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 52 nd 

### 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 SupervisorROP 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 – 52 nd 

### Street Paint East; 52 nd 

### Street Paint West; 52 nd 

### 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...............................................................................................6 7

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 ................................................................................................................. ........................70ROP 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................................................................................................... .............115ROP 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 ................................................................................... .116ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

PTI No: MI-PTI-N2079-2007

Page 5 of 116 

## AUTHORITY AND EN FORCEABILITY

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 condi tions 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 requirem ents 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 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

PTI No: MI-PTI-N2079-2007

Page 6 of 116 

## Section 1 – 52 nd 

## Street Paint East; 52 nd 

## Street Paint West; 52 nd 

## Street Mold;

and Barden Distribution

## Section 1 – 52 nd 

## 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 en forceable and state enforceab le unless otherwise noted. (R 336.1213(5))

• Those conditions that are hereby incorporated in a stat e-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 fede rally enforceable Source-wi de 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 Envi ronmental 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 co nditions of this ROP that are designated as federally enforceable are enforceable by the Admi nistrator of the United States En vironmental 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 desi gnated as “state only” are not en forceable 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 enforc ement action that it would hav e 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 notificat ion of planned changes or anticipated noncompliance does not stay any ROP term or condition. This does not su persede 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 aut horized representative of th e 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 emi ssions-related activity is

conducted or where records must be ke pt 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 compli ance with the ROP or applicable requirements.

## Section 1 – 52 nd 

## 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 wa y 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 f ee schedule and requirements pursuant to Section 5522 of

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

8. This ROP does not convey any prope rty 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 sha ll be performed in a manner so as to

minimize the introduction of contaminants to the outer ai r. Transport of collected ai r 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 pr ocess equipment a visible emission of a density greater than the most stringent of Rule 301(1)(a) or (b) unless otherwise specif ied 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 on e 6-minute average per hour of not more than 27% opacity. b. A limit specified by an applicable feder al new source performance standard.

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

alone or in reaction with other air co ntaminants, 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 comf ortable 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 expens e, 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 – 52 nd 

## 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 Ai r Quality Division (AQD) in the format prescribed by the applicable reference test method within 60 day s 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 me thod 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 para meters 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, me asurement, 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 certific ation 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 certif y 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 t he appropriate District Office of the AQD pursuant to Rule 213(3)(c). This certification shall include all the information specif ied in Rule 213(4)(c)(i) throug h (v) and shall state that,

based on information and belief formed after reasonabl e inquiry, the statements and information in the certification are true, accurate, and complete. The E PA address is: US EPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Ja ckson Boulevard, Chicago, IL, 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annua lly 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 defi ned in Rule 213(3)(c)(ii) as follows, unless otherwise

described in this ROP (R 336.1213(3)(c)) : a. For deviations that exceed t he emissions allowed under the ROP, prompt reporting means reporting consistent with the requirements of Rule 912 as detail ed in Condition 25. All reports submitted pursuant to this paragraph shall be promptly certif ied as specified in Rule 213(3)(c)(iii).

b. For deviations which exceed the emissions allow ed 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 exc eed the emissions allowed under the RO P, prompt reporting means the reporting of all deviations in the semiannual reports requi red by Rule 213(3)(c)(i). The report shall describe

the reasons for each deviation and the actions ta ken to minimize or correct each deviation.

## Section 1 – 52 nd 

## 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 ei ther of the following (R 336.1213(3)(c)) : a. Submitting a certification by a resp onsible 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 cale ndar 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 certif ication by a responsible official which states that, based on information and belief formed after reasonable inquiry, the statements and info rmation contained in each of the reports submitted during the previous month were true, accurate, and comple te. The certification sha ll include a listing of the reports that are being certif ied. 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 certificati on 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 fr equently if specified, the permittee shall submit certified reports of any required monitoring to the approp riate 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 regulat ed air pollutant as defined in Rule 212(6) for each emi ssion unit utilizing the emissions inventory form s provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdo wn, or malfunction that results in emissions of a hazardous or toxic air pollutant which cont inue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contami nant continuing for more than two hours in excess of an applicable standard or limitation, as requir ed 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 s hall be by any reasonable means, includ ing 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 di scovery of the abnormal c onditions 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 su mmary 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 ha ve been identified as non-applicable to this ROP and are included in the permit shield.

## Section 1 – 52 nd 

## 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 alte r or affect any of the following: a. The provisions of Section 303 of the CAA, emer gency 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 fo r 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 prog ram, consistent with Sect ion 408(a) of the CAA. (R 336.1213(6)(b)(iii)) d. The ability of the EPA to obtain information from a source purs uant to Section 114 of the CAA. (R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incor porated 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 Ru le 216(1)(a)(v) until the am endment 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 cove red 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 ap plication 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 t he 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 co mply 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 – 52 nd 

## 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 stati onary 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 appl ication 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 servic es, maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of app liances containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaime r, 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) v ehicles when this service involves refrigerant in the MVAC, t he permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Ai r Conditioners. The term “motor vehicle” as used in Subpart B does not include a vehicle in which final as sembly of the vehicle has not been completed by the original equipment manufacturer. The term MVAC as us ed 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 re ducing 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 provisio ns under Section 112(r)(1).

## Section 1 – 52 nd 

## 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 pr esent 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 regulato ry agency necessary to ensure comp liance 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 redu ction credit trading are allowed pursua nt to any applicable interstate or regional emission trading program t hat has been approved by the Administ rator of the EPA as a part of Michigan’s State Implementation Plan. Such activi ties must comply with Rule 215 and Rule 216. (R 336.1213(12))



### Permit To Install (PTI)

43. The process or proc ess equipment included in this permit shall not be reconstructed, relocated, or modified unless a PTI authorizing such action is issued by the depa rtment, except to the ext ent 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 perfor ming 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. T he 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 sh all become void unless otherwise authorized by the department. Furthermore, the person to whom that PT I 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, reconstructi on, 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 – 52 nd 

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Page 14 of 116 

## B. SOURCE-WIDE CONDITIONS

Part B outlines the Source-wide terms and conditions that appl y to this stationary source. The permittee is subject to these special conditions for the stationary source in addi tion 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 appl y to this source, NA (not applicable) has been used in

the table. If there are no Source-wide c onditions, this section will be left blank.

## Section 1 – 52 nd 

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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/OPERATIO NAL 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 stationar y 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 – 52 nd 

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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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 – 52 nd 

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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 appl y, NA (not applicable) has been used in the table. If there are no conditions specific to individual em ission 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 – 52 nd 

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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 loca ted 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 cons ists 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 cons ists 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 – 52 nd 

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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 cons ists 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 cons ists 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 cons ists 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 cons ists 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 cons ists 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 – 52 nd 

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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 cons ists 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 t he paint mixing room. 07/07/1994 FGWESTSOLVENT

## Section 1 – 52 nd 

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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 – 52 nd 

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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/OPERATIO NAL 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 coati ng, 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 – 52 nd 

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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 fo rmat acceptable to the AQD District Supervisor and made available by the 15th day of the calend ar 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 m anufacturer 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 t he 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 inform ation 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 mont hly 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 mont hly 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. 29-2 006, Paragraph 11)

See Appendix 1-4



### VII. REPORTING

1. Prompt reporting of deviations pursuant to Ge neral 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 – 52 nd 

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Page 24 of 116 3. Annual certification of compliance pursuant to Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 52 2 80.0 2 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 – 52 nd 

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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/OPERATIO NAL 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 coati ng, 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 – 52 nd 

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### 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 fo rmat acceptable to the AQD District Supervisor and made available by the 15th day of the calend ar 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 m anufacturer 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 t he 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 info rmation on a monthly bas is 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 mont hly 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 App endix 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 mont hly 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. 29-2 006, Paragraph 11)

See Appendix 1-4



### VII. REPORTING

1. Prompt reporting of deviations pursuant to Ge neral 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 – 52 nd 

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Page 27 of 116 3. Annual certification of compliance pursuant to Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 52 2 80.0 2 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 – 52 nd 

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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/OPERATIO NAL 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 coati ng, 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)

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### 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 fo rmat acceptable to the AQD District Supervisor and made available by the 15th day of the calend ar 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 chem ical 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 inform ation 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 m onthly 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 informatio n 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 ga llon, of each solvent used. c. VOC mass emission calculations determining the m onthly 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 form at specified in Appendix 4.C or an alte rnate 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 Ge neral 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)

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Page 30 of 116 3. Annual certification of compliance pursuant to Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 52 2 80.0 2 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).

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## 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 appl y, 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 di rectly 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 52 nd Paint West facility. The spray emis sions 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

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Page 32 of 116 Flexible Group ID Flexible Group Description Associated

Emission Unit IDs

FGWESTMANUAL This group consis ts of 11 hand spray booths and one paint dry oven located at the 52 nd Paint West facility. EUWESTMANUAL1

EUWESTMANUAL2

EUWESTMANUAL3

EUWESTMANUAL4

EUWESTMANUAL5

EUWESTMANUAL6

EUWESTMANUAL7

EUWESTMANUAL8

EUWESTMANUAL9

EUWESTMANUAL10

EUWESTMANUAL11

EUWESTMANOVEN

FGWESTMISCSOLVENT This group consist of miscellaneous usage at 52 nd
Street Paint West for purge and cleanup operations. EUWESTPURGE

EUWESTMASKWASH

EUWESTSTRIPTANK

EUWESTCLEANUP

FGSUBPARTPPPP Each new, reconstr ucted, 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 storag e 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 t hat 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

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## 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 po rtion of the line consists of two robotic booths (EUPRIMEROBOT1 & EUPRIMEROBOT2), one manual boot h (EUPRIMEMANUAL), and a flashoff area. The basecoat portion of the line consists of fo ur 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 a ll of the robotic booths are captured and controlled by a regenerative thermal oxidizer (RTO). Emissions from each of the manual booths and t he 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, EUPRIMEROBOT 2, 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

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### 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/OPERATIO NAL RESTRICTION(S)

1. All waste coatings, reducers, and solvents shall be ca ptured and stored in closed containers and shall be disposed of in an acceptable manner in complia nce 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 jeopar dized 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 ex haust system has been compromised. e. The RTO does not meet the permitted dest ruction 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 exce edance, 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 port ion 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 boo th portion of FGEASTPAINT unless the thermal oxidizer is installed, maintained and operated in a satisfactory manne r. 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 te mperature 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 main tain all basecoat and clearcoat spray booth portions of FGEASTPAINT with electrostatic applicators or equivalent technol ogy 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 electrosta tic applicator portions of FGEASTPAINT with a device to prevent electric current from being sh ut off except by authorized personnel. 2 (R 336.1220, R 336.1702; Consent Order No. 29-2006, Paragraph 10)

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### 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 veri fy the destruction efficiency of the regenerative thermal oxidizer, by testin g at owner's expense, in accordance with Department requirements. Not less than 60 days prior to testing, the permittee shall sub mit a complete test plan to the AQD. The AQD must approve the final plan prior to testing. Verification of emi ssion 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 pe rmittee shall submit a notice of the ant icipated 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 testi ng. All test methods, plans, and procedures shall be approved by the AQD prior to testing. After two consecutiv e tests demonstrate that the direction of air flow at all NDOs is into the booths, the permittee may reque st 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 coati ng, 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 remaini ng 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 char t 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 validat ed 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 dat a, 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))

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Page 36 of 116 6. The permittee shall maintain a current listing from the m anufacturer 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 t he 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 info rmation 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 det ermining 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 App endix 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 336.170 2, R 336.1901; Consent Order No. 29-2006, Paragraph 11)

8. The permittee shall keep the following info rmation 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 m onthly emission rate in tons per calendar month. d. Hours of operation.

The records shall be kept in the format specified in App endix 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 336.170 2, 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 gall on, of each solvent used. c. VOC mass emission calculations determining the annu al 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 gall on, of each solvent used. c. VOC mass emission calculations determining the m onthly 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)

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Page 37 of 116 11. All required calculations shall be completed in a fo rmat acceptable to the AQD District Supervisor and made available by the 15th day of the calend ar 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 ex ternal 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 exceedance s 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 o ffice 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 stat ement 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 we re no periods of monitor downtime in the reporting period, then this report shall include a statem ent 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 do cumentation 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 purs uant 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 Marc h 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

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### 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 52 2 80.0 2 R 336.1225, R 336.1901, 40 CFR 52.21(c) & (d); Consent Order No. 29-2006, Paragraph 10

2. SV-EASTBASE 52 2 80.0 2 R 336.1225, R 336.1901, 40 CFR 52.21(c) & (d); Consent Order No. 29-2006, Paragraph 10

3. SV-EASTCLEAR 52 2 80.0 2 R 336.1225, R 336.1901, 40 CFR 52.21(c) & (d); Consent Order No. 29-2006, Paragraph 10

4. SV-REGENINCIN5 48 2 45.0 2 R 336.1225, R 336.1901, 40 CFR 52.21(c) & (d); Consent Order No. 29-2006, Paragraph 10

5. SV-EASTBASECLROVEN 36 2 45.0 2 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 m onitoring 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 malfunction s, associated repairs, and required quality assurance or control activities, the permittee shall conduct all moni toring 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 an d operate FGEASTPAINT according to th e 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).

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## 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, EUWEST ROBOT6, EUWESTROBO T7, EUWESTROBOT8,

EUWESTRBTOVEN



### POLLUTION CONTROL EQUIPMENT

Regenerative Thermal Ox idizer, 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 – 52 nd 

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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/OPERATIO NAL 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 t he eight automatic resist coat spray boot hs 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 ma intaining 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 jeopar dized 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 ex haust system has been compromised. e. The RTO does not meet the permitted dest ruction 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 FGWESTROBO PAINT including the control device and capture system to normal or usual manner of operation as quickly as po ssible in response to an exceedance or excursion. (40 CFR 64.7(d))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA

## Section 1 – 52 nd 

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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 testi ng 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 e mission 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 sha ll 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 pe rmittee shall submit a notice of the ant icipated 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 testi ng. All test methods, plans, and procedures shall be approved by the AQD prior to testing. After two consecutiv e tests demonstrate that the direction of air flow at all NDOs is into the booths, the permittee may reque st 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 thereafte r, the permittee shall veri fy 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 form ulation values should diff er, 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 coati ng (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 t he 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 ma ss 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 char t 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 – 52 nd 

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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 validat ed 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 dat a, 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 st ructural 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 exceedance s 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 o ffice 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 stat ement 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 we re no periods of monitor downtime in the reporting period, then this report shall include a statem ent 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 do cumentation 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 purs uant 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 Marc h 15 for the previous calendar year. (R 336.1213(4)(c), 40 CFR 64.9)

See Appendix 1-8

## Section 1 – 52 nd 

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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 42 2 51 2 R 336.1201(3)

2. SV-OVENWRESIST 14 2 51 2 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 m onitoring 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 malfunction s, associated repairs, and required quality assurance or control activities, the permittee shall conduct all moni toring 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 FGWESTRO BOPAINT according to the procedures outlined in the approved Operation and Maintenance Plan, or an alternate plan approved by t he 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 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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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, EU WESTMANUAL7, 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 day 2 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

month 2 As determined at

the end of each

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

3. VOC 132.2 tons per

year 2 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 applied 2 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 – 52 nd 

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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 applied 2 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/OPERATIO NAL 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 man ual spray booths unless the dry filters are installed and operating properly. 2 (R 336.1910)

4. Permittee shall dispose of spent f ilters in a manner that minimizes the in troduction of air contaminants to the

outer air. 2 (R 336.1910)



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA

## Section 1 – 52 nd 

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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 remaini ng 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. ai r-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 reduce rs and catalysts and the amounts in gallons applied based upon a 24- hour averaging period and determin ed at the end of each 24-hour production day.

b. Average VOC emission calculations determining t he uncontrolled pounds per gallon of coating, minus water, as applied for air-dried red/black coatings and air-dried non red/black coat ings each calendar day. 2
(R 336.1220(1)(a))

c. VOC emission calculations determining the VOC ma ss 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 1-8

## Section 1 – 52 nd 

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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 24 2 51 2 R 336.1201(3)

2. SV-MANBOOTHM2 24 2 51 2 R 336.1201(3)

3. SV-MANBOOTHM3 24 2 51 2 R 336.1201(3)

4. SV-MANBOOTHM4 24 2 51 2 R 336.1201(3)

5. SV-MANBOOTHM5 24 2 51 2 R 336.1201(3)

6. SV-MANBOOTHM6 24 2 51 2 R 336.1201(3)

7. SV-MANBOOTHM7 24 2 51 2 R 336.1201(3)

8. SV-MANBOOTHM8 24 2 51 2 R 336.1201(3)

9. SV-MANBOOTHM9 24 2 51 2 R 336.1201(3)

10. SV-MANBOOTHM10 24 2 51 2 R 336.1201(3)

11. SV-MANBOOTHM11 24 2 51 2 R 336.1201(3)

12. SV-WTOPCOATOVE 16 2 51 2 R 336.1201(3)



### IX. OTHER REQUIREMENT(S)

1. The permittee shall maintain and operate FGWEST MANUAL according to the procedures outlined in the approved Operation and Maintenance Plan, or an alternate plan approved by t he 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 – 52 nd 

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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, EUW ESTMASKWASH, 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/hr 2 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/year 2 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/hr 2 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/year 2 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 – 52 nd 

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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/hr 2 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/year 2 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/hr 2 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/year 2 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/OPERATIO NAL 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 so lvents, mask washing solvent s, stripping solvents and cleanup solvents shall be captured and stored in closed containers and be dispos ed of in an acceptable manner which minimizes the

introduction of air contaminants to the outer air. 2 (R 336.1910)

## Section 1 – 52 nd 

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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 Met hod 24. Upon prior approval by the AQD District Supervisor, the VOC content may be determined from manuf acturer’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 conten t, in pounds per gallon, of each solvent used. 2 (R 336.1220(1)(a)) c. VOC mass emission calculations determining the a nnual 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 hour ly 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 1-8

## Section 1 – 52 nd 

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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 13 2 34 2 R 336.1201(3)

2. SV-WESTPAINTKITCHEN 37 2 34 2 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 – 52 nd 

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Page 52 of 116 

## FGSUBPART PPPP

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Each new, reconstructed, and existing affected source engag ed in the surface coating of plastic parts and products,

identified within each of the four subcat egories 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 associ ated activities, such as surf ace preparation, cleaning, mixing, and storage if they are directly re lated to the application of the coating.

Flexible Group: FGEASTPAINT, FGWESTROBOPAINT, FG WESTMANUAL, 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 em ission 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 a nd/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 wi thout 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 oper ation(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 alte rnatives in 40 CFR 63.4490(c)(1) or (2). (40 CFR 63.4490(c))

## Section 1 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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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/OPERATIO NAL 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 i dentified 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 temper ature in any 3-hour period must not fall below the combustion temperature limit establis hed 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 ti mes must be into the enclosure; and either

b. The average facial velocity of air throug h all natural draft openings in the enclosure must be at least 200 feet per minute; or

c. The pressure drop across the encl osure must be at least 0.007 inch H 2 O, 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 du ct 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 organi c-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 – 52 nd 

## 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 du ring cleaning of storage, mixing, and conveying equipment. (40 CFR 63.4493(b)(5))

The permittee may choose to comply with an alternativ e to the work practice standard, after receiving prior approval from the USEPA in acco rdance with 40 CFR 63.6(g). (40 CFR 63.4493(c))

3. If the affected source uses an emission capture syst em 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, shutdow n 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 conveyor s 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 star tup, 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 opti on, the permittee shall not operate FGEASTPAINT and FGWESTROBOT unless the re generative thermal oxid izers 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 or ganic 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 ac cording to the requirements in 40 CFR 63.7(e)(1) and under the conditions in 40 CFR 63.4564(a)(1) and (2), unles s 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 perf ormance 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 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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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 demons tration 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 12 th
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 thr ough 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 notificati on and report that is submi tted to comply with 40 CFR, Part 63, S ubpart PPPP, and the documentation supporting ea ch notification report. (40 CFR 63.4530(a))

b. A current copy of information provided by material s suppliers or manufacturers, such as manufacturer’s formulation data, or test data used to determine th e mass fraction of organic HAP and density of each coating, thinner and/or other additive, and cleaning ma terial, 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 optio n, the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or additi ves, and cleaning materials used each month using Equations 1, 1A through 1C and 2 of 40 CFR 63.4551; and, if applicable, the calcul ation 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 Equati on 2 of 40 CFR 63.4551; and the calculation of each 12-month organic HAP emission rate us ing 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 materi al 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) throug h (3), if an allowance is used in Equation 1 of 40 CFR 63.4551 for organic HAP contained in waste mate rials sent to or designated for shipment to a treatment, storage, and disposal facility (T SDF) 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, re cords specified in 40 CFR 63.4530(i)(1) through (8). (40 CFR 63.4530(i))

## Section 1 – 52 nd 

## 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 limit s 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 H 2 O, 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 opt ion, 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 operat ions using the emission rate without add-on controls option, the permittee shall demonstrate continuous comp liance 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 requi red by 40 CFR 63.4560, t he 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 – 52 nd 

## 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 Moni toring System (CPMS) according to the requirements of 40 CFR 63.4568(a). If the capture system contains a bypass line, th e permittee shall comply with the requirements of 40 CFR 63.4568(b). (40 CFR 63.4568)

10. The permittee must apply to the U SEPA for approval of alternat ive 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. For the compliant material option, the use of any coati ng, thinner or cleaning material which does not meet the criteria specified in 40 CFR 63.4542(a) is a devia tion 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 th e 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, t he 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-liqui d 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 notificatio ns 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 stat us as specified in 40 CFR

63.4510. (40 CFR, Part 63, Subparts A and PPPP)

8. The permittee shall submit all semiannual compli ance reports as required by 40 CFR 63.4520. Each semiannual compliance report shall identify which coati ng operation(s) used each compliance option, and if

there were no deviations from the emission limitations in 40 CFR 63.4490, include a st atement 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 t he emission rate with add-on controls option, the permittee shall submit all performance test reports for emission ca pture 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 – 52 nd 

## 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 provis ions 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 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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Page 59 of 116 

## FGRULE290

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Any emission unit that emits air contam inants and is exempt from the require ments 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 vo latile organic compounds or noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreci ably to the formation of ozone if the total uncontrolled

or controlled emissions of air contaminants are not mo re than 1,000 or 500 pounds per month, respectively. (R 336.1290(a)(i))

2. Each emission unit that the total uncontrolled or cont rolled 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 contam inants, 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 contam inants, 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 me ter, 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 sc reening levels greater than or equal to 0.04 microgram per cubic meter, the uncontrolled or controlled emis sions 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 contam inants, 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 screeni ng 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 no ncarcinogenic particulate air contaminant s and other air contaminants that are exempted under Rule 290(a)(i) and/or Rule 290(a)(ii), abov e, and all of the following provisions are met: (R 336.1290(a)(iii))

## Section 1 – 52 nd 

## 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 appropria tely designed and operated fabric filter collector or an equivalent control system which is designed to contro l 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 particul ate 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/OPERATIO NAL 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 Perm it 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 em issions 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 em ission 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 parti culate air contaminants pursuant to Rule 290(a)(iii), the permittee shall maintain a written description of the control device, incl uding the designed control efficiency and the designed exhaust gas flow rate. (R 336.1213(3))

## Section 1 – 52 nd 

## 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 particu late air contaminants pursuant to Rule 290(a)(iii), the permittee shall perform a monthly visible emission observ ation 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 – 52 nd 

## Street ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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Page 62 of 116 

## FGRULE287(c)

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Any emission unit that emits air contam inants and is exempt from the require ments 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/OPERATIO NAL 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 approv ed 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 – 52 nd 

## 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 – 52 nd 

## 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, perchloroet hylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride, chloroform, or any combination thereof. (R 336.1213(2))



### III. PROCESS/OPERATIO NAL 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 eac h 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 a nd 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 a ssisted if the Reid vapor pr essure of the solvent is more than 0.3 psia or if the solvent is agitated or heated. (R 336.1707(3)(a))

## Section 1 – 52 nd 

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Page 65 of 116 5. If the Reid vapor pressure of any so lvent used in a new cold cleaner is gr eater 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 rati o 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 wi th 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 adso rption 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, manuf actured 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 procedur es 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 dem onstration that the waste solvent is a safety hazard shall be made prior to storage in non-clos ed containers. If the waste solvent is a safety hazard

and is stored in non-closed c ontainers, verification that t he 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 – 52 nd 

## 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 – 52 nd 

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Page 67 of 116 

## E. NON-APPLICABLE REQUIREMENTS

At the time of ROP issuance, the AQD has determined t hat 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 – 52 nd 

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Page 68 of 116 

## APPENDICES

Appendix 1-1: Abbreviations & Acronyms

The following is an alphabetical listing of abbrevia tions/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 N SPS New Source Performance Standards

CO Carbon Monoxide NSR New Source Review

COM Continuous Opacity Monitoring PM Particulate Matter

department Michigan Department of Environmental Qualit y 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 A gency 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 Preventi on 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

H 2 S 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 SO 2 Sulfur Dioxide

LAER Lowest Achievable Emission Ra te 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 me asured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig).

## Section 1 – 52 nd 

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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 wi th 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 specif ications are the details to the monitoring requirements

identified and referenced in.

The permittee shall develop and implement a Compliance As surance 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 Dist rict 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 S upervisor in accordance with the r equirements 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 t he AQD District Supervisor.Section 1 – 52ndStreetROP No: MI-ROP-N2079-2007Expiration Date: April 30, 2012PTI No: MI-PTI-N2079-2007Page 70 of 116Appendix 1-4.ATotal VOC emissions for single and two component coatingsTIME PERIOD :ApplicatorA B * C D E=(AxB)+(CxD)F = (100-DS)/100COATINGGALLONS OF COATINGRESIN AS APPLIEDLBS OF VOC/GAL OF RESINCOMPONENT ASAPPLIED/MIXEDGAL OFCATALYSTUSEDLBS OF VOCPER GAL OFCATALYSTUSEDLBS OF VOCControl FactorDS=destructioneff. %TOTAL UNCONTROLLED LBS VOC = G = SUM OF ALL E's GLBS CONTROLLED VOC = H = G x F HTons VOC emitted this day = J = H/2000 JTons of VOC's emitted 364 previous days = K KTons of VOC's emitted 365-day rolling period = L = J + K LAt the end of each production day:Hours/day of operation, coating line = M MLBS OF VOC/HOUR = N = H/M NSection 1 – 52ndStreetROP No: MI-ROP-N2079-2007Expiration Date: April 30, 2012PTI No: MI-PTI-N2079-2007Page 71 of 116Appendix 1-4.BVOC content of solvent-based coatings, no-water, with reducersA B C D E F G=(AxB)+(CxD)+(ExF)MIX NAMEBASE RESINDESCRIPTIONBASERESINRATIOLBS OFVOC/GALOF BASERESINSOLVENTDESCRIPTIONSOLVENTRATIOLBS OFVOC/GAL OFSOLVENTCATALYSTDESCRIPTIONCATALYSTRATIOLBS OFVOC PERGAL OFCATALYSTLBS OF VOC/GAL OF MIX ASAPPLIEDPMN Number

## Section 1 – 52 nd 

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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 – 52 nd 

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Page 73 of 116 

### Appendix 1-5. Testing Procedures

There are no specific testing requirement plans or proced ures for this ROP. Therefore, this appendix is not applicable.



### Appendix 1-6. Permits to Install

The following table lists any Permits to Install issued si nce 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 Certificat ion form (EQP 5736) and MDEQ Deviation Report form (EQP 5737) for the annual, semiannual and deviation certificat ion reporting referenced in the Reporting section of the Source-wide, emission unit and/or flexible group spec ial conditions. Alternative formats must meet the provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), res pectively, and be approved by t he AQD District Supervisor.

B. Other Reporting

Specific reporting requirement format s 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 – 52 nd 

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

The permittee shall develop and implement an Operation and Ma intenance Plan for the facility. At a minimum this plan shall address the preventative main tenance of the coating lines and asso ciated capture and c ontrol 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

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Page 75 of 116 

## Section 2 - Barden Plating

## Section 2 - Barden Plating ROP No: MI-ROP-N2079-2007 Expiration Date: April 30, 2012

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Page 76 of 116 

## A. GENERAL CONDITIONS

Permit Enforceability

• All conditions in this permit are both federally en forceable and state enforceab le unless otherwise noted. (R 336.1213(5))

• Those conditions that are hereby incorporated in a stat e-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 fede rally enforceable Source-wi de 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 Envi ronmental 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 co nditions of this ROP that are designated as federally enforceable are enforceable by the Admi nistrator of the United States En vironmental 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 desi gnated as “state only” are not en forceable 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 enforc ement action that it would hav e 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 notificat ion of planned changes or anticipated noncompliance does not stay any ROP term or condition. This does not su persede 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 aut horized representative of th e 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 emi ssions-related activity is

conducted or where records must be ke pt 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 compli ance with the ROP or applicable requirements.

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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 wa y 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 f ee schedule and requirements pursuant to Section 5522 of

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

8. This ROP does not convey any prope rty 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 sha ll be performed in a manner so as to

minimize the introduction of contaminants to the outer ai r. Transport of collected ai r 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 pr ocess equipment a visible emission of a density greater than the most stringent of Rule 301(1)(a) or (b) unless otherwise specif ied 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 on e 6-minute average per hour of not more than 27% opacity. b. A limit specified by an applicable feder al new source performance standard.

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

alone or in reaction with other air co ntaminants, 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 comf ortable 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 expens e, 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 Ai r Quality Division (AQD) in the format prescribed by the applicable reference test method within 60 day s 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 me thod 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 para meters 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, me asurement, 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 certific ation 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 certif y 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 t he appropriate District Office of the AQD pursuant to Rule 213(3)(c). This certification shall include all the information specif ied in Rule 213(4)(c)(i) throug h (v) and shall state that,

based on information and belief formed after reasonabl e inquiry, the statements and information in the certification are true, accurate, and complete. The E PA address is: US EPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Ja ckson Boulevard, Chicago, IL, 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annua lly 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 defi ned in Rule 213(3)(c)(ii) as follows, unless otherwise

described in this ROP (R 336.1213(3)(c)) : a. For deviations that exceed t he emissions allowed under the ROP, prompt reporting means reporting consistent with the requirements of Rule 912 as detail ed in Condition 25. All reports submitted pursuant to this paragraph shall be promptly certif ied as specified in Rule 213(3)(c)(iii).

b. For deviations which exceed the emissions allow ed 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 exc eed the emissions allowed under the RO P, prompt reporting means the reporting of all deviations in the semiannual reports requi red by Rule 213(3)(c)(i). The report shall describe

the reasons for each deviation and the actions ta ken 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 ei ther of the following (R 336.1213(3)(c)) : a. Submitting a certification by a resp onsible 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 cale ndar 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 certif ication 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 comple te. The certification sha ll include a listing of the reports that are being certif ied. 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 certificati on 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 fr equently if specified, the permittee shall submit certified reports of any required monitoring to the approp riate 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 regulat ed air pollutant as defined in Rule 212(6) for each emi ssion unit utilizing the emissions inventory form s provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdo wn, or malfunction that results in emissions of a hazardous or toxic air pollutant which cont inue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contami nant continuing for more than two hours in excess of an applicable standard or limitation, as requir ed 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 s hall be by any reasonable means, includ ing 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 di scovery of the abnormal c onditions 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 su mmary 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 ha ve 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 alte r or affect any of the following: a. The provisions of Section 303 of the CAA, emer gency 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 fo r 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 prog ram, consistent with Sect ion 408(a) of the CAA. (R 336.1213(6)(b)(iii)) d. The ability of the EPA to obtain information from a source purs uant to Section 114 of the CAA. (R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incor porated 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 Ru le 216(1)(a)(v) until the am endment 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 cove red 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 ap plication 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 t he 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 co mply 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))

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### 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 stati onary 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 appl ication 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 servic es, maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of app liances containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaime r, appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall comp ly with all applicable st andards 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) v ehicles when this service involves refrigerant in the MVAC, t he permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Ai r Conditioners. The term “motor vehicle” as used in Subpart B does not include a vehicle in which final as sembly of the vehicle has not been completed by the original equipment manufacturer. The term MVAC as us ed 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 re ducing 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 provisio ns 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 pr esent above a threshold quantity in a process.

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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 regulato ry agency necessary to ensure comp liance 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 redu ction credit trading are allowed pursua nt to any applicable interstate or regional emission trading program t hat has been approved by the Administ rator of the EPA as a part of Michigan’s State Implementation Plan. Such activi ties must comply with Rule 215 and Rule 216. (R 336.1213(12))



### Permit To Install (PTI)

43. The process or proc ess equipment included in this permit shall not be reconstructed, relocated, or modified unless a PTI authorizing such action is issued by the depa rtment, except to the ext ent 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 perfor ming 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. T he 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 sh all become void unless otherwise authorized by the department. Furthermore, the person to whom that PT I 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, reconstructi on, 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).

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## B. SOURCE-WIDE CONDITIONS

Part B outlines the Source-wide terms and conditions that appl y to this stationary source. The permittee is subject to these special conditions for the stationary source in addi tion 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 appl y to this source, NA (not applicable) has been used in

the table. If there are no Source-wide c onditions, this section will be left blank.

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## 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 appl y, NA (not applicable) has been used in the table. If there are no conditions specific to individual em ission 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 hy drochloric acid. 8/22/05 FGNEUTCATACC

EUACCELERATOR Process tank containing hydrochloric acid. 8/22/05 FGNEUTCATACC

EUELECTROLESSNI Electrol ess 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 c ontaining copper sulfate,

ferrous sulfate and sulfuric acid. 8/22/05 FGCOPPER

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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 c ontaining 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 c ontaining copper sulfate,

ferrous sulfate and sulfuric acid. 8/22/05 FGCOPPER

EUACIDCOPPER5 Process tank c ontaining 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

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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 stri p tank controlled by a packed

bed scrubber with mist eliminators. 8/22/05 FGSTRIPTANKS

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## 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 pph 2 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate EUCONDITIONER unle ss the approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict Supervisor, is implemented and maintained. The plan shall include procedures for maintaining and operating in a satisf actory manner, the packed bed scrubber with mist eliminators and the monitoring equipment required to record the pressure dr op 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 unles s 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 ever y 48 months from the date of completion of the most recent stack test thereafter, the permittee shall ve rify 1,3-dichloro-2-propanol emission rates from EUCONDITIONER by testing at owner's expense, in accor dance 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))

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### 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 o perate 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 accordan ce 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 18 1 60 1 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).

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## 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 EUELEC TROLESSNI 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operat e EUELECTROLESSNI unless the approved operation and maintenance plan, or an alternate plan approved by the AQD District Supervi sor, 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 dr op 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 unles s 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 ev ery 48 months from the date of completion of the most recent stack test thereafter, the permittee shall ve rify 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 s ubmit 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

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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 o perate 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 accordan ce 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 46 1 60 1 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).

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## 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 pph 2 Test Method EU ELECTROLESSCU SC V.1 R 336.1225, R 336.1702(a)

2. Methanol 12.2 pph 2 Test Method EU ELECTROLESSCU SC V.1 R 336.1225, R 336.1702(a)

3. VOC Less than 36 tpy 2 12-month rolling time period as

determined at the

end of each

calendar month EUELECTROLESSCU S C 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate EUELECTROLESSCU unl ess the approved operation and maintenance plan, or an alternate plan approved by the AQD District Super visor, 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 dr op 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 unl ess, after testing it is determined that the actual

emission rates of formal dehyde 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))

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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 EU ELECTROLESSCU unless the packed bed sc rubber 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 ev ery 48 months from the date of completion of the most recent stack test thereafter, t he permittee shall verify formaldehyde and methanol emission rates from EUELECTROLESSCU by testing at owner's expense, in accordance with Department require ments. 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 o perate 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 t he 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 det ermined 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 accordan ce 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 2-8

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### 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 46 1 60 1 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).

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## 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 appl y, 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 elec troplating 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

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## 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, EUCHR OMEETCH2, 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 Hg 2 Test method FGCHROME1 SC V.1, VI.1, &

VI.2 R 336.1225

2. Total

Chromium 0.0025 pph 2 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate FGCHROME1 unless t he approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict Supervisor, is implemented and maintained. The plan shall include procedures for maintaining and operating in a satisfac tory manner, the composite mesh pad scrubber system and the monitoring equipment required to record the pr essure drop across the composite mesh pad system. 2
(R 336.1224, R 336.1225, R 336.1910)

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### 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 ever y 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 requirem ents. 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 co mplete 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 o perate 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 accordan ce 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 Genera l 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 52 1 60 1 R 336.1225

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### 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).

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## FGNEUTCATACC

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the neutralizer, catalyst, and ac celerator process tanks exhausted from a common stack, no

emission controls.

Emission Unit: EUNEUTRALIZER, EUCA TALYST, 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate FGNEUTCATACC unless the approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict 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 accordan ce with the approved operation and maintenance plan. (R 336.1213(3))

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### 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 Genera l 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 42 1 60 1 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).

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## FGCOPPER

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the copper electroplating ta nks which are exhausted by a common stack, no emission

controls.

Emission Unit: EUCOPPERSTRIKE, EUAC IDCOPPER1, EUACIDCO PPER2, 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/OPERATIO NAL 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 operat e FGCOPPER unless the appr oved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict 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)

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### 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 accordan ce 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 Genera l 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 52 1 60 1 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).

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## FGSEMINICKEL

EMISSION UNIT CONDITIONS

DESCRIPTION

This group consists of 5 semi-brite nickel electropl ating tanks which are exhausted by a common stack, no

emission controls.

Flexible Group ID: EUSEMIBRINI1, EUSEMIBRINI2, EUSEM IBRINI3, 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 pph 1 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate FGSEMINICKEL unless the approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict 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 ev ery 48 months from the date of completion of the most recent stack test thereafter, the per mittee shall verify nickel emission rates from FGSEMINICKEL by testing at owner's expense, in accordance with Department require ments. 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))

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### 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 accordan ce 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 Genera l Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District O ffice 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 52 1 60 1 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).

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## FGBRIMICRONI

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the brite and micro-porous elec troplating tanks which are exhausted by a common stack, no

emission controls

Emission Unit: EUBRINICKEL1, EUBR INICKEL2, 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 pph 1 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate FGBRIMICRONI unless the approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict 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 ev ery 48 months from the date of completion of the most recent stack test thereafter, the per mittee shall verify nickel emission rates from FGSEMINICKEL by testing at owner's expense, in accordance with Department requi rements. 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))

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### 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 accordan ce 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 Genera l 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 42 1 60 1 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).

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## FGCHROME2

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

This group consists of the decorative chrome plating t anks and a chrome recovery unit controlled by a composite mesh pad and fume suppressant control subjec t 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 pph 1 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/OPERATIO NAL 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 appro ved 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))

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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 st andardized 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 proce ss equipment, add-on control device(s) and monitoring equipment malfunctions and for implementing correc tive actions to address such malfunctions.

3. If actions taken by the permittee during periods of malf unction are inconsistent with the procedures specified in the Preventative Maintenance/Operation and maintenan ce/Malfunction Abatement Plan, the permittee shall record the actions taken for that event and shall repor t 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 CF R 63.342(f)(3)(E)(iv))

4. If the operation and maintenance plan fails to addre ss 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 proces s 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, shutdo wn, and malfunction, owners or operators shall operate and maintain any affected source, including associated moni toring 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 afte r 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 ever y 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 requirem ents. 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 co mplete 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 satisfacto ry manner, the surface tension of FGCHROME2. 2 (R 336.1225, R 336.1910)

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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 t he 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 atta ck on the structural integrity of the control device.

c. Visually inspect the back portion of the mesh pad clos est 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 syst em, 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 requi red to comply with applicable work practice standards of 40 CFR 63.342(f). Each inspection record shall identi fy 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 tensi on 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, dur ation, and cause (if known) of each malfunction of the electroplating process, control dev ice, 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 t hat 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 s pecific 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 s pecific 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 decorativ e chrome electroplating tank(s) operating time. (R 336.1941, 40 CFR 63.346(b)(11))

13. The permittee shall perform all applicable monito ring 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)

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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 Pollutant s 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 informat ion 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 Genera l 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 on going 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 oc curred in the reporting period. (R 336.1941, 40 CFR 63.347(g))

6. The permittee shall perform all applic able 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 46 1 60 1 R 336.1225

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### IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provis ions 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).

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## 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/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate FGSTRIPTANKS unles s the approved operation and maintenance plan, or an alternate plan approved by the AQD Dist rict Supervisor, is implemented and maintained. The plan shall include procedures for maintaining and operating in a satisf actory manner, the packed bed scrubber with mist eliminators and the monitoring equipment required to record the pressure dr op 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

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### 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 o perate 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 accordan ce 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 Genera l 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 46 1 60 1 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).

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## E. NON-APPLICABLE REQUIREMENTS

At the time of ROP issuance, the AQD has determined t hat 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).

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## APPENDICES

Appendix 2-1: Abbreviations & Acronyms

The following is an alphabetical listing of abbrevia tions/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 N SPS New Source Performance Standards

CO Carbon Monoxide NSR New Source Review

COM Continuous Opacity Monitoring PM Particulate Matter

department Michigan Department of Environmental Qualit y 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 A gency 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 Preventi on 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

H 2 S 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 SO 2 Sulfur Dioxide

LAER Lowest Achievable Emission Ra te 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 me asured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig).

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### 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 wi th 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 sp ecifications are detailed in Part A or the appropriate Source-wide, emission unit and/or flex ible 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 condit ions. Therefore, this appendix is not applicable.



### Appendix 2-5. Testing Procedures

Specific testing requirement plans, procedures, and aver aging times are detailed in the appropriate Source-wide, emission unit and/or flexible group special condit ions. Therefore, this appendix is not applicable.



### Appendix 2-6. Permits to Install

The following table lists any Permits to Install issued si nce 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.

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### Appendix 2-8. Reporting

A. Annual, Semiannual, and Deviation Certification Reporting

The permittee shall use the MDEQ Report Certificat ion form (EQP 5736) and MDEQ Deviation Report form (EQP 5737) for the annual, semiannual and deviation certificat ion reporting referenced in the Reporting section of the Source-wide, emission unit and/or flexible group spec ial conditions. Alternative formats must meet the provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), res pectively, and be approved by t he AQD District Supervisor.

B. Other Reporting

Specific reporting requirement format s 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 Mainte nance Plan for the facility. At a minimum this plan shall address the preventative maintenance of the pl ating 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.