 9 of 116 

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days following the last date of the test. (R 336.2001(4))

Monitoring/Recordkeeping 

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following 

information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)): 

a. The date, location, time, and method of sampling or measurements. 

b. The dates the analyses of the samples were performed. 

c. The company or entity that performed the analyses of the samples. 

d. The analytical techniques or methods used. 

e. The results of the analyses. 

f. The related process operating conditions or parameters that existed at the time of sampling or 

measurement. 

17. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records, for continuous monitoring instrumentation and copies of all reports required by the ROP. 

(R 336.1213(1)(e), R 336.1213(3)(b)(ii))

Certification & Reporting 

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be 

submitted to the department as a term or condition of this ROP shall contain an original certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

19. A responsible official shall certify to the appropriate District Office of the AQD and the EPA that the stationary 

source is and has been in compliance with all terms and conditions contained in the ROP except for deviations 

that have been or are being reported to the appropriate District Office of the AQD pursuant to Rule 213(3)(c). 

This certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and shall state that, 

based on information and belief formed after reasonable inquiry, the statements and information in the 

certification are true, accurate, and complete. The EPA address is: US EPA, Air Compliance Data - Michigan, 

Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL, 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special 

conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt 

reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise 

described in this ROP (R 336.1213(3)(c)): 

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to 

this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to 

Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the 

semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and 

the actions taken to minimize or correct each deviation. 

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 10 of 116 

22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in 

Rule 213(3)(c)(iii) as either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible official with each report which states that, based on information 

and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports 

of deviations from the emissions allowed under the ROP were submitted to the department pursuant to 

Rule 213(3)(c)(ii), a certification by a responsible official which states that, based on information and belief 

formed after reasonable inquiry, the statements and information contained in each of the reports submitted 

during the previous month were true, accurate, and complete. The certification shall include a listing of the 

reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a 

monthly basis pursuant to this paragraph shall include a statement that certification of the report will be 

provided within 30 days following the end of the calendar month. 

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate District Office of the AQD. 

All instances of deviations from ROP requirements during the reporting period shall be clearly identified in the 

reports. (R 336.1213(3)(c)(i))

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine 

the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required in Rule 912, to the appropriate District Office of the AQD. The notice 

shall be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal 

conditions or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, or oral 

communication. Written reports, if required under Rule 912, must be submitted to the appropriate District 

Supervisor within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or 

malfunction has been corrected, or within 30 days of discovery of the abnormal conditions or malfunction, 

whichever is first. The written reports shall include all of the information required in Rule 912(5) and shall be 

certified by a responsible official in a manner consistent with the CAA. (R 336.1912)

Permit Shield 

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements 

as of the date of ROP issuance, if either of the following provisions is satisfied (R 336.1213(6)(a)(i), 

R 336.1213(6)(a)(ii)): 

a. The applicable requirements are included and are specifically identified in the ROP. 

b. The permit includes a determination or concise summary of the determination by the department that other 

specifically identified requirements are not applicable to the stationary source. 

Any requirements identified in Part E of this ROP have been identified as non-applicable to this ROP and are 

included in the permit shield. 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 11 of 116 

27. Nothing in this ROP shall alter or affect any of the following: 

a. The provisions of Section 303 of the CAA, emergency orders, including the authority of the EPA under 

Section 303 of the CAA. (R 336.1213(6)(b)(i))

b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at 

the time of this ROP issuance. (R 336.1213(6)(b)(ii))

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. 

(R 336.1213(6)(b)(iii)) 

d. The ability of the EPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the 

following: 

a. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5))

b. Administrative amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii))

c. Administrative amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved 

by the department. (R 336.1216(1)(c)(iii))

d. Minor permit modifications made pursuant to Rule 216(2). (R 336.1216(2)(f))

e. State-only modifications made pursuant to Rule 216(4) until the changes have been approved by the 

department. (R 336.1216(4)(e))

29. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration 

date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP 

does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original 

ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))

Revisions 

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the 

ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to 

Rule 216(1). (R 336.1219(3))

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the time frames specified in Rule 216. (R 336.1210(9))

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the 

department takes final action, the permittee shall comply with both the applicable requirements governing the 

change and the ROP terms and conditions proposed in the application for the modification. During this time 

period, the permittee may choose to not comply with the existing ROP terms and conditions that the application 

seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the 

application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(3), 

R 336.1216(2)(d), R 336.1216(4)(d))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 12 of 116 

Reopenings 

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under 

any of the following circumstances: 

a. If additional requirements become applicable to this stationary source with three or more years remaining in 

the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 

expiration date. (R 336.1217(2)(a)(i))

b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. 

(R 336.1217(2)(a)(ii))

c. If the department determines that the ROP contains a material mistake, information required by any 

applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or 

the terms or conditions of the ROP. (R 336.1217(2)(a)(iii))

d. If the department determines that the ROP must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv))

Renewals 

35. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by 

the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. 

(R 336.1210(7))

Stratospheric Ozone Protection 

36. If the permittee is subject to 40 CFR Part 82 and services, maintains, or repairs appliances except for motor 

vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small 

appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or 

recycling and recovery equipment, the permittee shall comply with all applicable standards for recycling and 

emissions reduction pursuant to 40 CFR Part 82, Subpart F. 

37. If the permittee is subject to 40 CFR Part 82 and performs a service on motor (fleet) vehicles when this service 

involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified in 

40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term “motor vehicle” as used in 

Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using 

Hydrochlorofluorocarbon-22 refrigerant. 

Risk Management Plan 

38. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall register and submit to the EPA 

the required data related to the risk management plan for reducing the probability of accidental releases of any 

regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 68.130. The list of 

substances, threshold quantities, and accident prevention regulations promulgated under Part 68 do not limit in 

any way the general duty provisions under Section 112(r)(1). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 13 of 116 

39. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements of 

Part 68 no later than the latest of the following dates as provided in 68.10(a): 

a. June 21, 1999, 

b. Three years after the date on which a regulated substance is first listed under 68.130, or 

c. The date on which a regulated substance is first present above a threshold quantity in a process. 

40. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 

40 CFR Part 68. 

41. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance with 

all applicable requirements of Section 112(r) as detailed in Rule 213(4)(c)). (40 CFR Part 68)

Emission Trading 

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the EPA as a part of 

Michigan’s State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. 

(R 336.1213(12))

Permit To Install (PTI) 

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt 

from the PTI requirements by any applicable rule. 2

 (R 336.1201(1)) 

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence 

indicates the process or process equipment is not performing in accordance with the terms and conditions of 

the PTI or is violating the department’s rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451, PA 1994)

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or 

operates the process or process equipment at the location authorized by the PTI. If a new owner or operator 

submits a written request to the department pursuant to Rule 219 and the department approves the request, 

this PTI will be amended to reflect the change of ownership or operational control. The request must include all 

of the information required by subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the 

appropriate AQD District Supervisor, MDEQ. 2

 (R 336.1219) 

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and 

conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, 

the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the 

department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall 

notify the department via the Supervisor, Permit Section, MDEQ, AQD, P. O. Box 30260, Lansing, MI 48909, if 

it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment allowed 

by the terms and conditions from that PTI. 2

 (R 336.1201(4)) 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 14 of 116 

B. SOURCE-WIDE CONDITIONS 

Part B outlines the Source-wide terms and conditions that apply to this stationary source. The permittee is subject 

to these special conditions for the stationary source in addition to the General Conditions in Part A and any other 

terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in 

the table. If there are no Source-wide conditions, this section will be left blank. 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 15 of 116 

SOURCE-WIDE CONDITIONS

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 249.0 tons per 

year 

12-month rolling 

time period as 

determined at 

the end of each 

calendar month.

Source-wide SC VI.1 R 336.1213(2)

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall calculate and record the stationary Source-wide, emission rates, in tons, for volatile 

organic compound for each calendar month and each 12-month rolling time period, as determined at the end 

of each calendar month. (R 336.1213(3))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 16 of 116 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

NA NA NA NA 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 17 of 116 

C. EMISSION UNIT CONDITIONS 

Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit 

Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General 

Conditions in Part A and any other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no conditions specific to individual emission units, this section will be left blank. 

EMISSION UNIT SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUPRIMEROBOT1 An automatic spray booth used to apply 

prime/adhesion prime coatings to plastic 

parts. Emissions from the booth are 

controlled by a common regenerative 

thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUPRIMEROBOT2 An automatic spray booth used to apply 

prime/adhesion prime coatings to plastic 

parts. Emissions from the booth are 

controlled by a common regenerative 

thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUPRIMEMANUAL A manual spray booth used to apply 

prime/adhesion prime coatings to plastic 

parts. 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUBASEROBOT1 An automatic spray booth used to apply 

base coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUBASEROBOT2 An automatic spray booth used to apply 

base coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUBASEROBOT3 An automatic spray booth used to apply 

base coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUBASEROBOT4 An automatic spray booth used to apply 

base coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUBASEMANUAL A manual spray booth used to apply base 

coatings to plastic parts. 

05/04/1994, 

04/02/2002 

FGEASTPAINT 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 18 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUCLEARROBOT1 An automatic spray booth used to apply 

clear coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUCLEARROBOT2 An automatic spray booth used to apply 

clear coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUCLEARROBOT3 An automatic spray booth used to apply 

clear coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUCLEARROBOT4 An automatic spray booth used to apply 

clear coatings to plastic parts. Emissions 

from the booth are controlled by a common 

regenerative thermal oxidizer (RTO). 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUCLEARMANUAL A manual spray booth used to apply clear 

coatings to plastic parts. 

05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUOVEN A natural gas-fired cure oven. 05/04/1994, 

04/02/2002 

FGEASTPAINT 

EUWASTESOLVRC This unit is located at the Paint East facility 

and consists of a waste solvent distillation 

unit used for onsite recycling of purge and 

cleanup solvents. 

12/13/1993 FGRULE290 

EUWESTROBOT1 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT2 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT3 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 19 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUWESTROBOT4 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT5 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT6 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT7 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOT8 This group consists of one resist coating 

air-dried robotic booth to coat plastic parts. 

The auto booth emissions are captured 

and controlled by a regenerative thermal 

oxidizer. Particulate is controlled by a dry 

mat filter or equivalent technology. 

07/07/1994 FGWESTROBOPAINT

EUWESTROBOOVEN This group consists of one resist dry off 

oven. 

07/07/1994 FGWESTROBOPAINT

EUWESTMANUAL1 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL2 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL3 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 20 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUWESTMANUAL4 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL5 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL6 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL7 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL8 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL9 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL10 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANUAL11 This unit consists of one air-dried manual 

spray booth to coat plastic parts, one hand 

spray gun, with dry filters to remove 

overspray. 

07/07/1994 FGWESTMANUAL 

EUWESTMANOVEN This unit consists for one paint dry oven for 

the manual spray booths. 

07/07/1994 FGWESTMANUAL 

EUWESTPURGE This unit consists of paint line purging 

operations. 

07/07/1994 FGWESTSOLVENT 

EUWESTMASKWASH This unit consists of paint mask washers. 07/07/1994 FGWESTSOLVENT 

EUWESTSTRIPTANK This unit consists of one strip tank for 

masks. 

07/07/1994 FGWESTSOLVENT 

EUWESTCLEANUP This unit consists of miscellaneous cleanup 

operations. 

07/07/1994 FGWESTSOLVENT 

EUWESTPAINTKITCHEN This emission unit is the paint mixing room. 07/07/1994 FGWESTSOLVENT 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 21 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUWESTASSEMBLY Assembly station which uses a silicone and 

“Super Glue” type adhesive to assemble 

plastic component parts. The 52nd Street - 

West facility has (3) assembly work 

stations using adhesives. Exempt by Rule 

287(a) < 2 gallons/day. 

NA FGRULE287(c) 

EUASSEMBLYOPS Assembly stations that use adhesive and 

foam to assemble plastic component parts. 

The operation consists of eight (8) 

individual workstations located in the 

Assembly Facility on Barden Drive. 

NA FGRULE290 

EUMAINTCLEANER Small, cold solvent cleaner units used in 

the maintenance departments to clean 

machine parts being repaired. 

NA FGCOLDCLEANER 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 22 of 116 

EUPRIMEMANUAL 

EMISSION UNIT CONDITIONS

DESCRIPTION

A manual spray booth used to apply prime/adhesion prime coatings to plastic parts. 

Flexible Group ID: FGEASTPAINT 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 45.0 tpy 2 12-month rolling time 

period as determined 

at the end of each 

calendar month 

EUPRIMEMANUAL SC VI.3 & 

VI.4 

R 336.1702(a);

Consent Order 

No. 29-2006, 

Paragraph 10 

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA. NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. The VOC content, water content, and density of any coating, reducer, and/or solvent, as applied and as received, 

may be determined from manufacturer’s formulation data.2

 (R 336.1225, R 336.1702, R 336.1901; Consent 

Order No. 29-2006, Paragraph 10, R 336.1213(3))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 23 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. All required calculations shall be completed in a format acceptable to the AQD District Supervisor and made 

available by the 15th day of the calendar month, for the previous calendar month, unless otherwise specified in 

any recordkeeping, reporting or notification special condition.2

 (R 336.1224, R 336.1225, R 336.1702, 

R 336.1901; Consent Order No. 29-2006, Paragraph 11)

2. The permittee shall maintain a current listing from the manufacturer of the chemical composition of each coating, 

reducer, and solvent, including the weight percent of each component. The data may consist of Material Safety 

Data Sheets, manufacturer’s formulation data, or both as deemed acceptable by the AQD District Supervisor.2

(R 336.1224, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, Paragraph 11) 

3. The permittee shall keep the following information on a monthly basis for EUPRIMEMANUAL: 

a. Gallons (with water) of each coating, reducer, and solvent used. 

b. VOC content (minus water and with water) of each coating as applied. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

e. Hours of operation.

The records shall be kept in the format specified in Appendix 4.A and 4.B or an alternate format that has been 

approved by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

4. The permittee shall keep the following information on a monthly basis for the use of purge and clean-up solvents 

associated with EUPRIMEMANUAL: 

a. Gallons of each solvent used and reclaimed. 

b. VOC content, in pounds per gallon, of each solvent used. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

The records shall be kept in the format specified in Appendix 4.C or an alternate format that has been approved 

by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

See Appendix 1-4 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii); 

Consent Order No. 29-2006, Paragraph 11)

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i); Consent 

Order No. 29-2006, Paragraph 11)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 24 of 116 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c); Consent Order No. 29-2006, Paragraph 11)

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-EASTPRIME 522 80.02 R 336.1702(a); Consent Order 

No. 29-2006, Paragraph 10

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 25 of 116 

EUBASEMANUAL 

EMISSION UNIT CONDITIONS

DESCRIPTION

A manual spray booth used to apply base coatings to plastic parts. 

Flexible Group ID: FGEASTPAINT 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 60.0 tpy 2 12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

EUBASEMANUAL SC VI.3 & 

VI.4 

R 336.1702(a); 

Consent Order 

No. 29-2006, 

Paragraph 10 

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. The VOC content, water content, and density of any coating, reducer, and/or solvent, as applied and as received, 

may be determined from manufacturer’s formulation data.2

 (R 336.1225, R 336.1702, R 336.1901 

R 336.1213(3); Consent Order No. 29-2006, Paragraph 10)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 26 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. All required calculations shall be completed in a format acceptable to the AQD District Supervisor and made 

available by the 15th day of the calendar month, for the previous calendar month, unless otherwise specified in 

any recordkeeping, reporting or notification special condition.2

 (R 336.1224, R 336.1225, R 336.1702, 

R 336.1901; Consent Order No. 29-2006, Paragraph 11)

2. The permittee shall maintain a current listing from the manufacturer of the chemical composition of each coating, 

reducer, and solvent, including the weight percent of each component. The data may consist of Material Safety 

Data Sheets, manufacturer’s formulation data, or both as deemed acceptable by the AQD District Supervisor.2

 

(R 336.1224, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, Paragraph 11) 

3. The permittee shall keep the following information on a monthly basis for EUBASEMANUAL: 

a. Gallons (with water) of each coating, reducer, and solvent used. 

b. VOC content (minus water and with water) of each coating as applied. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

e. Hours of operation. 

The records shall be kept in the format specified in Appendix 1-4.A and 1-4.B or an alternate format that has been 

approved by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

4. The permittee shall keep the following information on a monthly basis for the use of purge and clean-up solvents 

associated with EUBASEMANUAL: 

a. Gallons of each solvent used and reclaimed. 

b. VOC content, in pounds per gallon, of each solvent used. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

The records shall be kept in the format specified in Appendix 1-4.C or an alternate format that has been approved 

by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

See Appendix 1-4 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii); 

Consent Order No. 29-2006, Paragraph 11)

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i); Consent 

Order No. 29-2006, Paragraph 11)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 27 of 116 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c); Consent Order No. 29-2006, Paragraph 11)

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-EASTBASE 522 80.02 R 336.1702(a); Consent Order 

No. 29-2006, Paragraph 10

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 28 of 116 

EUCLEARMANUAL 

EMISSION UNIT CONDITIONS

DESCRIPTION

A manual spray booth used to apply clear coatings to plastic parts. 

Flexible Group ID: FGEASTPAINT 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 30.0 tpy 2 12-month rolling time 

period as determined at 

the end of each 

calendar month 

EUCLEARMANUAL SC VI.3 & 

VI.4 

R 336.1702(a); 

Consent Order 

No. 29-2006, 

Paragraph 10 

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA. NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. The VOC content, water content, and density of any coating, reducer, and/or solvent, as applied and as received, 

may be determined from manufacturer’s formulation data.2

 (R 336.1225, R 336.1702, R 336.1901 

R 336.1213(3); Consent Order No. 29-2006, Paragraph 10)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 29 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. All required calculations shall be completed in a format acceptable to the AQD District Supervisor and made 

available by the 15th day of the calendar month, for the previous calendar month, unless otherwise specified in 

any recordkeeping, reporting or notification special condition.2

 (R 336.1224, R 336.1225, R 336.1702, 

R 336.1901; Consent Order No. 29-2006, Paragraph 11)

2. The permittee shall maintain a current listing from the manufacturer of the chemical composition of each 

coating, reducer, and solvent, including the weight percent of each component. The data may consist of 

Material Safety Data Sheets, manufacturer’s formulation data, or both as deemed acceptable by the AQD 

District Supervisor.2 (R 336.1224, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

3. The permittee shall keep the following information on a monthly basis for EUCLEARMANUAL: 

a. Gallons (with water) of each coating, reducer, and solvent used. 

b. VOC content (minus water and with water) of each coating as applied. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

e. Hours of operation. 

The records shall be kept in the format specified in Appendix 1-4.A and 1-4.B or an alternate format that has 

been approved by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 

29-2006, Paragraph 11) 

4. The permittee shall keep the following information on a monthly basis for the use of purge and clean-up 

solvents associated with EUCLEARMANUAL: 

a. Gallons of each solvent used and reclaimed. 

b. VOC content, in pounds per gallon, of each solvent used. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 

The records shall be kept in the format specified in Appendix 4.C or an alternate format that has been approved 

by the AQD District Supervisor.2

 (R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, 

Paragraph 11) 

See Appendix 1-4

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii); 

Consent Order No. 29-2006, Paragraph 11)

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i); Consent 

Order No. 29-2006, Paragraph 11)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 30 of 116 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c); Consent Order No. 29-2006, Paragraph 11)

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-EASTCLEAR 522 80.02 R 336.1702(a); Consent Order 

No. 29-2006, Paragraph 10

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 31 of 116 

D. FLEXIBLE GROUP CONDITIONS 

Part D outlines terms and conditions that apply to more than one emission unit. The permittee is subject to the 

special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and 

conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no special conditions that apply to more than one emission unit, this section will be left blank. 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions. 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FGEASTPAINT A plastic parts coating line consisting of thirteen 

spray booths located at 52nd Paint East. The 

coatings applied on the line are prime/adhesion 

prime, base, and clear coats. The prime coating 

portion of the line consists of two robotic booths 

(EUPRIMEROBOT1 & EUPRIMEROBOT2), one 

manual booth (EUPRIMEMANUAL), and a flashoff 

area. The basecoat portion of the line consists of 

four robotic booths (EUBASEROBOT1, 

EUBASEROBOT2, EUBASEROBOT3, & 

EUBASEROBOT4), one manual booth 

(EUBASEMANUAL), and a flashoff area. The 

clearcoat portion of the line consists of four robotic 

booths (EUCLEARROBOT1, EUCLEARROBOT2, 

EUCLEARROBOT3, & EUCLEARROBOT4), one 

manual booth (EUCLEARMANUAL), a flashoff area, 

and a natural gas-fired cure oven (EUOVEN). 

Emissions from all of the robotic booths are 

captured and controlled by a regenerative thermal 

oxidizer (RTO). Emissions from each of the manual 

booths and the oven are directly vented to the 

outside atmosphere. All booths use down-draft 

waterwash particulate control. 

EUPRIMEROBOT1 

EUPRIMEROBOT2 

EUPRIMEMANUAL 

EUBASEROBOT1 

EUBASEROBOT2 

EUBASEROBOT3 

EUBASEROBOT4 

EUBASEMANUAL 

EUCLEARROBOT1 

EUCLEARROBOT2 

EUCLEARROBOT3 

EUCLEARROBOT4 

EUCLEARMANUAL 

EUOVEN 

FGWESTROBOPAINT This flexible group consists of 8 robot spray booths 

and 1 dry oven located at the 52nd Paint West 

facility. The spray emissions are captured and 

controlled by a single RTO. The booths use dry 

filters to remove paint overspray. 

EUWESTROBOT1 

EUWESTROBOT2 

EUWESTROBOT3 

EUWESTROBOT4 

EUWESTROBOT5 

EUWESTROBOT6 

EUWESTROBOT7 

EUWESTROBOT8 

EUWESTRBTOVEN 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 32 of 116 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FGWESTMANUAL This group consists of 11 hand spray booths and 

one paint dry oven located at the 52nd Paint West 

facility. 

EUWESTMANUAL1 

EUWESTMANUAL2 

EUWESTMANUAL3 

EUWESTMANUAL4 

EUWESTMANUAL5 

EUWESTMANUAL6 

EUWESTMANUAL7 

EUWESTMANUAL8 

EUWESTMANUAL9 

EUWESTMANUAL10 

EUWESTMANUAL11 

EUWESTMANOVEN 

FGWESTMISCSOLVENT This group consist of miscellaneous usage at 52nd

Street Paint West for purge and cleanup operations. 

EUWESTPURGE 

EUWESTMASKWASH 

EUWESTSTRIPTANK 

EUWESTCLEANUP 

FGSUBPARTPPPP Each new, reconstructed, and existing affected 

source engaged in the surface coating of plastic 

parts and products, identified within each of the four 

subcategories listed in 40 CFR Part 63, Subpart 

PPPP (40 CFR), 63.4481(a)(2) to (5). This includes 

equipment covered by other permits, grandfathered 

equipment, and exempt equipment. Surface coating 

is defined by 40 CFR 63.4481 as the application of 

coating to a substrate using, for example, spray 

guns or dip tanks. Surface coating also includes 

associated activities, such as surface preparation, 

cleaning, mixing, and storage if they are directly 

related to the application of the coating. 

NA 

FGRULE290 Any emission unit that emits air contaminants and is 

exempt from the requirements of Rule 201 pursuant 

to Rules 278 and 290. 

EUWASTESOLVRC, 

EUASSEMBLYOPS 

FGRULE287(c) Any emission unit that emits air contaminants and is 

exempt from the requirements of Rule 201 pursuant 

to Rules 278 and 287(c). 

EUWESTASSEMBLY 

FGCOLDCLEANER Any cold cleaner that is grandfathered or exempt 

from Rule 201 pursuant to Rule 281(h) or Rule 

285(r)(iv). Existing cold cleaners were placed into 

operation prior to July 1, 1979. New cold cleaners 

were placed into operation on or after July 1, 1979. 

EUMAINTCLEANER 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 33 of 116 

FGEASTPAINT 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

A plastic parts coating line consisting of thirteen spray booths. The coatings applied on the line are prime/adhesion 

prime, base, and clear coats. The prime coating portion of the line consists of two robotic booths 

(EUPRIMEROBOT1 & EUPRIMEROBOT2), one manual booth (EUPRIMEMANUAL), and a flashoff area. The 

basecoat portion of the line consists of four robotic booths (EUBASEROBOT1, EUBASEROBOT2, 

EUBASEROBOT3, & EUBASEROBOT4), one manual booth (EUBASEMANUAL), and a flashoff area. The 

clearcoat portion of the line consists of four robotic booths (EUCLEARROBOT1, EUCLEARROBOT2, 

EUCLEARROBOT3, & EUCLEARROBOT4), one manual booth (EUCLEARMANUAL), a flashoff area, and a 

natural gas-fired cure oven (EUOVEN). Emissions from all of the robotic booths are captured and controlled by a 

regenerative thermal oxidizer (RTO). Emissions from each of the manual booths and the oven are directly vented 

to the outside atmosphere. All booths use down-draft water wash particulate control. Compliance Assurance 

Monitoring applies to this flexible group.

Emission Units: EUPRIMEROBOT1, EUPRIMEROBOT2, EUPRIMEMANUAL, EUBASEROBOT1, 

EUBASEROBOT2, EUBASEROBOT3, EUBASEROBOT4, EUBASEMANUAL, 

EUCLEARROBOT1, EUCLEARROBOT2, EUCLEARROBOT3, EUCLEARROBOT4, 

EUCLEARMANUAL, EUOVEN 

POLLUTION CONTROL EQUIPMENT

Regenerative Thermal Oxidizer, Water Wash Particulate Control 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 45.0 pounds per 

hour 1

Test Protocol FGEASTPAINT SC V.1 & 

GC 13 

R 336.1225; 

Consent Order 

No. 29-2006, 

Paragraph 10.B

2. VOC 11.1 tons per 

month 2

As determined at the 

end of each calendar 

month. 

FGEASTPAINT SC VI.8 & 

VI.10 

R 336.1220 , 

R 336.1702(a); 

Consent Order 

No. 29-2006, 

Paragraph 10.B

3. VOC 111.61 tons per 

year 2

365-day rolling time 

period as determined 

at the end of each 

calendar day. 

FGEASTPAINT SC VI.7 & 

VI.9 

R 336.1205,

R 336.1220, 

R 336.1702(a); 

Consent Order 

No. 29-2006, 

Paragraph 10.B
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 34 of 116 

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA. NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. All waste coatings, reducers, and solvents shall be captured and stored in closed containers and shall be 

disposed of in an acceptable manner in compliance with all applicable rules and regulations. 2 (R 336.1224, 

R 336.1702(a); Consent Order No. 29-2006, Paragraph 10)

2. An excursion occurs under the following circumstances: (40 CFR 64.6(c)(2))

a. The RTO combustion chamber temperature is operated below 1400 °F. 

b. The structural integrity of the RTO has been jeopardized and the RTO is no longer operating as designed. 

c. The integrity of the thermocouple has been compromised. 

d. The integrity of the capture and exhaust system has been compromised. 

e. The RTO does not meet the permitted destruction efficiency of 95% by weight. 

f. The annual inspection of the RTO is not performed. 

g. The direction of air flow at any natural draft opening (NDO) of a robotic booth is flowing out of the robotic 

booth rather than into the booth. 

3. Upon detecting an excursion or exceedance, the permittee shall restore operation of FGEASTPAINT including 

the control device and capture system to normal or usual manner of operation as quickly as possible in 

response to an exceedance or excursion. (40 CFR 64.7(d))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate any spray booth portion of FGEASTPAINT unless its respective waterwash 

particulate control is installed and operating in a satisfactory manner.2

 (R 336.1224, R 336.1901, R 336.1910; 

Consent Order No. 29-2006, Paragraph 10)

2. The permittee shall not operate any robotic spray booth portion of FGEASTPAINT unless the thermal oxidizer is 

installed, maintained and operated in a satisfactory manner. Satisfactory operation of the thermal oxidizer 

includes a minimum VOC capture efficiency of 100 percent (by weight), a minimum VOC destruction efficiency 

of 95 percent (by weight), and maintaining a minimum temperature of 1400 °F and a minimum retention time of 

0.5 seconds.2

 (R 336.1220, R 336.1224, R 336.1225, R 336.1702, R 336.1901, R 336.1910; Consent Order 

No. 29-2006, Paragraph 10) 

3. The permittee shall equip and maintain all basecoat and clearcoat spray booth portions of FGEASTPAINT with 

electrostatic applicators or equivalent technology with comparable transfer efficiency.2

 (R 336.1220, 

R 336.1702; Consent Order No. 29-2006, Paragraph 10)

4. The permittee shall equip and maintain all electrostatic applicator portions of FGEASTPAINT with a device to 

prevent electric current from being shut off except by authorized personnel.2

 (R 336.1220, R 336.1702; 

Consent Order No. 29-2006, Paragraph 10)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 35 of 116 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. Within five years from issuance of this ROP, the permittee shall verify the destruction efficiency of the 

regenerative thermal oxidizer, by testing at owner's expense, in accordance with Department requirements. Not 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD. The AQD must 

approve the final plan prior to testing. Verification of emission limits includes the submittal of a complete report of 

the test results to the AQD within 60 days following the last date of the test. (R 336.1213(3), 40 CFR 64.6(d))

2. Within 180 days after October 31, 2005 and semiannually thereafter, the permittee shall verify that the direction 

of air flow at each natural draft opening (NDO) on each robotic booth portion of FGEASTPAINT is into the 

booth. The verification of the direction of air flow at the NDOs shall be conducted using the smoke tube test 

method, or an alternate method. The permittee shall submit a notice of the anticipated test date to the District 

Office no later than two weeks prior to the test date, and a test report shall be submitted to the District 

Supervisor within 30 days after the completion of the testing. All test methods, plans, and procedures shall be 

approved by the AQD prior to testing. After two consecutive tests demonstrate that the direction of air flow at 

all NDOs is into the booths, the permittee may request that the monitoring schedule be revised to a less 

frequent time period as approved by the District Supervisor.2

 (R 336.1220, R 336.1224, R 336.1225, 

R 336.1702, R 336.1901, R 336.1910, 40 CFR 64.6(d); Consent Order No. 29-2006, Paragraph 10)

3. The VOC content, water content, and density of any coating, reducer, and/or solvent as applied and as received 

may be determined from manufacturer’s formulation data.2

 (R 336.1225, R 336.1702, R 336.1901 

R 336.1213(3); Consent Order No. 29-2006, Paragraph 10)

4. Within one year of ROP issuance and annually thereafter, the permittee shall verify the VOC content of the five 

most frequently used coatings, plus 2% of the remaining coatings, as received and as applied using federal 

reference Method 24. The five most frequently used coatings shall be determined based on the previous 12 

months from the date of sampling. If at any time, the Method 24 and the manufacturer’s formulation values 

should differ, the highest of the two values shall be used to calculate emissions. (R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall monitor, in a satisfactory manner, the temperature in the thermal oxidizer combustion zone 

on a continuous basis using a thermocouple and paper chart recorder or in a manner and with instrumentation 

acceptable to the AQD.2

 (R 336.1220, R 336.1224, R 336.1225, R 336.1702, R 336.1901, 40 CFR 64.6(c)(1); 

Consent Order No. 29-2006, Paragraph 10) 

2. The permittee shall keep, in a satisfactory manner, continuous records of the temperature in the thermal 

oxidizer combustion zone.2

 (R 336.1220, R 336.1224, R 336.1225, R 336.1702, R 336.1901, 40 CFR 64.6(b); 

Consent Order No. 29-2006, Paragraph 11)

3. The permittee shall conduct continuous temperature monitoring while the equipment is operating. Data 

collected during monitoring malfunctions, associated repairs, and QA/QC activities shall not be used to satisfy 

monitoring requirements. (40 CFR 64.6(c)(3), 40 CFR 64.7(c)) 

4. The temperature system of the RTO shall be validated and calibrated on an annual basis by a third party 

auditor. (40 CFR 64.6(c)(3), 40 CFR 64.7(c))

5. The permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, 

and other supporting information required to be maintained under 40 CFR Part 64 (such as data used to 

document the adequacy of monitoring, or records of monitoring maintenance or corrective actions).

(40 CFR 64.9(b))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 36 of 116 

6. The permittee shall maintain a current listing from the manufacturer of the chemical composition of each coating, 

reducer, and solvent, including the weight percent of each component. The data may consist of Material Safety 

Data Sheets, manufacturer’s formulation data, or both as deemed acceptable by the AQD District Supervisor.2 

(R 336.1220, R 336.1224, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-2006, Paragraph 11)

7. The permittee shall keep the following information on a daily basis for FGEASTPAINT: 

a. Gallons (with water) of each coating, reducer, and solvent used. 

b. VOC content (minus water and with water) of each coating as applied. 

c. VOC mass emission calculations determining the annual emission rate in tons per 365-day rolling time period 

as determined at the end of each calendar day. 

The records shall be kept in the format specified in Appendix 1-4.A and 1-4.B or an alternate format that has been 

approved by the AQD District Supervisor.2

 (R 336.1220, R 336.1225, R 336.1702, R 336.1901; Consent Order 

No. 29-2006, Paragraph 11)

8. The permittee shall keep the following information on a monthly basis for FGEASTPAINT: 

a. Gallons (with water) of each coating, reducer, and solvent used. 

b. VOC content (minus water and with water) of each coating as applied. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

d. Hours of operation. 

The records shall be kept in the format specified in Appendix 1-4.A and 1-4.B or an alternate format that has been 

approved by the AQD District Supervisor.2

 (R 336.1220, R 336.1225, R 336.1702, R 336.1901; Consent Order 

No. 29-2006, Paragraph 11) 

9. The permittee shall keep the following information on a daily basis for the use of purge and clean-up solvents 

associated with FGEASTPAINT: 

a. Gallons of each solvent used and reclaimed. 

b. VOC content, in pounds per gallon, of each solvent used. 

c. VOC mass emission calculations determining the annual emission rate in tons per 365-day rolling time 

period as determined at the end of each calendar day. 

The records shall be kept in the format specified in Appendix 1-4.C or an alternate format that has been approved 

by the AQD District Supervisor.2

 (R 336.1220, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-

2006, Paragraph 11)

10. The permittee shall keep the following information on a monthly basis for the use of purge and clean-up solvents 

associated with FGEASTPAINT: 

a. Gallons of each solvent used and reclaimed. 

b. VOC content, in pounds per gallon, of each solvent used. 

c. VOC mass emission calculations determining the monthly emission rate in tons per calendar month. 

The records shall be kept in the format specified in Appendix 1-4.C or an alternate format that has been approved 

by the AQD District Supervisor.2

 (R 336.1220, R 336.1225, R 336.1702, R 336.1901; Consent Order No. 29-

2006, Paragraph 11) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 37 of 116 

11. All required calculations shall be completed in a format acceptable to the AQD District Supervisor and made 

available by the 15th day of the calendar month, for the previous calendar month, unless otherwise specified in 

any recordkeeping, reporting or notification special condition.2

 (R 336.1224, R 336.1225, R 336.1702, 

R 336.1901; Consent Order No. 29-2006, Paragraph 11)

12. On an annual basis, the permittee shall inspect and document the internal and external structural integrity of the 

regenerative thermal oxidizer to ensure proper operation as documented in the O&M Plan. (40 CFR 64.6(c))

13. The permittee shall comply with all elements of the approved Compliance Assurance Monitoring Plan. 

(40 CFR 64.9)

See Appendices 1-3 and 1-4 

VII. REPORTING

1. Prompt reporting of deviations, including exceedances and excursions pursuant to General Conditions 21 and 

22 of Part A. (R 336.1213(3)(c)(ii), 40 CFR 64.9; Consent Order No. 29-2006, Paragraph 11)

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i); Consent 

Order No. 29-2006, Paragraph 11)

3. Each semiannual report of monitoring and deviations shall include the following: 

a. Summary information on the number, duration, and cause of exceedances/excursions in the reporting 

period; and the corrective actions taken in response. If there were no excursions/exceedances in the 

reporting period, then this report shall include a statement that there were no excursions/exceedances. 

(40 CFR 64.9(a)(2)(i), R 336 1213(3)(c))

b. Summary information on monitor downtime. If there were no periods of monitor downtime in the reporting 

period, then this report shall include a statement that there were no periods of downtime. 

(40 CFR 64.9(a)(2)(ii), R 336 1213(3)(c))

c. A description of the actions taken to implement a Quality Improvement Plan (QIP) during the reporting 

period, if appropriate. If a QIP has been completed, the report shall include documentation that the QIP 

has been implemented, and a discussion pertaining to whether the QIP implementation has reduced the 

likelihood of excursions or exceedances. (40 CFR 64.9)

4. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. This certification shall 

include whether compliance was intermittent or continuous. The report shall be postmarked or received by the 

appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c), 40 CFR 64.9; 

Consent Order No. 29-2006, Paragraph 11)

See Appendix 1-8 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 38 of 116 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-EASTPRIME 522 80.02 R 336.1225, R 336.1901, 

40 CFR 52.21(c) & (d); Consent 

Order No. 29-2006, Paragraph 10

2. SV-EASTBASE 522 80.02 R 336.1225, R 336.1901, 

40 CFR 52.21(c) & (d); Consent 

Order No. 29-2006, Paragraph 10

3. SV-EASTCLEAR 522 80.02 R 336.1225, R 336.1901, 

40 CFR 52.21(c) & (d); Consent 

Order No. 29-2006, Paragraph 10

4. SV-REGENINCIN5 482 45.02 R 336.1225, R 336.1901, 

40 CFR 52.21(c) & (d); Consent 

Order No. 29-2006, Paragraph 10

5. SV-EASTBASECLROVEN 362 45.02 R 336.1225, R 336.1901, 

40 CFR 52.21(c) & (d); Consent 

Order No. 29-2006, Paragraph 10

IX. OTHER REQUIREMENT(S)

1. The permittee shall notify the appropriate District Office of the AQD for the need to modify the monitoring plan if 

the approved monitoring is found to be inadequate and shall submit a proposed modification to the plan if 

appropriate. (40 CFR 64.7(e))

2. The permittee shall, at all times, maintain the monitoring system, including but not limited to, maintaining 

necessary parts for routine repairs of the monitoring equipment. (40CFR 64.7(b))

3. Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or 

control activities, the permittee shall conduct all monitoring in continuous operation at all times that the 

pollutant-specific emissions unit operating. (40 CFR 64.7(c))

4. The permittee shall comply with all applicable requirements of 40 CFR Part 64. (40 CFR Part 64)

5. The permittee shall maintain and operate FGEASTPAINT according to the procedures outlined in the approved 

Operation and Maintenance Plan, or an alternate plan approved by the AQD District Supervisor. See Appendix 

1-9. 2

 (R 336.1910; Consent Order No. 29-2006, Paragraph 10) 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 39 of 116 

FGWESTROBOPAINT 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of eight (8) resist coat spray booths used to coat plastic parts and one (1) oven located at the 

52nd Paint West facility. Compliance Assurance Monitoring applies to this flexible group.

Emission Units: EUWESTROBOT1, EUWESTROBOT2, EUWESTROBOT3, EUWESTROBOT4, 

EUWESTROBOT5, EUWESTROBOT6, EUWESTROBOT7, EUWESTROBOT8, 

EUWESTRBTOVEN 

POLLUTION CONTROL EQUIPMENT

Regenerative Thermal Oxidizer, Dry Mat Filters 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 610 pounds 

per day 2

Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

FGWESTROBOPAINT SC VI.4 R 336.1220(1)(a)

2. VOC 6.3 tons per 

month 2

As determined at 

the end of each 

calendar month. 

FGWESTROBOPAINT SC VI.3 R 336.1220(1)(a)

3. VOC 50.8 tons per 

year 2

Based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

FGWESTROBOPAINT SC VI.3 R 336.1220(1)(a)

4. VOC 

(uncontrolled) 

6.7 pounds per 

gallon of 

coating, minus 

water, as 

applied. 2

Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

FGWESTROBOPAINT SC VI.2 R 336.1220(1)(a)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 40 of 116 

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

5. VOC 

(uncontrolled) 

6.5 pounds per 

gallon of 

coating, minus 

water, as 

applied. 2

Based upon a 

calendar month 

averaging time 

period as 

determined at the 

end of each 

calendar month 

FGWESTROBOPAINT SC VI.2 R 336.1220(1)(a)

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. Permittee shall equip and maintain all paint spray booths with High Volume Low Pressure spray guns or 

equivalent technology with comparable transfer efficiency. 2

 (R 336.1220(1)(a))

2. Permittee shall not operate any of the eight automatic resist coat spray booths unless the dry filters are 

installed and operating properly. 2

 (R 336.1910)

3. Permittee shall not operate any of the eight automatic resist coat spray booths unless the thermal incinerator is 

installed and operating properly. Proper operation of the thermal incinerator includes a minimum VOC 

destruction efficiency of 95% (by weight) and maintaining a minimum operating temperature of 1400°

F and a 

minimum retention time of 0.5 seconds. 2

 (R 336.1910)

4. An excursion occurs under the following circumstances: (40 CFR 64.6(c)(2))

a. The RTO combustion chamber temperature is operated below 1400 °F. 

b. The structural integrity of the RTO has been jeopardized and the RTO is no longer operating as designed. 

c. The integrity of the thermocouple has been compromised. 

d. The integrity of the capture and exhaust system has been compromised. 

e. The RTO does not meet the permitted destruction efficiency of 95% by weight. 

f. The annual inspection of the RTO is not performed. 

g. The direction of air flow at any natural draft opening (NDO) of a robotic booth is flowing out of the robotic 

booth rather than into the booth. 

5. The permittee shall restore operation of FGWESTROBOPAINT including the control device and capture system 

to normal or usual manner of operation as quickly as possible in response to an exceedance or excursion. 

(40 CFR 64.7(d))

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 41 of 116 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Within five years from issuance of this ROP, the permittee shall verify the destruction efficiency of the 

regenerative thermal oxidizer, by testing at owner's expense, in accordance with Department requirements. Not 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD. The AQD must 

approve the final plan prior to testing. Verification of emission limits includes the submittal of a complete report of 

the test results to the AQD within 60 days following the last date of the test. (R 336.1213(3), 40 CFR 64.6(d))

2. Within 60 days of issuance of this ROP and semiannually thereafter, the permittee shall verify that the direction 

of air flow at each natural draft opening (NDO) on each robotic booth in FGWESTROBOPAINT is into the 

booth. The verification of the direction of air flow at the NDOs shall be conducted using the smoke tube test 

method, or an alternate method. The permittee shall submit a notice of the anticipated test date to the District 

Office no later than two weeks prior to the test date, and a test report shall be submitted to the District 

Supervisor within 30 days after the completion of the testing. All test methods, plans, and procedures shall be 

approved by the AQD prior to testing. After two consecutive tests demonstrate that the direction of air flow at 

all NDOs is into the booths, the permittee may request that the monitoring schedule be revised to a less 

frequent time period as approved by the District Supervisor. (R 336.1213(3), 40 CFR 64.6(d))

3. The VOC content, water content, and density of any coating, reducer, and/or solvent as applied and as received 

may be determined from manufacturer’s formulation data. (R 336.1213(3))

4. Within one year of ROP issuance and annually thereafter, the permittee shall verify the VOC content of the 

three most frequently used coatings as received and as applied using federal reference Method 24. The three 

most frequently used coatings shall be determined based on the previous 12 months from the date of sampling. 

If at any time, the Method 24 and the manufacturer’s formulation values should differ, the highest of the two 

values shall be used to calculate emissions. (R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain the following records: 2 (R 336.1220(1)(a))

a. Monthly records for each coating sprayed: 2 (R 336.1220(1)(a))

i. The amount in gallons of coating applied. 

ii. The VOC content in pounds per gallon of coating (minus water) as received and as applied. 

iii. The VOC content in pounds per gallon of reducers and catalysts and the amounts in gallons applied. 

b. Average VOC emission calculations determining the uncontrolled pounds per gallon of coating, minus 

water, as applied for each 24-hour production day and for each calendar month.2 (R 336.1220(1)(a))

c. VOC emission calculations determining the VOC mass emissions for each calendar month in tons per 

month and a 12-month rolling time period average mass emission at the end of each calendar month in 

tons per year.2 (R 336.1220(1)(a))

d. VOC emission calculations determining the VOC emission rate in pounds per day based upon a 24-hour 

averaging period and determined at the end of each 24-hour production day. (R 336.1213(3)) 

2. The permittee shall monitor, in a satisfactory manner, the temperature in the thermal oxidizer combustion zone 

on a continuous basis using a thermocouple and paper chart recorder or in a manner and with instrumentation 

acceptable to the AQD.2 (R 336.1220(1)(a), 40 CFR 64.6(c)(1)) 

3. The permittee shall keep, in a satisfactory manner, continuous records of the temperature in the thermal 

oxidizer combustion zone.2 (R 336.1220(1)(a), 40 CFR 64.6(b))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 42 of 116 

4. The permittee shall conduct continuous temperature monitoring while the equipment is operating. Data 

collected during monitoring malfunctions, associated repairs, and QA/QC activities shall not be used to satisfy 

monitoring requirements. (40 CFR 64.6(c)(3), 40 CFR 64.7(c)) 

5. The temperature system of the RTO shall be validated and calibrated on an annual basis by a third party 

auditor. (40 CFR 64.6(c)(3), 40 CFR 64.7(c))

6. The permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, 

and other supporting information required to be maintained under 40 CFR Part 64 (such as data used to 

document the adequacy of monitoring, or records of monitoring maintenance or corrective actions).

(40 CFR 64.9(b)) 

7. On an annual basis, the permittee shall inspect and document the internal and external structural integrity of the 

regenerative thermal oxidizer to ensure proper operation as documented in the O&M Plan. (40 CFR 64.6(c))

8. The permittee shall comply with all elements of the approved Compliance Assurance Monitoring Plan. 

(40 CFR 64.9)

See Appendix 1-3 

VII. REPORTING

1. Prompt reporting of deviations, including exceedances and excursions pursuant to General Conditions 21 and 

22 of Part A. (R 336.1213(3)(c)(ii), 40 CFR 64.9)

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Each semiannual report of monitoring deviations shall include the following: 

a. Summary information on the number, duration, and cause of exceedances/excursions in the reporting 

period; and the corrective actions taken in response. If there were no excursions/exceedances in the 

reporting period, then this report shall include a statement that there were no excursions/exceedances. 

(40 CFR 64.9(a)(2)(i), R 336 1213(3)(c))

b. Summary information on monitor downtime. If there were no periods of monitor downtime in the reporting 

period, then this report shall include a statement that there were no periods of downtime. 

(40 CFR 64.9(a)(2)(ii), R 336 1213(3)(c))

c. A description of the actions taken to implement a Quality Improvement Plan (QIP) during the reporting 

period, if appropriate. If a QIP has been completed, the report shall include documentation that the QIP 

has been implemented, and a discussion pertaining to whether the QIP implementation has reduced the 

likelihood of excursions or exceedances. (40 CFR 64.9)

4. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. This certification shall 

include whether compliance was intermittent or continuous. The report shall be postmarked or received by the 

appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c), 40 CFR 64.9)

See Appendix 1-8 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 43 of 116 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-REGENINCIN 422 512 R 336.1201(3) 

2. SV-OVENWRESIST 142 512 R 336.1201(3)

IX. OTHER REQUIREMENT(S)

1. The permittee shall notify the appropriate District Office of the AQD for the need to modify the monitoring plan if 

the approved monitoring is found to be inadequate and shall submit a proposed modification to the plan if 

appropriate. (40 CFR 64.7(e)) 

2. The permittee shall, at all times, maintain the monitoring system, including but not limited to, maintaining 

necessary parts for routine repairs of the monitoring equipment. (40CFR 64.7(b)) 

3. Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or 

control activities, the permittee shall conduct all monitoring in continuous operation at all times that the 

pollutant-specific emissions unit operating. (40 CFR 64.7(c))

4. The permittee shall comply with all requirements of 40 CFR Part 64. (40 CFR Part 64) 

5. The permittee shall maintain and operate FGWESTROBOPAINT according to the procedures outlined in the 

approved Operation and Maintenance Plan, or an alternate plan approved by the AQD District Supervisor. See 

Appendix 1-9. (R 336.1213(3)) 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 44 of 116 

FGWESTMANUAL 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

The group consists of (11) manual spray coat booths used to coat plastic parts and one (1) oven located at Lacks 

52nd Paint West Paint facility.

Emission Unit: EUWESTMANUAL1, EUWESTMANUAL2, EUWESTMANUAL3, EUWESTMANUAL4, 

EUWESTMANUAL5, EUWESTMANUAL6, EUWESTMANUAL7, EUWESTMANUAL8, 

EUWESTMANUAL9, EUWESTMANUAL10, EUWESTMANUAL11, EUWESTMANOVEN

POLLUTION CONTROL EQUIPMENT

Dry Mat Filters 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC 1587 pounds per 

day2 Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-hour 

production day. 

FGWESTMANUAL SC VI.4 R 336.1220(1)(a)

2. VOC 16.5 tons per 

month2

As determined at 

the end of each 

calendar month. 

FGWESTMANUAL SC VI.3 R 336.1220(1)(a)

3. VOC 132.2 tons per 

year2

Based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

FGWESTMANUAL SC VI.3 R 336.1220(1)(a)

4. VOC 6.7 pounds per 

gallon of coating, 

minus water, as 

applied. 2

Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-hour 

production day. 

FGWESTMANUAL SC VI.2 R 336.1220(1)(a)

5. VOC 

Red and black 

air-dried 

coatings 

5.75 pounds per 

gallon of coating, 

minus water, as 

applied2

Based upon a 

calendar day 

averaging time 

period as 

determined at the 

end of each 

calendar day. 

FGWESTMANUAL SC VI.2 R 336.1220(1)(a)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 45 of 116 

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

6. VOC 

Non-red and 

black air-dried 

coatings 

5.0 pounds per 

gallon of coating, 

minus water, as 

applied2

Based upon a 

calendar day 

averaging time 

period as 

determined at the 

end of each 

calendar day. 

FGWESTMANUAL SC VI.2 R 336.1220(1)(a)

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. Exotic colored coatings a maximum of 

10%, by 

volume, of all 

coatings 

applied. 2

NA NA SC VI.2 R 336.1220(1)(a)

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall equip and maintain all paint spray booths with High Volume Low Pressure spray guns or 

equivalent technology with comparable transfer efficiency. 2

 (R 336.1220(1)(a))

2. Permittee may use conventional air atomized spray guns in the spraycoat booths for the application of exotic 

colors only. 2 (R 336.1220(1)(a))

3. Permittee shall not operate any of the eleven manual spray booths unless the dry filters are installed and 

operating properly. 2 (R 336.1910)

4. Permittee shall dispose of spent filters in a manner that minimizes the introduction of air contaminants to the 

outer air. 2

 (R 336.1910)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 46 of 116 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The VOC content, water content, and density of any coating, reducer, and/or solvent as applied and as received 

may be determined from manufacturer’s formulation data. (R 336.1213(3))

2. Within one year of ROP issuance and annually thereafter, the permittee shall verify the VOC content of the five 

most frequently used coatings, plus 2% of the remaining coatings, as received and as applied using federal 

reference Method 24. The five most frequently used coatings shall be determined based on the previous 12 

months from the date of sampling. If at any time, the Method 24 and the manufacturer’s formulation values 

should differ, the highest of the two values shall be used to calculate emissions. (R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records of the following: 

a. Monthly records for each coating sprayed:2

 (R 336.1220(1)(a))

i. The coating identification/coating category (e.g. air-dried red/black coating, air-dried non red/black 

coating or exotic colors) for each coating used. 

ii. The amount in gallons of coating applied. 

iii. The VOC content in pounds per gallon of coating, minus water, as received and as applied based upon 

a 24- hour averaging period and determined at the end of each 24-hour production day. 

iv. The VOC content in pounds per gallon of reducers and catalysts and the amounts in gallons applied 

based upon a 24- hour averaging period and determined at the end of each 24-hour production day. 

b. Average VOC emission calculations determining the uncontrolled pounds per gallon of coating, minus 

water, as applied for air-dried red/black coatings and air-dried non red/black coatings each calendar day.2

(R 336.1220(1)(a))

c. VOC emission calculations determining the VOC mass emissions for each calendar month in tons per 

month and a 12-month rolling time period average mass emission at the end of each calendar month in 

tons per year.2

 (R 336.1220(1)(a))

d. VOC emission calculations determining the VOC emission rate in pounds per day based upon a 24- hour 

averaging period and determined at the end of each 24-hour production day. (R 336.1213(3)) 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 47 of 116 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-MANBOOTHM1 242 512 R 336.1201(3) 

2. SV-MANBOOTHM2 242 512 R 336.1201(3) 

3. SV-MANBOOTHM3 242 512 R 336.1201(3) 

4. SV-MANBOOTHM4 242 512 R 336.1201(3) 

5. SV-MANBOOTHM5 242 512 R 336.1201(3) 

6. SV-MANBOOTHM6 242 512 R 336.1201(3) 

7. SV-MANBOOTHM7 242 512 R 336.1201(3) 

8. SV-MANBOOTHM8 242 512 R 336.1201(3) 

9. SV-MANBOOTHM9 242 512 R 336.1201(3) 

10. SV-MANBOOTHM10 242 512 R 336.1201(3) 

11. SV-MANBOOTHM11 242 512 R 336.1201(3) 

12. SV-WTOPCOATOVE 162 512 R 336.1201(3) 

IX. OTHER REQUIREMENT(S)

1. The permittee shall maintain and operate FGWESTMANUAL according to the procedures outlined in the 

approved Operation and Maintenance Plan, or an alternate plan approved by the AQD District Supervisor. See 

Appendix 1-9. (R 336.1213(3)) 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 48 of 116 

FGWESTMISCSOLVENT 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

The group consists of miscellaneous solvent usage at the 52nd Paint West Facility. 

Emission Unit: EUWESTPURGE, EUWESTMASKWASH, EUWESTSTRIPTANK, EUWESTCLEANUP and 

EUWESTPAINTKITCHEN 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

1. VOC from 

purging 

operation 

7.0 lbs/hr2 Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

EUWESTPURGE SC VI.1 R 336.1220(1)(a)

2. VOC – 

purging 

operation 

10.6 tons/year2 based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

EUWESTPURGE SC VI.1 R 336.1220(1)(a)

3. VOC from 

mask wash 

operation 

7.0 lbs/hr2 Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

EUWESTMASKWASH SC VI.1 R 336.1220(1)(a)

4. VOC – 

mask wash 

operation 

10.6 tons/year2 based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

EUWESTMASKWASH SC VI.1 R 336.1220(1)(a)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 49 of 116 

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

5. VOC – 

strip tank 

operations 

1.4 lbs/hr2 Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

EUWESTSTRIPTANK SC VI.1 R 336.1220(1)(a)

6. VOC – 

strip tank 

operations 

2.0 tons/year2 Based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

EUWESTSTRIPTANK SC VI.1 R 336.1220(1)(a)

7. VOC – 

miscellane

ous 

cleanup 

18.3 lbs/hr2 Based upon a 24-

hour averaging 

period as 

determined at the 

end of each 24-

hour production 

day. 

EUWESTCLEANUP SC VI.1 R 336.1220(1)(a)

8. VOC – 

miscellane

ous 

cleanup 

8.8 tons/year2 Based upon a 12-

month rolling time 

period as 

determined at the 

end of each 

calendar month. 

EUWESTCLEANUP SC VI.1 R 336.1220(1)(a)

II. MATERIAL LIMIT(S)

Material Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements 

NA NA NA NA NA NA

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall recover and reclaim, recycle or dispose of, in accordance with applicable regulations, a 

minimum of 90% by weight of all purge and cleanup solvents. 2

 (R 336.1220(1)(a))

2. The permittee shall equip and maintain both the strip tank and the solvent mask washer with covers. The 

covers shall be closed whenever the individual units are not in use. 2

 (R 336.1220(1)(a))

3. All waste paints, purge solvents, mask washing solvents, stripping solvents and cleanup solvents shall be 

captured and stored in closed containers and be disposed of in an acceptable manner which minimizes the 

introduction of air contaminants to the outer air. 2

 (R 336.1910)
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 50 of 116 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The VOC content, water content, and density of any coating, reducer, and/or solvent as applied and as received 

shall be determined using federal Reference Test Method 24. Upon prior approval by the AQD District 

Supervisor, the VOC content may be determined from manufacturer’s formulation data. If the Method 24 and the 

formulation values should differ, then the Method 24 results shall be used to determine compliance.

(R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. For each operation associated with FGWESTMISCSOLVENT, the permittee shall keep the following information 

on a monthly basis for the use of purge and clean-up solvents: 

a. Gallons of each solvent used and reclaimed. 2 (R 336.1220(1)(a))

b. A listing of the type, use and VOC content, in pounds per gallon, of each solvent used.2 (R 336.1220(1)(a))

c. VOC mass emission calculations determining the annual emission rate in tons per 12-month rolling time 

period as determined at the end of each calendar month. 2 (R 336.1220(1)(a))

d. VOC mass emission calculations determining the hourly emission rate in pounds per 24-hour averaging 

period as determined at the end of each 24-hour production day. (R 336.1213(3))

See Appendix 1-7 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 51 of 116 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV-WESTSTRIPTANKRM 132 342 R 336.1201(3) 

2. SV-WESTPAINTKITCHEN 372 342 R 336.1201(3) 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 52 of 116 

FGSUBPART PPPP 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Each new, reconstructed, and existing affected source engaged in the surface coating of plastic parts and products, 

identified within each of the four subcategories listed in 40 CFR, Part 63, Subpart PPPP, 63.4481(a)(2) to (5). 

Surface coating is defined by 40 CFR 63.4481 as the application of coating to a substrate using, for example, spray 

guns or dip tanks. Surface coating also includes associated activities, such as surface preparation, cleaning, 

mixing, and storage if they are directly related to the application of the coating. 

Flexible Group: FGEASTPAINT, FGWESTROBOPAINT, FGWESTMANUAL, FGWESTMISCSOLVENT, 

FGRULE290, FGRULE287(c) 

POLLUTION CONTROL EQUIPMENT

Regenerative Thermal Oxidizer 

I. EMISSION LIMIT(S) 

Pollutant Limit 

Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method 

Underlying 

Applicable 

Requirements 

1. Organic HAP 0.16 pounds per 

pound of 

coating solids 

12-month rolling 

time period * 

Existing – 

General Use Coating 

SC V.1, V.2, 

VI.1 through 

VI.10 

40 CFR 63.4490(b)(1)

2. Organic HAP 0.26 pounds per 

pound of 

coating solids 

12-month rolling 

time period * 

Existing –

Thermoplastic Olefin 

(TPO) Coating 

SC V.1, V.2, 

VI.1 through 

VI.10 

40 CFR 63.4490(b)(3)

* as determined at the end of each calendar month 

1. The permittee shall determine whether the organic HAP emission rate is equal to or less than the applicable 

emission limits in 40 CFR 63.4490 using at least one of the following three options, which are listed in 40 CFR 

63.4491(a) through (c): 

a. Compliant material option, 

b. Emission rate without add-on controls option, or 

c. Emission rate with add-on controls option. 

2. The permittee shall include all coatings, thinners and/or other additives, and cleaning materials used when 

determining the emission rate. (40 CFR 63.4491)

3. Any coating operation(s) using the compliant material option or the emission rate without add-on controls option 

shall be in compliance with the applicable emission limits in 40 CFR 63.4490 at all times. 

(40 CFR 63.4500(a)(1)) 

4. Any coating operation(s) using the emission rate with add-on controls option shall be in compliance with the 

applicable emission limits at all times except during periods of startup, shutdown, and malfunction. 

(40 CFR 63.4500(a)(2)(i)) 

5. If the surface coating operation(s) meet the applicability criteria of more than one of the subcategory emission 

limits specified in 40 CFR 63.4490(a) or (b), the permittee may comply separately with each subcategory 

emission limit, or comply using one of the alternatives in 40 CFR 63.4490(c)(1) or (2). (40 CFR 63.4490(c))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 53 of 116 

II. MATERIAL LIMIT(S)

For the compliant materials option, the permittee shall meet the material limits specified in the following table. 

Material Limit 

Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method 

Underlying 

Applicable 

Requirements 

1. Each Thinner 

and/or Additive 

No Organic 

HAP * 

Continuous Each Coating Operation 

using 

Compliant Material 

Option 

SC VI.1, VI.2, 

VI.3, VI.5 

40 CFR 63.4491(a)

2. Each Cleaning 

Material 

No Organic 

HAP * 

Continuous Each Coating Operation 

using 

Compliant Material 

Option 

SC VI.1, VI.2, 

VI.3, VI.5 

40 CFR 63.4491(a)

* Determined according to 40 CFR 63.4541(a). 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall meet the 

operating limits specified in Table 1 of 40 CFR, Part 63, Subpart PPPP as identified below. The permittee must 

establish the operating limits during the performance test according to the requirements in 40 CFR 63.4567. 

(40 CFR 63.4492(b) and Table 1) 

Add-on Control 

Device Operating Limit 

Thermal oxidizer a. The average combustion temperature in any 3-hour period must not fall below the 

combustion temperature limit established according to 40 CFR 63.4567(a). 

Emission capture 

system that is a PTE 

according to 40 CFR 

63.4565(a). 

a. The direction of the air flow at all times must be into the enclosure; and either 

b. The average facial velocity of air through all natural draft openings in the enclosure 

must be at least 200 feet per minute; or 

c. The pressure drop across the enclosure must be at least 0.007 inch H2O, as 

established in Method 204 of Appendix M to 40 CFR 51. 

Emission capture 

system that is not a 

PTE according to 40 

CFR 63.4565(a). 

a. The average gas volumetric flow rate or duct static pressure in each duct between a 

capture device and add-on control device inlet in any 3-hour period must not fall 

below the average volumetric flow rate or duct static pressure limit established for 

that capture device according to 40 CFR 63.4567(f). 

2. For any coating operation(s) using the emission rate with add-on controls option, 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/or other additives, and cleaning materials used in, and waste materials 

generated by the controlled coating operation(s). The work practice plan shall specifiy practices and 

procedures to ensure at a minimum the following elements are implemented: 

a. All organic HAP containing coatings, thinners and/or other additives, cleaning materials, and waste 

materials must be stored in closed containers. (40 CFR 63.4493(b)(1))

b. Spills of organic HAP containing coatings, thinners and/or other additives, cleaning materials, and waste 

materials must be minimized. (40 CFR 63.4493(b)(2))

c. Organic HAP containing coatings, thinners and/or other additives, cleaning materials and waste materials 

must be conveyed from one location to another in closed containers or pipes. (40 CFR 63.4493(b)(3))

d. Mixing vessels which contain organic-HAP-containing coatings and other materials must be closed except 

when adding to, removing, or mixing the contents. (40 CFR 63.4493(b)(4))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 54 of 116 

e. Emissions of organic HAP must be minimized during cleaning of storage, mixing, and conveying 

equipment. (40 CFR 63.4493(b)(5))

The permittee may choose to comply with an alternative to the work practice standard, after receiving prior 

approval from the USEPA in accordance with 40 CFR 63.6(g). (40 CFR 63.4493(c)) 

3. If the affected source uses an emission capture system and add-on control device, the permittee shall develop 

and implement a written startup, shutdown and malfunction plan (SSMP) according to the provisions of 40 CFR 

63.6(e)(3). This SSMP must address the startup, shutdown and corrective actions in the event of a malfunction 

of the emission capture system or the add-on control device. 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 63.4500(c)) 

4. Any coating operation(s) using the emission rate with add-on controls option shall be in compliance with the 

operating limits for emission capture systems and add-on control devices required by 40 CFR 63.4492 at all 

times except during periods of startup, shutdown, and malfunction. (40 CFR 63.4500(a)(2)(ii)) 

5. Any coating operation(s) using the emission rate with add-on controls option shall be in compliance with the 

work practice standards in 40 CFR 63.4493 at all times. (40 CFR 63.4500(a)(2)(iii)) 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall not 

operate FGEASTPAINT and FGWESTROBOT unless the regenerative thermal oxidizers are installed, 

maintained, and operated in a satisfactory manner. (40 CFR 63.4492(b))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall determine the mass fraction of organic HAP for each material used, the mass fraction of 

coating solids for each coating, and the density of each material used in accordance with 40 CFR 63.4541, 

40 CFR 63.4551, and/or 40 CFR 63.4561. (40 CFR 63.4541, 40 CFR 63.4551, 40 CFR 63.4561) 

2. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall conduct 

each performance test required by 40 CFR 63.4560 according to the requirements in 40 CFR 63.7(e)(1) and 

under the conditions in 40 CFR 63.4564(a)(1) and (2), unless a waiver of the performance test is obtained in 

accordance with 40 CFR 63.7(h). (40 CFR 63.4564(a)) 

3. The permittee shall conduct each performance test of an emission capture system and add-on control device to 

determine capture efficiency and emission destruction or removal efficiency, according to the requirements in 

40 CFR 63.4565 and 40 CFR 63.4566. (40 CFR 63.4564(b))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 55 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii), 40 CFR 63.4531)

1. The permittee shall conduct an initial compliance demonstration for the initial compliance period according to 

the requirements in 40 CFR 63.4541, 40 CFR 63.4551, or 40 CFR 63.4561. The initial compliance period 

begins on the applicable compliance date specified in 40 CFR 63.4483 and ends on the last day of the 12th

month following the compliance date. If the compliance date occurs on any day other than the first of the 

month, then the compliance period extends through that month plus the next 12 months. (40 CFR 63.4483, 

40 CFR 63.4540, 40 CFR 63.4550, 40 CFR 63.4560) 

2. The permittee shall keep all records required by 40 CFR 63.4530 in the format and timeframes outlined in 

40 CFR 63.4531. (40 CFR 63.4542(d), 40 CFR 63.4552(d), 40 CFR 63.4563(j)) 

3. The permittee shall maintain, at a minimum, the following records for each compliance period: 

a. A copy of each notification and report that is submitted to comply with 40 CFR, Part 63, Subpart PPPP, and 

the documentation supporting each notification report. (40 CFR 63.4530(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 and density of each 

coating, thinner and/or other additive, and cleaning material, and the mass fraction of coating solids for 

each coating. (40 CFR 63.4530(b)) 

c. A list the coating operations on which each compliance option was used, and the beginning and ending 

dates and times for each compliance option used. (40 CFR 63.4530(c)(1)) 

d. For the compliant materials option, the calculation of the organic HAP content for each coating, using 

Equation 1 of 40 CFR 63.4541. (40 CFR 63.4530(c)(2))

e. For the emission rate without add-on controls option, the calculation of the total mass of organic HAP 

emissions for the coatings, thinners and/or additives, and cleaning materials used each month using 

Equations 1, 1A through 1C and 2 of 40 CFR 63.4551; and, if applicable, the calculation used to determine 

mass of organic HAP in waste materials according to 40 CFR 63.4551(e)(4); the calculation of the total 

mass of coating solids used each month using Equation 2 of 40 CFR 63.4551; and the calculation of each 

12-month organic HAP emission rate using Equation 3 of 40 CFR 63.4551. (40 CFR 63.4530(c)(3)) 

f. For the emission rate with add-on controls option, the calculations specified in 40 CFR 63.4530(c)(4)(i) 

through (v). (40 CFR 63.4530(c)(4))

g. The name and mass or volume of each coating, thinner and/or other additive, and cleaning material used 

during each compliance period. If the compliant material option is used for all coatings at the affected 

source, the permittee may maintain purchase records for each material used rather than a record of the 

mass used. (40 CFR 63.4530(d)) 

h. The mass fraction of organic HAP for each coating, thinner and/or additive, and cleaning material used 

during each compliance period. (40 CFR 63.4530(e)) 

i. The mass fraction of coating solids for each coating used during each compliance period. 

(40 CFR 63.4530(f)) 

j. The information specified in 40 CFR 63.4530(g)(1) through (3), if an allowance is used in Equation 1 of 40 

CFR 63.4551 for organic HAP contained in waste materials sent to or designated for shipment to a 

treatment, storage, and disposal facility (TSDF) according to 40 CFR 63.4551(e)(4). (40 CFR 63.4530(g)) 

k. The date, time, and duration of each deviation. (40 CFR 63.4530(h)) 

l. For the emission rate with add-on controls option, records specified in 40 CFR 63.4530(i)(1) through (8). 

(40 CFR 63.4530(i)) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 56 of 116 

4. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall 

demonstrate continuous compliance with the operating limits specified in Table 1 to 40 CFR, Part 63, Subpart 

PPPP using the applicable method(s) described below: (40 CFR 63.4563(c)) 

Add-on Control 

Device Operating Limit Continuous Compliance Demonstration Method 

Thermal oxidizer a. The average combustion temperature in 

any 3-hour period must not fall below the 

combustion temperature limit established 

according to 40 CFR 63.4567(a). 

i. Collect the combustion temperature data 

according to 40 CFR 63.4568(c); 

ii. Reduce the data to 3-hour block 

averages; and 

ii. Maintain the 3-hour average combustion 

temperature at or above the temperature 

limit. 

Emission capture 

system that is a PTE 

according to 40 CFR 

63.4565(a). 

a. The direction of the air flow at all times 

must be into the enclosure; and either 

b. The average facial velocity of air 

through all natural draft openings in the 

enclosure must be at least 200 feet per 

minute; or 

c. The pressure drop across the enclosure 

must be at least 0.007 inch H2O, as 

established in Method 204 of Appendix 

M to 40 CFR, Part 51. 

i. Collect the direction of air flow, and 

either the facial velocity of air through all 

natural draft openings according to 40 

CFR 63.4568(g)(1) or the pressure drop 

across the enclosure according to 40 

CFR 63.4568(g)(2); and 

ii. Maintain the facial velocity of air flow 

through all natural draft openings or the 

pressure drop at or above the facial 

velocity limit or pressure drop limit, and 

maintain the direction of air flow into the 

enclosure at all times. 

Emission capture 

system that is not a 

PTE according to 40 

CFR 63.4565(a). 

a. The average gas volumetric flow rate or 

duct static pressure in each duct between 

a capture device and add-on control 

device inlet in any 3-hour period must not 

fall below the average volumetric flow rate 

or duct static pressure limit established for 

that capture device according to 40 CFR 

63.4567(f). 

i. Collect the gas volumetric flow rate or 

duct static pressure for each capture 

device according to 40 CFR 63.4568(g); 

ii. Reduce the data to 3-hour block 

averages; and 

iii. Maintain the 3-hour average gas 

volumetric flow rate or duct static 

pressure for each capture device at or 

above the gas volumetric flow rate or 

duct static pressure limit. 

5. For each coating used for the compliant coating option, the permittee shall demonstrate continuous compliance 

with the emission limit in 40 CFR 63.4490, for each compliance period, using Equation 1 of 40 CFR 63.4541. 

For each thinner and cleaning material used, the permittee shall determine continuous compliance according to 

40 CFR 63.4541(a). (40 CFR 63.4542) 

6. For any coating operation or group of coating operations using the emission rate without add-on controls 

option, the permittee shall demonstrate continuous compliance with the applicable organic HAP emission limit 

in 40 CFR 63.4490, for each compliance period according to 40 CFR 63.4551(a) through (g). (40 CFR 63.4552)

7. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall 

demonstrate continuous compliance with the applicable organic HAP emission limit, for each compliance period 

according to the procedures in 40 CFR 63.4561. (40 CFR 63.4563) 

8. During the performance test required by 40 CFR 63.4560, the permittee shall perform the applicable monitoring 

and recordkeeping in accordance with 40 CFR 63.4567 to establish the emission capture system and add-on 

control device operating limits required by 40 CFR 63.4492. (40 CFR 63.4567) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 57 of 116 

9. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall install, 

operate, and maintain each Continuous Parameter Monitoring System (CPMS) according to the requirements 

of 40 CFR 63.4568(a). If the capture system contains a bypass line, the permittee shall comply with the 

requirements of 40 CFR 63.4568(b). (40 CFR 63.4568) 

10. The permittee must apply to the USEPA for approval of alternative monitoring under 40 CFR 63.8(f), if using an 

add-on control device other than those listed in Table 1 of 40 CFR, Part 63, Subpart PPPP, or to monitor an 

alternative parameter and comply with a different operating limit. (40 CFR 63.4492(c)) 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

4. For the compliant material option, the use of any coating, thinner or cleaning material which does not meet the 

criteria specified in 40 CFR 63.4542(a) is a deviation that must be reported as specified in 40 CFR 

63.4510(c)(6) and 40 CFR 63.4520(a)(5) (40 CFR 63.4542(b))

5. For the emission rate without add-on controls, if the organic HAP emission rate for any compliance period 

exceeds the applicable emission limit specified in 40 CFR 63.4490, the permittee shall report this as a deviation 

as specified in 40 CFR 63.4510(c)(6) and 40 CFR 63.4520(a)(6). (40 CFR 63.4552(b)) 

6. For the emission rate with add-on controls option, the permittee shall report the following as deviations as 

specified in 40 CFR 63.4510(c)(6) and 40 CFR 63.4520(a)(7): 

a. The organic HAP emission rate for any compliance period exceeds the applicable emission limit specified 

in 40 CFR 63.4490; (40 CFR 63.4563(b))

b. An operating parameter is out of the allowed range; (40 CFR 63.4563(c)(1)) 

c. Any control system by-pass line, for which liquid-liquid material balances are not carried out, is opened; 

(40 CFR 63.4563(d))

d. Deviations from work practice standards occur. (40 CFR 63.4563(e)) 

7. The Permittee shall submit the applicable notifications specified in 40 CFR 63.7(b) and (c), 63.8(f)(4) and 

63.9(b) through (e) and (h), an initial notification and a notification of compliance status as specified in 40 CFR 

63.4510. (40 CFR, Part 63, Subparts A and PPPP)

8. The permittee shall submit all semiannual compliance reports as required by 40 CFR 63.4520. Each 

semiannual compliance report shall identify which coating operation(s) used each compliance option, and if 

there were no deviations from the emission limitations in 40 CFR 63.4490, include a statement that the coating 

operations were in compliance. (40 CFR 63.4520, 40 CFR 63.4542(c), 40 CFR 63.4552(c), 40 CFR 63.4563(f)) 

9. For any coating operation(s) using the emission rate with add-on controls option, the permittee shall submit all 

performance test reports for emission capture systems and add-on control devices. (40 CFR 63.4520(b)) 

10. If the emission rate with add-on controls option is used and a startup, shutdown, or malfunction occurs during 

the semiannual reporting period, the permittee shall submit a SSM report as specified in 40 CFR 63.4520(c). 

(40 CFR 63.4520(c), 40 CFR 63.10(d))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 58 of 116 

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

NA NA NA NA 

IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR Part 63, Subpart A and Subpart PPPP for Surface Coating of Plastic Parts 

and Products. (40 CFR, Part 63, Subparts A and PPPP) 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 59 of 116 

FGRULE290 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION

Any emission unit that emits air contaminants and is exempt from the requirements of Rule 201 pursuant to Rules 

278 and 290. 

Emission Unit: EUWASTESOLVRC, EUASSEMBLYOPS 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

1. Each emission unit that emits only noncarcinogenic volatile organic compounds or noncarcinogenic materials 

which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone if the total uncontrolled 

or controlled emissions of air contaminants are not more than 1,000 or 500 pounds per month, respectively. 

(R 336.1290(a)(i)) 

2. Each emission unit that the total uncontrolled or controlled emissions of air contaminants are not more than 

1,000 or 500 pounds per month, respectively, and all the following criteria listed below are met: 

(R 336.1290(a)(ii)) 

a. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and 

noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of 

ozone, with initial threshold screening levels greater than or equal to 2.0 micrograms per cubic meter, the 

uncontrolled or controlled emissions shall not exceed 1,000 or 500 pounds per month, respectively. 

(R 336.1290(a)(ii)(A)) 

b. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and 

noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of 

ozone, with initial threshold screening levels greater than or equal to 0.04 microgram per cubic meter and 

less than 2.0 micrograms per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 

10 pounds per month, respectively. (R 336.1290(a)(ii)(B)) 

c. For carcinogenic air contaminants with initial risk screening levels greater than or equal to 0.04 microgram 

per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 10 pounds per month, 

respectively. (R 336.1290(a)(ii)(C)) 

d. The emission unit shall not emit any air contaminants, excluding non-carcinogenic volatile organic 

compounds and noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to 

the formation of ozone, with an initial threshold screening level or initial risk screening level less than 0.04 

microgram per cubic meter. (R 336.1290(a)(ii)(D)) 

3. Each emission unit that emits noncarcinogenic particulate air contaminants and other air contaminants that are 

exempted under Rule 290(a)(i) and/or Rule 290(a)(ii), above, and all of the following provisions are met: 

(R 336.1290(a)(iii)) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 60 of 116 

a. The particulate emissions are controlled by an appropriately designed and operated fabric filter collector or 

an equivalent control system which is designed to control particulate matter to a concentration of less than 

or equal to 0.01 pound of particulate per 1,000 pounds of exhaust gases and which does not have an 

exhaust gas flow rate more than 30,000 actual cubic feet per minute. (R 336.1290(a)(iii)(A)) 

b. The visible emissions from the emission unit are not more than 5% opacity in accordance with the methods 

contained in Rule 303. (R 336.1290(a)(iii)(B)) 

c. The initial threshold screening level for each particulate air contaminant, excluding nuisance particulate, is 

more than 2.0 micrograms per cubic meter. (R 336.1290(a)(iii)(C))

II. MATERIAL LIMIT(S)

NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The provisions of Rule 290 apply to each emission unit that is operating pursuant to Rule 290. (R 336.1290)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records of the following information for each emission unit for each calendar 

month using the methods outlined in the DEQ Rule 290 Permit to Install Exemption Record form (EQP 3558) or 

an alternative format that is approved by the AQD District Supervisor. (R 336.1213(3)) 

a. Records identifying each air contaminant that is emitted. (R 336.1213(3)) 

b. Records identifying if each air contaminant is controlled or uncontrolled. (R 336.1213(3)) 

c. Records identifying if each air contaminant is either carcinogenic or non-carcinogenic. (R 336.1213(3)) 

d. Records identifying the ITSL and IRSL, if established, of each air contaminant that is being emitted under 

the provisions of Rules 290(a)(ii) and (iii). (R 336.1213(3)) 

e. Material use and calculations identifying the quality, nature, and quantity of the air contaminant emissions 

in sufficient detail to demonstrate that the actual emissions of the emission unit meet the emission limits 

outlined in this table and Rule 290. (R 336.1213(3), R 336.1290(c)) 

2. The permittee shall maintain an inventory of each emission unit that is exempt pursuant to Rule 290. This 

inventory shall include the following information. (R 336.1213(3)) 

a. The permittee shall maintain a written description of each emission unit as it is maintained and operated 

throughout the life of the emission unit. (R 336.1290(b), R 336.1213(3)) 

b. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), 

the permittee shall maintain a written description of the control device, including the designed control 

efficiency and the designed exhaust gas flow rate. (R 336.1213(3)) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 61 of 116 

3. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), the 

permittee shall perform a monthly visible emission observation of each stack or vent during routine operating 

conditions. This observation need not be performed using Method 9. The permittee shall keep a written record 

of the results of each observation. (R 336.1213(3))

See Appendix 1-4 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

NA 

IX. OTHER REQUIREMENT(S)

NA 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 62 of 116 

FGRULE287(c) 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION

Any emission unit that emits air contaminants and is exempt from the requirements of Rule 201 pursuant to Rules 

278 and Rule 287(c). 

Emission Unit: EUWESTASSEMBLY 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

NA 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating 

Scenario 

Equipment Underlying Applicable 

Requirement 

1. Coatings 200 

gallons 

Per month, as applied, minus 

water, per emission unit 

NA R 336.1287(c)(i) 

III. PROCESS/OPERATIONAL RESTRICTION(S)

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. Any exhaust system that serves only coating spray equipment shall be equipped with a properly installed and 

operating particulate control system. (R 336.1287(c)(ii))

V. TESTING/SAMPLING

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. The permittee shall maintain records of the following information for each emission unit for each calendar 

month using the methods outlined in the DEQ Rule 287(c) Permit to Install Exemption Record form (EQP 3562) 

or an alternative format that is approved by the AQD District Supervisor. (R 336.1213(3)) 

a. Volume of coating used, as applied, minus water, in gallons. (R 336.1287(c)(iii)) 

b. Documentation of any filter replacements for exhaust systems serving coating spray equipment. 

(R 336.1213(3)) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 63 of 116 

See Appendix 1-4 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S) 

NA 

IX. OTHER REQUIREMENT(S)

NA 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 64 of 116 

FGCOLDCLEANERS 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Any cold cleaner that is grandfathered or exempt from Rule 201 pursuant to Rule 281(h) or Rule 285(r)(iv). Existing 

cold cleaners were placed into operation prior to July 1, 1979. New cold cleaners were placed into operation on or 

after July 1, 1979. 

Emission Unit: EUMAINTCLEANER 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

NA 

II. MATERIAL LIMIT(S)

1. The permittee shall not use cleaning solvents containing more than 5 percent by weight of the following 

halogenated compounds: methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, 

carbon tetrachloride, chloroform, or any combination thereof. (R 336.1213(2))

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. Cleaned parts shall be drained for no less than 15 seconds or until dripping ceases. (R 336.1611(2)(b), 

R 336.1707(3)(b)) 

2. The permittee shall perform routine maintenance on each cold cleaner as recommended by the manufacturer. 

(R 336.1213(3))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The cold cleaner must meet one of the following design requirements: 

a. The air/vapor interface of the cold cleaner is no more than 10 square feet. (R 336.1281(h)) 

b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general in-plant 

environment. (R 336.1285(r)(iv)) 

2. The cold cleaner shall be equipped with a device for draining cleaned parts. (R 336.1611(2)(b), 

R 336.1707(3)(b)) 

3. All new and existing cold cleaners shall be equipped with a cover and the cover shall be closed whenever parts 

are not being handled in the cold cleaner. (R 336.1611(2)(a), R 336.1707(3)(a)) 

4. The cover of a new cold cleaner shall be mechanically assisted if the Reid vapor pressure of the solvent is 

more than 0.3 psia or if the solvent is agitated or heated. (R 336.1707(3)(a)) 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 65 of 116 

5. If the Reid vapor pressure of any solvent used in a new cold cleaner is greater than 0.6 psia; or, if any solvent 

used in a new cold cleaner is heated above 120 degrees Fahrenheit, then the cold cleaner must comply with at 

least one of the following provisions: 

a. The cold cleaner must be designed such that the ratio of the freeboard height to the width of the cleaner is 

equal to or greater than 0.7. (R 336.1707(2)(a)) 

b. The solvent bath must be covered with water if the solvent is insoluble and has a specific gravity of more 

than 1.0. (R 336.1707(2)(b)) 

c. The cold cleaner must be controlled by a carbon adsorption system, condensation system, or other method 

of equivalent control approved by the AQD. (R 336.1707(2)(c))

V. TESTING/SAMPLING

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii)) 

1. For each new cold cleaner in which the solvent is heated, the solvent temperature shall be monitored and 

recorded at least once each calendar week during routine operating conditions. (R 336.1213(3)) 

2. The permittee shall maintain the following information on file for each cold cleaner: (R 336.1213(3)) 

a. A serial number, model number, or other unique identifier for each cold cleaner. 

b. The date the unit was installed, manufactured or that it commenced operation. 

c. The air/vapor interface area for any unit claimed to be exempt under Rule 281(h). 

d. The applicable Rule 201 exemption. 

e. The Reid vapor pressure of each solvent used. 

f. If applicable, the option chosen to comply with Rule 707(2). 

3. The permittee shall maintain written operating procedures for each cold cleaner. These written procedures 

shall be posted in an accessible, conspicuous location near each cold cleaner. (R 336.1611(3), R 336.1707(4)) 

4. As noted in Rule 611(2)(c) and Rule 707(3)(c), if applicable, an initial demonstration that the waste solvent is a 

safety hazard shall be made prior to storage in non-closed containers. If the waste solvent is a safety hazard 

and is stored in non-closed containers, verification that the waste solvent is disposed of so that not more than 

20%, by weight, is allowed to evaporate into the atmosphere shall be made on a monthly basis. 

(R 336.1213(3), R 336.1611(2)(c), R 336.1707(3)(c))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 66 of 116 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1-8 

VIII. STACK/VENT RESTRICTION(S)

NA 

IX. OTHER REQUIREMENT(S)

NA 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 67 of 116 

E. NON-APPLICABLE REQUIREMENTS 

At the time of ROP issuance, the AQD has determined that no non-applicable requirements have been identified for 

incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to Rule 

213(6)(a)(ii). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 68 of 116 

APPENDICES

Appendix 1-1: Abbreviations & Acronyms 

The following is an alphabetical listing of abbreviations/acronyms that may be used in this permit. 

AQD Air Quality Division MM Million 

acfm Actual cubic feet per minute MSDS Material Safety Data Sheet 

BACT Best Available Control Technology MW Megawatts 

BTU British Thermal Unit NA Not Applicable 

°C Degrees Celsius NAAQS National Ambient Air Quality Standards 

CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air 

Pollutants 

CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds 

CEM Continuous Emission Monitoring NOx Oxides of Nitrogen 

CFR Code of Federal Regulations NSPS New Source Performance Standards 

CO Carbon Monoxide NSR New Source Review 

COM Continuous Opacity Monitoring PM Particulate Matter 

department Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns in 

diameter 

dscf Dry standard cubic foot pph Pound per hour 

dscm Dry standard cubic meter ppm Parts per million 

EPA United States Environmental Protection Agency ppmv Parts per million by volume 

EU Emission Unit ppmw Parts per million by weight 

°F Degrees Fahrenheit PS Performance Specification 

FG Flexible Group PSD Prevention of Significant Deterioration 

GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute 

gr Grains psig Pounds per square inch gauge 

HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure 

Hg Mercury PTI Permit to Install 

hr Hour RACT Reasonable Available Control Technology 

HP Horsepower ROP Renewable Operating Permit 

H2S Hydrogen Sulfide SC Special Condition 

HVLP High Volume Low Pressure * scf Standard cubic feet 

ID Identification (Number) sec Seconds 

IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction 

ITSL Initial Threshold Screening Level SO2 Sulfur Dioxide 

LAER Lowest Achievable Emission Rate SRN State Registration Number 

lb Pound TAC Toxic Air Contaminant 

m Meter Temp Temperature 

MACT Maximum Achievable Control Technology THC Total Hydrocarbons 

MAERS Michigan Air Emissions Reporting System tpy Tons per year 

MAP Malfunction Abatement Plan μg Microgram 

MDEQ Michigan Department of Environmental Quality VE Visible Emissions 

mg Milligram VOC Volatile Organic Compounds 

mm Millimeter yr Year 

*For HVLP applicators, the pressure measured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig). 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

Expiration Date: April 30, 2012 

PTI No: MI-PTI-N2079-2007 

Page 69 of 116 

Appendix 1-2. Schedule of Compliance 

The permittee certified in the ROP application that this stationary source is in compliance with all applicable 

requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of 

Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii)) 

Appendix 1-3. Monitoring Requirements 

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements 

identified and referenced in. 

The permittee shall develop and implement a Compliance Assurance Monitoring Plan in accordance with 40 CFR 

Part 64 and the applicable requirements referenced in FGEASTPAINT and FGWESTROBOPAINT. Approvable 

plans and any modifications shall be submitted to the AQD District Supervisor prior to the issuance of this permit. 

Any modifications and subsequent changes to the plan by the Company shall be promptly submitted to the AQD 

Grand Rapids District Supervisor in accordance with the requirements referenced in FGEASTPAINT, 

FGWESTROBOPAINT and 40 CFR Part 64. 

Appendix 1-4. Recordkeeping 

The permittee shall use the following approved formats and procedures for the recordkeeping requirements 

referenced in EUPRIMEMANUAL, EUBASEMANUAL, EUCLEARMANUAL, and FGEASTPAINT. Alternative 

formats must be approved by the AQD District Supervisor. 
 Section 1 – 52nd Street ROP No: MI-

 Expiration Da PTI No: MI-P

Page 70 of 116 

Appendix 1-4.A Total VOC emissions for single and two component coatings 

TIME PERIOD : Applicator 

 A B * C D E=(AxB)+(CxD) 

COATING GALLONS OF COATING RESIN AS APPLIED LBS OF VOC/GAL OF RESIN COMPONENT AS APPLIED/MIXED GAL OF CATALYST USED LBS OF VOC PER GAL OF CATALYST USED LBS OF VOC 

TOTAL UNCONTROLLED LBS VOC = G = SUM OF ALL E's G LBS CONTROLLED VOC = H = G x F H Tons VOC emitted this day = J = H/2000 J Tons of VOC's emitted 364 previous days = K K Tons of VOC's emitted 365-day rolling period = L = J + K L At the end of each production day: Hours/day of operation, coating line = M M LBS OF VOC/HOUR = N = H/M N 
 Section 1 – 52nd Street ROP No: MI-

 Expiration Da PTI No: MI-P

Page 71 of 116 

Appendix 1-4.BVOC content of solvent-based coatings, no-water, with reducers 

A B C D E F 

MIX NAME BASE RESIN DESCRIPTION BASE RESIN RATIO LBS OF VOC/GAL OF BASE RESIN SOLVENT DESCRIPTION SOLVENT RATIO LBS OF VOC/ GAL OF SOLVENT CATALYST DESCRIPTION CATALYST RATIO LBS 

VOC P

GAL 

CATAL

 PMN Number 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 72 of 116 

Appendix 1-4.C 

VOC Purge and Clean-up solvents. 

 A B C=(AxB) D E E=(BxD) F=(C-E) 

DATE 

TOTAL 

CLEAN 

PURGE 

USED 

(GALLONS)

LBS OF 

VOC/GAL 

OF CLEAN 

PURGE 

LBS OF VOC 

USED 

TOTAL 

WASTE 

(GALLONS)

LBS OF 

VOC/GAL 

OF 

WASTE 

LBS OF 

VOC OF 

WASTE 

LBS OF VOC 

EMITTED 

 

 

 

 

 

 

 

 

 

 

TOTAL UNCONTROLLED LBS VOC = G = SUM OF ALL F's G 

 

Tons VOC emitted this day = H = G/2000 H 

 

Tons of VOC's emitted 364 previous days = I I 

 

Tons of VOC's emitted 365-day rolling period = J = I + H J 

 

At the end of each production day: 

Hours/day of operation, coating line = K K 

 

LBS OF VOC/HOUR = L = H/K L 
 Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 73 of 116 

Appendix 1-5. Testing Procedures 

There are no specific testing requirement plans or procedures for this ROP. Therefore, this appendix is not 

applicable. 

Appendix 1-6. Permits to Install 

The following table lists any Permits to Install issued since the effective date of previously issued ROP No. 

199600144. 

Permit to Install 

Number Description of Equipment 

Corresponding Emission Unit(s) or 

Flexible Group(s) 

201-05 This group consists of air-dried prime/adhesion 

prime, base, and clear coat applications to 

plastic parts. The prime/adhesion prime coating 

consists of two robots in one booth (1 auto 

booth) and one manual booth. The base coating 

consists of four robots in one booth (1 auto 

booth), one manual booth and flash-off booth. 

The clear coating consists of four robots in one 

booth (1 auto booth) and one manual booth. 

The sprayed parts are dried in a bake oven. The 

auto booth emissions are captured and 

controlled by a regenerative thermal oxidizer. 

The manual booth emissions are captured and 

vented to the ambient air. All booths use downdraft water wash particulate control. 

EUPRIMEROBOT1, EUPRIMEROBOT2, 

EUPRIMEMANUAL, EUBASEROBOT1, 

EUBASEROBOT2, EUBASEROBOT3 

EUBASEROBOT4, EUBASEMANUAL, 

EUCLEARROBOT1, EUCLEARROBOT2, 

EUCLEARROBOT3, EUCLEARROBOT4, 

EUCLEARMANUAL, EUOVEN 

Appendix 1-7. Emission Calculations 

Specific emission calculations to be used with monitoring, testing or recordkeeping data are detailed in the 

appropriate Source-wide, Emission Unit and/or Flexible group Special Conditions. Therefore, this appendix is not 

applicable. 

Appendix 1-8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting section of 

the Source-wide, emission unit and/or flexible group special conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Specific reporting requirement formats and procedures are detailed in Part A or the appropriate Source-wide, 

emission unit and/or flexible group special conditions. Therefore, Part B of this appendix is not applicable. 
Section 1 – 52nd Street ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 74 of 116 

Appendix 1-9. Operation and Maintenance Plan 

The permittee shall develop and implement an Operation and Maintenance Plan for the facility. At a minimum this 

plan shall address the preventative maintenance of the coating lines and associated capture and control systems. 

Approvable plans and any modifications shall be submitted to the AQD District Supervisor prior to the issuance of 

this permit. Any modifications and subsequent changes to the plan by the Company shall be promptly submitted to 

the AQD Grand Rapids District Supervisor. 
 Section 2 – Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 75 of 116 

Section 2 - Barden Plating 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 76 of 116 

A. GENERAL CONDITIONS 

Permit Enforceability 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5))

• Those conditions that are hereby incorporated in a state-only enforceable Source-wide Permit to Install (PTI) 

pursuant to Rule 201(2)(d) are designated by Footnote 1. (R 336.1213(5)(a), R 336.1214a(5))

• Those conditions that are hereby incorporated in federally enforceable Source-wide PTI No. MI-PTI-N2079-2007 

pursuant to Rule 201(2)(c) are designated by Footnote 2. (R 336.1213(5)(b), R 336.1214a(3))

General Provisions 

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of 

Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 

1994 PA 451, as amended (Act 451), and is grounds for enforcement action, for ROP revocation or revision, or 

for denial of the renewal of the ROP. All terms and conditions of this ROP that are designated as federally 

enforceable are enforceable by the Administrator of the United States Environmental Protection Agency (EPA) 

and by citizens under the provisions of the federal Clean Air Act (CAA). Any terms and conditions based on 

applicable requirements which are designated as “state only” are not enforceable by the EPA or citizens 

pursuant to the CAA. (R 336.1213(1)(a))

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or 

reduce the permitted activity in order to maintain compliance with the conditions of this ROP. 

(R 336.1213(1)(b))

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit 

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make 

changes, at the permittee’s own risk, pursuant to Rules 215 and 216. (R 336.1213(1)(c))

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation 

of credentials and other documents as may be required by law and upon stating the authority for and purpose 

of the investigation, to perform any of the following activities (R 336.1213(1)(d)): 

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity is 

conducted or where records must be kept under the conditions of the ROP. 

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

ROP. 

c. Inspect, at reasonable times, any of the following: 

i. Any stationary source. 

ii. Any emission unit. 

iii. Any equipment, including monitoring and air pollution control equipment. 

iv. Any work practices or operations regulated or required under the ROP. 

d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the ROP or applicable requirements. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 77 of 116 

5. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to 

determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies 

of any records that are required to be kept as a term or condition of this ROP. For information which is claimed 

by the permittee to be confidential, consistent with the requirements of 1976 PA 442, MCL §15.231 et seq., and 

known as the Freedom of Information Act, the person may also be required to furnish the records directly to the 

EPA together with a claim of confidentiality. (R 336.1213(1)(e))

6. A challenge by any person, the Administrator of the EPA, or the department to a particular condition or a part of 

this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other 

condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of 

Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

Equipment & Design 

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370)

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance 

with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

Emission Limits 

11. Except as provided in subrules 2, 3, and 4 of Rule 301, a person shall not cause or permit to be discharged into 

the outer air from a process or process equipment a visible emission of a density greater than the most 

stringent of Rule 301(1)(a) or (b) unless otherwise specified in this ROP. The grading of visible emissions shall 

be determined in accordance with Rule 303. (R 336.1301(1) in pertinent part): 

a. A 6-minute average of 20% opacity, except for one 6-minute average per hour of not more than 27% 

opacity. 

b. A limit specified by an applicable federal new source performance standard. 

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or in reaction with other air contaminants, either of the following: 

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.1 

(R 336.1901(a)) 

b. Unreasonable interference with the comfortable enjoyment of life and property.1 (R 336.1901(b)) 

Testing/Sampling 

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner’s or operator’s expense, in accordance with Rule 1001 and Rule 1003, under 

any of the conditions listed in Rule 1001(1). (R 336.2001)

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and 

Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 78 of 116 

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days following the last date of the test. (R 336.2001(4))

Monitoring/Recordkeeping 

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following 

information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)): 

a. The date, location, time, and method of sampling or measurements. 

b. The dates the analyses of the samples were performed. 

c. The company or entity that performed the analyses of the samples. 

d. The analytical techniques or methods used. 

e. The results of the analyses. 

f. The related process operating conditions or parameters that existed at the time of sampling or 

measurement. 

17. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records, for continuous monitoring instrumentation and copies of all reports required by the ROP. 

(R 336.1213(1)(e), R 336.1213(3)(b)(ii))

Certification & Reporting 

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be 

submitted to the department as a term or condition of this ROP shall contain an original certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

19. A responsible official shall certify to the appropriate District Office of the AQD and the EPA that the stationary 

source is and has been in compliance with all terms and conditions contained in the ROP except for deviations 

that have been or are being reported to the appropriate District Office of the AQD pursuant to Rule 213(3)(c). 

This certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and shall state that, 

based on information and belief formed after reasonable inquiry, the statements and information in the 

certification are true, accurate, and complete. The EPA address is: US EPA, Air Compliance Data - Michigan, 

Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL, 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special 

conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt 

reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise 

described in this ROP (R 336.1213(3)(c)): 

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to 

this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to 

Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the 

semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and 

the actions taken to minimize or correct each deviation. 

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 79 of 116 

22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in 

Rule 213(3)(c)(iii) as either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible official with each report which states that, based on information 

and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports 

of deviations from the emissions allowed under the ROP were submitted to the department pursuant to 

Rule 213(3)(c)(ii), a certification by a responsible official which states that, based on information and belief 

formed after reasonable inquiry, the statements and information contained in each of the reports submitted 

during the previous month were true, accurate, and complete. The certification shall include a listing of the 

reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a 

monthly basis pursuant to this paragraph shall include a statement that certification of the report will be 

provided within 30 days following the end of the calendar month. 

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate District Office of the AQD. 

All instances of deviations from ROP requirements during the reporting period shall be clearly identified in the 

reports. (R 336.1213(3)(c)(i))

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine 

the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required in Rule 912, to the appropriate District Office of the AQD. The notice 

shall be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal 

conditions or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, or oral 

communication. Written reports, if required under Rule 912, must be submitted to the appropriate District 

Supervisor within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or 

malfunction has been corrected, or within 30 days of discovery of the abnormal conditions or malfunction, 

whichever is first. The written reports shall include all of the information required in Rule 912(5) and shall be 

certified by a responsible official in a manner consistent with the CAA. (R 336.1912)

Permit Shield 

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements 

as of the date of ROP issuance, if either of the following provisions is satisfied (R 336.1213(6)(a)(i), 

R 336.1213(6)(a)(ii)): 

a. The applicable requirements are included and are specifically identified in the ROP. 

b. The permit includes a determination or concise summary of the determination by the department that other 

specifically identified requirements are not applicable to the stationary source. 

Any requirements identified in Part E of this ROP have been identified as non-applicable to this ROP and are 

included in the permit shield. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 80 of 116 

27. Nothing in this ROP shall alter or affect any of the following: 

a. The provisions of Section 303 of the CAA, emergency orders, including the authority of the EPA under 

Section 303 of the CAA. (R 336.1213(6)(b)(i))

b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at 

the time of this ROP issuance. (R 336.1213(6)(b)(ii))

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. 

(R 336.1213(6)(b)(iii)) 

d. The ability of the EPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the 

following: 

a. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5))

b. Administrative amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii))

c. Administrative amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved 

by the department. (R 336.1216(1)(c)(iii))

d. Minor permit modifications made pursuant to Rule 216(2). (R 336.1216(2)(f))

e. State-only modifications made pursuant to Rule 216(4) until the changes have been approved by the 

department. (R 336.1216(4)(e))

29. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration 

date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP 

does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original 

ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))

Revisions 

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the 

ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to 

Rule 216(1). (R 336.1219(3))

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the time frames specified in Rule 216. (R 336.1210(9))

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the 

department takes final action, the permittee shall comply with both the applicable requirements governing the 

change and the ROP terms and conditions proposed in the application for the modification. During this time 

period, the permittee may choose to not comply with the existing ROP terms and conditions that the application 

seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the 

application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(3), 

R 336.1216(2)(d), R 336.1216(4)(d))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 81 of 116 

Reopenings 

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under 

any of the following circumstances: 

a. If additional requirements become applicable to this stationary source with three or more years remaining in 

the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 

expiration date. (R 336.1217(2)(a)(i))

b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. 

(R 336.1217(2)(a)(ii))

c. If the department determines that the ROP contains a material mistake, information required by any 

applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or 

the terms or conditions of the ROP. (R 336.1217(2)(a)(iii))

d. If the department determines that the ROP must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv))

Renewals 

35. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by 

the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. 

(R 336.1210(7))

Stratospheric Ozone Protection 

36. If the permittee is subject to 40 CFR Part 82 and services, maintains, or repairs appliances except for motor 

vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small 

appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or 

recycling and recovery equipment, the permittee shall comply with all applicable standards for recycling and 

emissions reduction pursuant to 40 CFR Part 82, Subpart F. 

37. If the permittee is subject to 40 CFR Part 82 and performs a service on motor (fleet) vehicles when this service 

involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified in 

40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term “motor vehicle” as used in 

Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using 

Hydrochlorofluorocarbon-22 refrigerant. 

Risk Management Plan 

38. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall register and submit to the EPA 

the required data related to the risk management plan for reducing the probability of accidental releases of any 

regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 68.130. The list of 

substances, threshold quantities, and accident prevention regulations promulgated under Part 68 do not limit in 

any way the general duty provisions under Section 112(r)(1). 

39. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements of 

Part 68 no later than the latest of the following dates as provided in 68.10(a): 

a. June 21, 1999, 

b. Three years after the date on which a regulated substance is first listed under 68.130, or 

c. The date on which a regulated substance is first present above a threshold quantity in a process. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 82 of 116 

40. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 

40 CFR Part 68. 

41. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance with 

all applicable requirements of Section 112(r) as detailed in Rule 213(4)(c)). (40 CFR Part 68)

Emission Trading 

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the EPA as a part of 

Michigan’s State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. 

(R 336.1213(12))

Permit To Install (PTI) 

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt 

from the PTI requirements by any applicable rule. 2 (R 336.1201(1)) 

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence 

indicates the process or process equipment is not performing in accordance with the terms and conditions of 

the PTI or is violating the department’s rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451, PA 1994) 

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or 

operates the process or process equipment at the location authorized by the PTI. If a new owner or operator 

submits a written request to the department pursuant to Rule 219 and the department approves the request, 

this PTI will be amended to reflect the change of ownership or operational control. The request must include all 

of the information required by subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the 

appropriate AQD District Supervisor, MDEQ. 2 (R 336.1219) 

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and 

conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, 

the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the 

department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall 

notify the department via the Supervisor, Permit Section, MDEQ, AQD, P. O. Box 30260, Lansing, MI 48909, if 

it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment allowed 

by the terms and conditions from that PTI. 2 (R 336.1201(4)) 

Footnotes: 

1

This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 83 of 116 

B. SOURCE-WIDE CONDITIONS 

Part B outlines the Source-wide terms and conditions that apply to this stationary source. The permittee is subject 

to these special conditions for the stationary source in addition to the General Conditions in Part A and any other 

terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in 

the table. If there are no Source-wide conditions, this section will be left blank. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 84 of 116 

C. EMISSION UNIT CONDITIONS 

Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit 

Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General 

Conditions in Part A and any other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no conditions specific to individual emission units, this section will be left blank. 

EMISSION UNIT SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID Emission Unit Description 

(Including Process Equipment & 

Control Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUCONDITIONER Conditioner tank containing 1,3-dichloro-2-

propanol (DCP). This tank is controlled by 

a packed bed scrubber with mist 

eliminator. 

8/22/05 NA 

EUCHROMEETCH1 Chromic acid etch tank containing chromic 

acid and hydrochloric acid. This tank is 

controlled by a composite mesh pad 

scrubber. 

8/22/05 FGCHROME1 

EUCHROMEETCH2 Chromic acid etch tank containing chromic 

acid and hydrochloric acid. This tank is 

controlled by a composite mesh pad 

scrubber. 

8/22/05 FGCHROME1 

EUCHROMEETCH3 Chromic acid etch tank containing chromic 

acid and hydrochloric acid. This tank is 

controlled by a composite mesh pad 

scrubber. 

8/22/05 FGCHROME1 

EUNEUTRALIZER Process tank containing sulfuric acid. 8/22/05 FGNEUTCATACC 

EUCATALYST Process tank containing hydrochloric acid. 8/22/05 FGNEUTCATACC 

EUACCELERATOR Process tank containing hydrochloric acid. 8/22/05 FGNEUTCATACC 

EUELECTROLESSNI Electroless nickel plating tank. This tank is 

controlled by a packed bed scrubber with 

mist eliminators. This is an optional 

process to the electroless copper. 

8/22/05 NA 

EUELECTROLESSCU Electroless copper plating tank. This tank 

is controlled by a packed bed scrubber 

with mist eliminators. 

8/22/05 NA 

EUCOPPERSTRIKE Copper strike tank containing copper 

sulfate and sulfuric acid. 

8/22/05 FGCOPPER 

EUACIDCOPPER1 Process tank containing copper sulfate, 

ferrous sulfate and sulfuric acid. 

8/22/05 FGCOPPER 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 85 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & 

Control Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUACIDCOPPER2 Process tank containing copper sulfate, 

ferrous sulfate and sulfuric acid. 

8/22/05 FGCOPPER 

EUACIDCOPPER 3 Process tank containing copper sulfate, 

ferrous sulfate and sulfuric acid. 

8/22/05 FGCOPPER 

EUACIDCOPPER4 Process tank containing copper sulfate, 

ferrous sulfate and sulfuric acid. 

8/22/05 FGCOPPER 

EUACIDCOPPER5 Process tank containing copper sulfate, 

ferrous sulfate and sulfuric acid. 

8/22/05 FGCOPPER 

EUSEMIBRINI1 Semi-brite nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGSEMINICKEL 

EUSEMIBRINI2 Semi-brite nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGSEMINICKEL 

EUSEMIBRINI3 Semi-brite nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGSEMINICKEL 

EUSEMIBRINI4 Semi-brite nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGSEMINICKEL 

EUSEMIBRINI5 Semi-brite nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGSEMINICKEL 

EUBRINICKEL1 Brite nickel plating tank containing nickel 

sulfate, nickel chloride, formaldehyde and 

boric acid. 

8/22/05 FGBRIMICRONI 

EUBRINICKEL2 Brite nickel plating tank containing nickel 

sulfate, nickel chloride, formaldehyde and 

boric acid. 

8/22/05 FGBRIMICRONI 

EUMICRONI Micro-porous nickel plating tank containing 

nickel sulfate, nickel chloride, 

formaldehyde and boric acid. 

8/22/05 FGBRIMICRONI 

EUCHROME1 Decorative chrome electroplating tank with 

composite mesh pad scrubber and fume 

suppressant for control. 

8/22/05 FGCHROME2 

EUCHROME2 Decorative chrome electroplating tank with 

composite mesh pad scrubber and fume 

suppressant for control. 

8/22/05 FGCHROME2 

EUCHROME3 Decorative chrome electroplating tank with 

composite mesh pad scrubber and fume 

suppressant for control. 

8/22/05 FGCHROME2 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 86 of 116 

Emission Unit ID Emission Unit Description 

(Including Process Equipment & 

Control Device(s)) 

Installation 

Date/ 

Modification 

Date 

Flexible Group ID 

EUCHROMESTRIP Chrome strip tank containing sodium 

hydroxide controlled by a packed bed 

scrubber with mist eliminators. 

8/22/05 FGSTRIPTANKS 

EUNITRICSTRIP Nitric acid strip tank controlled by a packed 

bed scrubber with mist eliminators. 

8/22/05 FGSTRIPTANKS 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 87 of 116 

EUCONDITIONER

EMISSION UNIT CONDITIONS

DESCRIPTION

Conditioner tank containing 1,3-dichloro-2-propanol (DCP). 

Flexible Group ID: NA 

POLLUTION CONTROL EQUIPMENT

Packed bed scrubber with mist eliminator. 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. 1,3-dichloro2-propanol 0.48 pph2 Test method EUCONDITIONER SC V.1, VI.1, & 

VI.2 

R 336.1225, 

R 336.1702(a)

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate EUCONDITIONER unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the packed bed scrubber with mist 

eliminators and the monitoring equipment required to record the pressure drop across the packed bed 

scrubber.2 (R 336.1225, R 336.1702(a), R 336.1910)

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate EUCONDITIONER unless the packed bed scrubber with mist eliminator is 

installed, maintained, and operated in a satisfactory manner. 2 (R 336.1225, R 336.1702(a), R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 48 months from January 17, 2006 and within every 48 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify 1,3-dichloro-2-propanol emission rates from 

EUCONDITIONER by testing at owner's expense, in accordance with Department requirements. No less than 

60 days prior to testing, the permittee shall submit a complete test plan to the AQD. The AQD must approve 

the final plan prior to testing. Verification of emission rates includes the submittal of a complete report of the 

test results to the AQD within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004 

R 336.1213(3))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 88 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the pressure drop across the packed bed scrubber on a daily basis. 2 (R 336.1225, R 336.1702(a), 

R 336.1910)

2. The permittee shall keep records of daily pressure drop. 2 (R 336.1225, R 336.1702(a))

3. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-1 181 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 89 of 116 

EUELECTROLESSNI

EMISSION UNIT CONDITIONS

DESCRIPTION

Electroless nickel plating tank which is an optional process to the electroless copper. 

Flexible Group ID: NA 

POLLUTION CONTROL EQUIPMENT

Packed bed scrubber with mist eliminator. 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Nickel 0.0014 pph 1 Test Method EUELECTROLESSNI GC 13, SC V.1 

& VI.1 

R 336.1225 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate EUELECTROLESSNI unless the approved operation and maintenance plan, or 

an alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall 

include procedures for maintaining and operating in a satisfactory manner, the packed bed scrubber with mist 

eliminators and the monitoring equipment required to record the pressure drop across the packed bed 

scrubber. 2 (R 336.1224, R 336.1225, R 336.1910)

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate EUELECTROLESSNI unless the packed bed scrubber with mist eliminators is 

installed, maintained, and operated in a satisfactory manner. 2

 (R 336.1224, R 336.1225, R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 48 months from January 17, 2006 and within every 48 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify formaldehyde, nickel and 1,3 dichloro-2-propanol 

emission rates from FGN-1 by testing at owner's expense, in accordance with Department requirements. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD. The AQD must 

approve the final plan prior to testing. Verification of emission rates includes the submittal of a complete report 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 90 of 116 

of the test results to the AQD within 60 days following the last date of the test. (R 336.2001, R 336.2003, 

R 336.2004)

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor the 

pressure drop across the packed bed scrubber. 2 (R 336.1224, R 336.1225, R 336.1910)

2. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-4 461 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 91 of 116 

EUELECTROLESSCU 

EMISSION UNIT CONDITIONS

DESCRIPTION

Electroless copper plating tank. 

Flexible Group ID: NA 

POLLUTION CONTROL EQUIPMENT

Packed bed scrubber with mist eliminator. 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Formaldehyde 2.97 pph2 Test Method EUELECTROLESSCU SC V.1 R 336.1225, 

R 336.1702(a) 

2. Methanol 12.2 pph2 Test Method EUELECTROLESSCU SC V.1 R 336.1225, 

R 336.1702(a) 

3. VOC Less than 36 

tpy2

12-month rolling 

time period as 

determined at the 

end of each 

calendar month 

EUELECTROLESSCU SC VI.2, VI.3, 

& VI.4 

R 336.1205(3),

R 336.1225, 

R 336.1702(a) 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate EUELECTROLESSCU unless the approved operation and maintenance plan, 

or an alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall 

include procedures for maintaining and operating in a satisfactory manner, the packed bed scrubber with mist 

eliminators and the monitoring equipment required to record the pressure drop across the packed bed 

scrubber. 2 (R 336.1225, R 336.1702(a), R 336.1910)

2. The permittee shall not operate EUELECTROLESSCU for more than 4746 hours per 12-month rolling time 

period as determined at the end of each calendar month unless, after testing it is determined that the actual 

emission rates of formaldehyde and methanol from EUELECTROLESSCU are lower than the emission limits 

specified in SC 3.1a and 3.1b, then the permittee may use the following equation to determine maximum hours 

of operation: 2

 (R 336.1205, R 336.1225, R 336.1702(a))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 92 of 116 

71,999 lbs/year / (Actual Formaldehyde emission rate + Actual Methanol emission rate) = maximum hours of 

operation 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate EUELECTROLESSCU unless the packed bed scrubber with mist eliminators is 

installed, maintained, and operated in a satisfactory manner.2

 (R 336.1225, R 336.1702(a), R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 48 months from January 17, 2006 and within every 48 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify formaldehyde and methanol emission rates from 

EUELECTROLESSCU by testing at owner's expense, in accordance with Department requirements. No less 

than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD. The AQD must 

approve the final plan prior to testing. Verification of emission rates includes the submittal of a complete report 

of the test results to the AQD within 60 days following the last date of the test. (R 336.2001, R 336.2003, 

R 336.2004 R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor the 

pressure drop across the packed bed scrubber. 2 (R 336.1225, R 336.1702(a), R 336.1910)

2. The permittee shall monitor and record the hours of operation for EUELECTORLESSCU. 2

 (R 336.1205, 

R 336.1225, R 336.1702(a))

3. The permittee shall keep, in a satisfactory manner, records of the hours of operation of EUELECTROLESSCU, 

on a 12-month rolling time period basis, as determined at the end of each calendar month. 2

 (R 336.1205, 

R 336.1225, R 336.1702, R 336.1910)

4. The permittee shall calculate, in a satisfactory manner, the monthly and 12-month rolling time period VOC 

emission rate from EUELECTROLESSCU. 2

 (R 336.1205, R 336.1225, R 336.1702(a))

5. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 93 of 116 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-4 461 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 94 of 116 

D. FLEXIBLE GROUP CONDITIONS 

Part D outlines terms and conditions that apply to more than one emission unit. The permittee is subject to the 

special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and 

conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no special conditions that apply to more than one emission unit, this section will be left blank. 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions. 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FGCHROME1 This group consists of 3 chrome etch tanks, a chrome 

conversion unit, and a chrome recovery unit controlled 

by a common composite mesh pad scrubber. 

EUCHROMEETCH1, 

EUCHROMEETCH2, 

EUCHROMEETCH3 

FGNEUTCATACC This group consists of the neutralizer, catalyst, and 

accelerator process tanks exhausted from a common 

stack, no emission controls. 

EUNEUTRALIZER, 

EUCATALYST, 

EUACCELERATOR 

FGCOPPER This group consists of the copper electroplating tanks 

which are exhausted by a common stack, no emission 

controls. 

EUCOPPERSTRIKE, 

EUACIDCOPPER1, 

EUACIDCOPPER2, 

EUACIDCOPPER3, 

EUACIDCOPPER4, 

EUACIDCOPPER5 

FGSEMINICKEL This group consists of 5 semi-brite nickel electroplating 

tanks which are exhausted by a common stack, no 

emission controls. 

EUSEMIBRINI1, 

EUSEMIBRINI2, 

EUSEMIBRINI3, 

EUSEMIBRINI4, 

EUSEMIBRINI5 

FGBRIMICRONI This group consists of the brite and micro-porous 

electroplating tanks which are exhausted by a common 

stack, no emission controls 

EUBRINICKEL1, 

EUBRINICKEL2, 

EUMICRONI 

FGCHROME2 This group consists of the decorative chrome plating 

tanks and a chrome recovery unit controlled by a 

composite mesh pad and fume suppressant control. 

EUCHROME1, 

EUCHROME2, 

EUCHROME3 

FGSTRIPTANKS This group consists of the chrome strip and nitric acid 

strip tanks controlled by a packed bed scrubber with a 

mist eliminator. 

EUCHROMESTRIP, 

EUNITRICSTRIP 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 95 of 116 

FGCHROME1 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of 3 chrome etch tanks, a chrome conversion unit, and a chrome recovery unit controlled by a 

common composite mesh pad scrubber. 

Emission Unit: EUCHROMEETCH1, EUCHROMEETCH2, EUCHROMEETCH3 

POLLUTION CONTROL EQUIPMENT

Composite mesh pad scrubber 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Total 

Chromium 

0.012 

milligram per 

dry standard 

cubic meter, 

corrected to 

70°F and 

29.92 inches 

Hg2

Test method FGCHROME1 SC V.1, VI.1, & 

VI.2 

R 336.1225 

2. Total 

Chromium 

0.0025 pph2 Test method FGCHROME1 SC V.1, VI.1, & 

VI.2 

R 336.1225 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate FGCHROME1 unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the composite mesh pad scrubber system 

and the monitoring equipment required to record the pressure drop across the composite mesh pad system. 2

(R 336.1224, R 336.1225, R 336.1910)
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 96 of 116 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate FGCHROME1 unless the composite mesh pad scrubber system is installed, 

maintained, and operated in a satisfactory manner. 2

 (R 336.1224, R 336.1225, R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 30 months from January 17, 2006 and within every 30 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify chromium emission rates from FGCHROME1 by testing at 

owner's expense, in accordance with Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the pressure drop across the composite mesh pad scrubber system on a daily basis. 2 (R 336.1224, 

R 336.1225, R 336.1910)

2. The permittee shall keep records of daily pressure drop readings. 2 (R 336.1224, R 336.1225, R 336.1213(3))

3. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-2 521 601 R 336.1225 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 97 of 116 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 98 of 116 

FGNEUTCATACC 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the neutralizer, catalyst, and accelerator process tanks exhausted from a common stack, no 

emission controls. 

Emission Unit: EUNEUTRALIZER, EUCATALYST, EUACCELERATOR 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate FGNEUTCATACC unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the fan and the monitoring equipment 

required to monitor the fan operation. 1 (R 336.1225)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 99 of 116 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-3 421 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 100 of 116 

FGCOPPER 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the copper electroplating tanks which are exhausted by a common stack, no emission 

controls. 

Emission Unit: EUCOPPERSTRIKE, EUACIDCOPPER1, EUACIDCOPPER2, EUACIDCOPPER3, 

EUACIDCOPPER4, EUACIDCOPPER5 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

NA 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall not operate FGCOPPER unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the fan and the monitoring equipment 

required to monitor the fan operation. 1

 (R 336.1225)
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 101 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-5 521 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 102 of 116 

FGSEMINICKEL 

EMISSION UNIT CONDITIONS

DESCRIPTION

This group consists of 5 semi-brite nickel electroplating tanks which are exhausted by a common stack, no 

emission controls. 

Flexible Group ID: EUSEMIBRINI1, EUSEMIBRINI2, EUSEMIBRINI3, EUSEMIBRINI4, EUSEMIBRINI5 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Nickel 0.028 pph1 Test method FGSEMINICKEL GC 13, SC V.1 R 336.1225 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall not operate FGSEMINICKEL unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the fan and the monitoring equipment 

required to monitor the fan operation. 1

 (R 336.1225)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 48 months from January 17, 2006 and within every 48 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify nickel emission rates from FGSEMINICKEL by testing at 

owner's expense, in accordance with Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 

60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 103 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-6 521 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 104 of 116 

FGBRIMICRONI 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION

This group consists of the brite and micro-porous electroplating tanks which are exhausted by a common stack, no 

emission controls 

Emission Unit: EUBRINICKEL1, EUBRINICKEL2, EUMICRONI 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Nickel 0.017 pph1 Test method FGBRIMICRONI GC 13, SC V.1 R 336.1225 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall not operate FGBRIMICRONI unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the fan and the monitoring equipment 

required to monitor the fan operation. 1 (R 336.1225)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 48 months from January 17, 2006 and within every 48 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify nickel emission rates from FGSEMINICKEL by testing at 

owner's expense, in accordance with Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 

60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 105 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records in accordance with the approved operation and maintenance plan.

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-7 421 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
 Section 2 – Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 106 of 116 

FGCHROME2 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the decorative chrome plating tanks and a chrome recovery unit controlled by a composite 

mesh pad and fume suppressant control subject to the Chromium Electroplating NESHAP. 

Emission Unit: EUCHROME1, EUCHROME2, EUCHROME3 

POLLUTION CONTROL EQUIPMENT

Composite mesh pad scrubber and fume suppressant for control.

I. EMISSION LIMIT(S

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

1. Total 

chromium 

0.005 

milligram per 

dry standard 

cubic meter, 

corrected to 

70°F and 

29.92 inches 

Hg 2

Test Method FGCHROME2 SC V.1, VI.1, 

VI.2, VI.3, VI.4, 

VI.5, VI.6, & 

VI.7 

R 336.1225, 

R 336.1941, 

40 CFR Part 

63 Subparts A 

& N 

2. Total 

chromium 

0.0006 pph1 Test Method FGCHROME2 SC V.1, VI.4, 

VI.5, VI.6, & 

VI.7 

R 336.1225 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall not operate FGCHROME2 unless the chemical fume suppressant is applied in quantities 

and at a frequency to ensure the surface tension of each tank in FGCHROME2 does not exceed 45 dynes/cm 

(3.1x10-3 pound-force per foot) at any time during operation. 2

 (R 336.1225, R 336.1910)

2. The permittee shall maintain and implement the approved operation and maintenance plan. The plan shall 

contain all information required by 40 CFR 63.342(f)(3)(i), which includes the following: 2 (R 336.1225, 

R 336.1910, R 336.1941, 40 CFR 63.342(f)(3)(i))
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 107 of 116 

a. Operation and maintenance criteria for FGCHROME2, add-on control device(s), and for the process and 

control device(s) monitoring equipment as well as a standardized checklist to document the operation and 

maintenance of the equipment; 

b. The work practice standards for the add-on control device(s) and monitoring equipment; 

c. Procedures to be followed to ensure that equipment or process malfunctions due to poor maintenance or 

other preventable conditions do not occur; and 

d. A systematic procedure for identifying process equipment, add-on control device(s) and monitoring 

equipment malfunctions and for implementing corrective actions to address such malfunctions. 

3. If actions taken by the permittee during periods of malfunction are inconsistent with the procedures specified in 

the Preventative Maintenance/Operation and maintenance/Malfunction Abatement Plan, the permittee shall 

record the actions taken for that event and shall report by phone such actions within 2 working days after 

commencing actions inconsistent with the plan. This report shall be followed by a letter within 7 working days 

after the end of the event. (R 336.1941, 40 CFR 63.342(f)(3)(E)(iv))

4. If the operation and maintenance plan fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction at the time the plan is initially developed, the owner or operator shall revise the 

operation and maintenance plan within 45 days after such an event occurs. The revised plan shall include 

procedures for operating and maintaining the process equipment, or monitoring equipment during similar 

malfunction events, and a program for corrective action for such events. (R 336.1941, 40 CFR 63.342(f)(3)(ii))

5. At all times, including periods of startup, shutdown, and malfunction, owners or operators shall operate and 

maintain any affected source, including associated monitoring equipment, in a manner consistent with good air 

pollution control practices, consistent with the operation and maintenance plan. (R 336.1941, 

40 CFR 63.342(f)(1)(i))

6. Malfunction shall be corrected as soon as practical after their occurrence in accordance with the operation and 

maintenance plan. (40 CFR 63.342(f)(1)(i))

See Appendix 2-9 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate FGCHROME2 unless the composite mesh pad scrubber system is installed, 

maintained, and operated in a satisfactory manner. 2 (R 336.1225, R 336.1910, R 336.1941, 40 CFR 63.3424) 

2. The permittee shall equip and maintain the composite mesh pad scrubber system with a differential pressure 

monitoring device. 2 (R 336.1225, R 336.1910, R 336.1941, 40 CFR 63.343(c))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 30 months from January 17, 2006 and within every 30 months from the date of completion of the most 

recent stack test thereafter, the permittee shall verify chromium emission rates from FGCHROME2 by testing at 

owner's expense, in accordance with Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall monitor, in a satisfactory manner, the surface tension of FGCHROME2. 2

 (R 336.1225, 

R 336.1910)
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 108 of 116 

2. The permittee shall perform inspections of the composite mesh pad (CMP) system as follows: 2 (R 336.1225, 

R 336.1910, R 336.1941, 40 CFR 63.342(d) and 63.343(c))

a. Determine pressure drop across the CMP system on a daily basis. If the pressure drop across the control 

varies by more than ±2 inch of water gauge, from the pressure drop determined during compliance testing, 

the variation shall be documented, and the operation and maintenance procedures shall be reviewed. Any 

corrective action shall be documented. 

b. Visually inspect the CMP system, on a quarterly basis, to ensure there is proper drainage, no chromic acid 

build up on the pads, and no evidence of chemical attack on the structural integrity of the control device. 

c. Visually inspect the back portion of the mesh pad closest to the fan, on a quarterly basis, to ensure there is 

no breakthrough of chromic acid mist. 

d. Visually inspect ductwork from tanks to the CMP system, on a quarterly basis, to ensure there are no leaks. 

e. Perform wash-down of composite mesh pads in accordance with manufacturer’s recommendations. 

3. The permittee shall maintain records of inspections required to comply with applicable work practice standards 

of 40 CFR 63.342(f). Each inspection record shall identify the device inspected, the date, approximate time of 

inspection, and a brief description of the working condition of the device during the inspection. The permittee 

shall also record any actions taken to correct the deficiencies found during the inspection.2

 (R 336.1225, 

R 336.1910, R 336.1941, 40 CFR 63.346)

4. The permittee shall keep records of the daily pressure drop. 2

 (R 336.1941, 40 CFR Part 63.343(c)(1))

5. The permittee shall keep records of the surface tension of each tank in FGCHROME2, the amount of chemical 

fume suppressant added to each tank in FGCHROME2 and the date and time of each addition.2

(R 336.1225, R 336.1910)

6. The permittee shall keep records of all maintenance performed on the chrome electroplating process tank(s), 

control device, and monitoring equipment. (R 336.1941, 40 CFR 63.346(b)(2))

7. The permittee shall keep records of the occurrence, duration, and cause (if known) of each malfunction of the 

electroplating process, control device, and monitoring equipment. (R 336.1941, 40 CFR 63.346(b)(3))

8. The permittee shall keep records of actions taken during periods of malfunction when such actions are 

inconsistent with the operation and maintenance plan. (R 336.1941, 40 CFR 63.346(b)(4))

9. The permittee shall keep records of monitoring data that are used to demonstrate compliance with the standard 

for decorative chrome electroplating tank(s), including the date and time the data are collected. (R 336.1941,

40 CFR 63.346(b)(8))

10. The permittee shall record the specific identification (i.e., the date and time of commencement and completion) 

of each period of excess emissions, as indicated by monitoring data, that occurs during malfunction of the 

decorative chrome electroplating process or monitoring equipment. (R 336.1941, 40 CFR 63.346(b)(9))

11. The permittee shall record the specific identification (i.e., the date and time of commencement and completion) 

of each period of excess emissions, as indicated by monitoring data, that occurs during periods other than 

malfunction of the decorative chrome electroplating process or monitoring equipment. (40 CFR 63.346(b)(10))

12. The permittee shall record the total decorative chrome electroplating tank(s) operating time. (R 336.1941, 

40 CFR 63.346(b)(11)) 

13. The permittee shall perform all applicable monitoring and recordkeeping as outlined in 40 CFR 63.343 and 

63.346 for each decorative chrome electroplating tank at the facility. (R 336.1941, 40 CFR 63.343 and 63.346)
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 109 of 116 

14. The permittee shall monitor emissions and operating and maintenance information in accordance with the 

National Emission Standards for Hazardous Air Pollutants as specified in 40 CFR Part 63 Subparts A and N. 2 

(R 336.1941, 40 CFR Part 63 Subparts A & N)

15. The permittee shall keep records of emission information and operating and maintenance information to comply 

with the National Emission Standards for Hazardous Air Pollutants as specified in 40 CFR Part 63 Subparts A 

and N.2

 (R 336.1941, 40 CFR Part 63 Subparts A & N)

See Appendix 2-9 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

4. The permittee shall submit the following notifications to the Department in accordance with 40 CFR 63.347: 

(R 336.1941, 40 CFR 40 CFR 63.347)

a. A notification of the date when construction was commenced, submitted no later than 30 calendar days 

after such date. 

b. A notification of the actual date of startup of the source, submitted within 30 calendar days after such date. 

c. Notification of compliance status. 

5. The permittee shall submit to the AQD a report of ongoing compliance status containing information required in 

63.347(g)(3). This report shall be submitted semi-annually if no exceedances occurred during the reporting 

period and quarterly if exceedances occurred in the reporting period. (R 336.1941, 40 CFR 63.347(g))

6. The permittee shall perform all applicable reporting as outlined in 40 CFR 63.347. (R 336.1941, 

40 CFR 63.347)

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-8 461 601 R 336.1225 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 110 of 116 

IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous Air 

Pollutants as specified in 40 CFR Part 63 Subparts A and N.2

 (R 336.1941, 40 CFR Part 63 Subparts A & N)

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 111 of 116 

FGSTRIPTANKS 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the chrome strip and nitric acid strip tanks controlled by a packed bed scrubber with a mist 

eliminator. 

Emission Unit: EUCHROMESTRIP, EUNITRICSTRIP 

POLLUTION CONTROL EQUIPMENT

Packed bed scrubber with mist eliminator 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ 

Operating Scenario 

Equipment Monitoring/ 

Testing 

Method 

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall not operate FGSTRIPTANKS unless the approved operation and maintenance plan, or an 

alternate plan approved by the AQD District Supervisor, is implemented and maintained. The plan shall include 

procedures for maintaining and operating in a satisfactory manner, the packed bed scrubber with mist 

eliminators and the monitoring equipment required to record the pressure drop across the packed bed 

scrubber. 2 (R 336.1224, R 336.1225, R 336.1910)

See Appendix 2-9

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall not operate FGSTRIPTANKS unless the packed bed scrubber with mist eliminators is 

installed, maintained, and operated in a satisfactory manner. 2 (R 336.1224, R 336.1225, R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 112 of 116 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor the 

pressure drop across the packed bed scrubber. 2

 (R 336.1224, R 336.1225, R 336.1910)

2. The permittee shall maintain records in accordance with the approved operation and maintenance plan. 

(R 336.1213(3))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c)) 

See Appendix 2-8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SVK-9 461 601 R 336.1225 

IX. OTHER REQUIREMENT(S)

NA 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 113 of 116 

E. NON-APPLICABLE REQUIREMENTS 

At the time of ROP issuance, the AQD has determined that no non-applicable requirements have been identified for 

incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to Rule 

213(6)(a)(ii). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 114 of 116 

APPENDICES

Appendix 2-1: Abbreviations & Acronyms 

The following is an alphabetical listing of abbreviations/acronyms that may be used in this permit. 

AQD Air Quality Division MM Million 

Acfm Actual cubic feet per minute MSDS Material Safety Data Sheet 

BACT Best Available Control Technology MW Megawatts 

BTU British Thermal Unit NA Not Applicable 

°C Degrees Celsius NAAQS National Ambient Air Quality Standards 

CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air 

Pollutants 

CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds 

CEM Continuous Emission Monitoring NOx Oxides of Nitrogen 

CFR Code of Federal Regulations NSPS New Source Performance Standards 

CO Carbon Monoxide NSR New Source Review 

COM Continuous Opacity Monitoring PM Particulate Matter 

department Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns in 

diameter 

Dscf Dry standard cubic foot pph Pound per hour 

Dscm Dry standard cubic meter ppm Parts per million 

EPA United States Environmental Protection Agency ppmv Parts per million by volume 

EU Emission Unit ppmw Parts per million by weight 

°F Degrees Fahrenheit PS Performance Specification 

FG Flexible Group PSD Prevention of Significant Deterioration 

GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute 

gr Grains psig Pounds per square inch gauge 

HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure 

Hg Mercury PTI Permit to Install 

hr Hour RACT Reasonable Available Control Technology 

HP Horsepower ROP Renewable Operating Permit 

H2S Hydrogen Sulfide SC Special Condition 

HVLP High Volume Low Pressure * scf Standard cubic feet 

ID Identification (Number) sec Seconds 

IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction 

ITSL Initial Threshold Screening Level SO2 Sulfur Dioxide 

LAER Lowest Achievable Emission Rate SRN State Registration Number 

lb Pound TAC Toxic Air Contaminant 

m Meter Temp Temperature 

MACT Maximum Achievable Control Technology THC Total Hydrocarbons 

MAERS Michigan Air Emissions Reporting System tpy Tons per year 

MAP Malfunction Abatement Plan μg Microgram 

MDEQ Michigan Department of Environmental Quality VE Visible Emissions 

mg Milligram VOC Volatile Organic Compounds 

mm Millimeter yr Year 

*For HVLP applicators, the pressure measured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig). 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 115 of 116 

Appendix 2-2. Schedule of Compliance 

The permittee certified in the ROP application that this stationary source is in compliance with all applicable 

requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of 

Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii)) 

Appendix 2-3. Monitoring Requirements 

Specific monitoring requirement procedures, methods or specifications are detailed in Part A or the appropriate 

Source-wide, emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 2-4. Recordkeeping 

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate Source-wide, 

emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 2-5. Testing Procedures 

Specific testing requirement plans, procedures, and averaging times are detailed in the appropriate Source-wide, 

emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 2-6. Permits to Install 

The following table lists any Permits to Install issued since the effective date of previously issued ROP No. 

199600144. 

Permit to Install 

Number Description of Equipment 

Corresponding 

Emission Unit(s) or 

Flexible Group(s) 

182-04A Chrome Plating Line FGCHROME1, 

FGNEUTCATACC 

FGCOPPER 

FGSEMINICKEL 

FGBRIMICRONI 

FGCHROME2 

FGSTRIPTANKS 

Appendix 2-7. Emission Calculations 

Specific emission calculations to be used with monitoring, testing or recordkeeping data are detailed in the 

appropriate Source-wide, Emission Unit and/or Flexible group Special Conditions. Therefore, this appendix is not 

applicable. 
Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 

 Expiration Date: April 30, 2012 

 PTI No: MI-PTI-N2079-2007 

Page 116 of 116 

Appendix 2-8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting section of 

the Source-wide, emission unit and/or flexible group special conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Specific reporting requirement formats and procedures are detailed in Part A or the appropriate Source-wide, 

emission unit and/or flexible group special conditions. Therefore, Part B of this appendix is not applicable. 

Appendix 2-9. Operation and Maintenance Plan 

Permittee shall develop and implement an Operation and Maintenance Plan for the facility. At a minimum this plan 

shall address the preventative maintenance of the plating lines and associated capture and control systems. 

Approvable plans and any modifications shall be submitted to the AQD District Supervisor prior to the issuance of 

this permit. Any modifications and subsequent changes to the plan by the Company shall be promptly submitted to 

the AQD Grand Rapids District Supervisor.