}J' 

Page: 1 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

STATE OF MICmGAN 

RENEWABLE OPERATING PERMIT 

IS HEREBY ISSUED TO 

Deco' Plate Manufacturing Company 

SRN: N1863 

LOCATED AT 

395 Demille Road 

Lapeer, MI 48446 

Pennit Numb~r: 199600451 

Effective Date: June 2, 1999 

Expiration Date: June 2, 2004 

This permit is issued in accordance with and subject to Part 5506(3) of Article II, Chapter 1, Part 55 (Air 

Pollution Control) ofP.A. 451 of 1994. Pursuant to Air Pollution Control Rule 336.1210(1), this pennit 

constitutes the permittee's authority to operate the major stationary source identified above in accordance 

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

stationary source and all emission unit/process groups listed in the permit are subject to all future or 

amended rules and regulations pursuant to P.A. 451. 

This permit does not relieve the permittee from the responsibility to obtain the necessary permits to install 

pursuant to Air Pollution Control Rule 336.1201 for new or modified process or process equipment. In 

addition, issuance of this renewable operating pennit does not obviate the necessity of obtaining such 

permits or approvals from other units of government as required by law. 

Michigan Department of Environmental Quality 

Michael J. Koryto, District Supervisor 

Air Quality Division, Shiawassee District Office 
; r 

Page: 2 of 65 

Table of Contents 

A. GENERAL REQUIREMENTS 

EnforceabiUty 

GENERAL CONDITIONS 

Recordkeeping and Reporting 

CompUance Reporting and Certification 

Permit Sbield 

Stratospberic Ozone Protection 

Risk Management Plan 

Emission Trading 

B. SOURCE-WIDE REQUIREMENTS 

C. EMISSION UNIT/PROCESS GROUP SUMMARY TABLE 

D. FLEXIBLE GROUPINGS SUMMARY TABLE 

E. EMISSION UNIT/PROCESS GROUP REQUIREMENTS 

TABLE E-l.l EGPAINTLINE#l 

TABLE E-l.2 EGPAINTLINE#2 

TABLE E-l.3 EG-CHROMETANKJ2 

TABLE E-l.4 EG-COPPERTANKS 

TABLE E-l.S EG-ACTIVATORTANKS 

TABLE E-1.6 EG-NEUTRALIZERTANKS 

TABLE E-l. 7 EG-CHROMEETCH 

F. FLEXIBLE GROUPING REQUIREMENTS 

TABLE F-l.1 FG-CHROMEPROCESS 

TABLE F-l.2 FG-COLDCLEANER 

G. NON-APPLICABLE REQUIREMENTS 

APPENDICES 

Permit Nwnber: 19960045 I 

Expiration Date: June 2. 2004 

4 

4 

4 

6 

7 

7 

8 

8 

9 

9 

10 

10 

11 

12 

16 

20 

24 

26 

28 

30 

32 

33 . 

3S 

37 

37 
; II 

Page: 3 of 65 

Appendix 1. Abbreviations Used in This Permit 

Appendix 2. Schedule of Compliance 

Appendix 3. Monitoring Requirements 

Appendix 4. Recordkeeping 

Appendix 5. Testing Procedures 

Appendix 6. Voided Permits 

Appendix 7. Emission Calculations 

Appendix 8. Reporting 

Appendix 9. Preventive Maintenance Plan-Air Exhaust Equipment 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

37 

37 

37 

38 

42 

42 

43 

52 

64 
Page: 4 of 65 

A. General Requirements 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

For the purpose of this Renewable Operating (RO) pennit, the permittee is defined as any person who owns or operates an 

emission unit/process group at a stationary source for which a RO pennit has been issued. This pennit is issued to Deco' Plate 

Manufacturing Company, hereinafter the pennittee for this RO pennit. The department is defined in R 336.1104(d) as the 

Director of the Department of Environmental Quality or his or her designee. 

Enforceability 

All conditions in this pennit are both federally enforceable and state enforceable unless otherwise noted. Those requirements 

which are enforceable by the state only are designated by an asterisk. (R 336.1213(5» 

General Conditions 

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

pennit shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other condition or part of 

this RO pennit. (R 336.1213(1)(f) 

2. Except as provided in subrules 2, 3, and 4 ofR 336.1301, a person shall not cause or pennit to be discharged into the outer 

air from an emission unit/process group a visible emission ofa density greater than the most stringent of R 336.1301(a) or (b) 

unless otherwise specified in this RO pennit. The grading of visible emissions shall be determined in accordance with 

R 336.1303. (R 336.1301(1) in pertinent part) 

a) A 6-minute average of20% opacity, except for one 6-minute average per hour of not more than 27% opacity. 

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

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

The collection and disposal of air contaminants shall be perfonned in a manner so as to minimize the introduction of 

contaminants to the outer air. Transport of collected air contaminants in Priority I and II areas requires the use of material 

handling methods specified in R 336.1370(2). (R 336.1370) 

4. 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 336.19 I 0) 

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

tests, at the owner's or operator's expense, in accordance with R 336.2001 and R 336.2003, under any of the conditions listed 

in R 336.2001. (R 336.2001) 

6. A change in ownership or operational control of a stationary source covered by a RO pennit shall be made pursuant to 

R 336.1216(1). (R 336.1219(3» 

7. Operation of any emission unit/process group at this stationary source shall not result in the emission of an air contaminant in 

quantities which cause injurious effects to human health or safety, animal life, plant life of significant economic value, or property, 

or which cause unreasonable interference with the comfortable enjoyment of life and property.· (R 336.190 I) 

8. Approval of this RO pennit does not exempt the pennittee from complying with any future regulations which may be 

promulgated under Act 451 of 1994, as amended, Part 55, (Air Pollution Control) andlor the CAA. (R 336.1217(2)(a)(i) and (ii» 

9. The pennittee shall comply with all conditions of this RO pennit. Any pennit noncompliance constitutes a violation of 

Act 45 I of 1994, as amended, Part 55, (Air Pollution Control) and is grounds for enforcement action, for pennit revocation or 

revision, or for denial of the renewal of the RO pennit. . Notwithstanding the compliance detennination methods which the . 

owner or operator of a stationary source is authorized to use under Act 451 of 1994, as amended, Part 55 (Air Pollution 

Control), the department may use any relevant information or appropriate method to detennine a stationary source's compliance 

with applicable emission limitations. All terms and conditions of this RO pennit that are designated as federally enforceable 

are enforceable by the Administrator of the EPA and by citizens under the provisions of the CAA. Any terms and conditions 

based on applicable requirements which are defined as "state only" are not enforceable by the EPA or citizens pursuant to the 

CAA. (R 336.1213(1)(a» 
Page: 5 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

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

permitted activity in order to maintain compliance with the conditions of this RO permit. (R 336.1213(1)(b» 

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

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does not stay any 

pennit condition. Pursuant to R 336.1215 and R 336.1216 the permittee may make changes at a stationary source at his/her 

own risk. (R 336.1213(1)(c» 

12. 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 RO permit or to determine compliance with 

this RO permit. Upon request, a person shall also furnish to the department copies of any records that are required to be kept as 

a term or condition of this RO permit. (R 336.1213( 1)( e» 

13. The permittee shall allow the department, or an authorized representative of the department, to enter at reasonable times, 

this stationary source or other premises, have access to and copy any records that must be kept under the conditions of this RO 

permit, and inspect, sample, or monitor emission unit/process groups at this stationary source. (Act 451 Part 5526(1)(b) and 

R 336.1213(l)(d» 

14. The permittee shall pay fees consistent with the department fee schedule and requirements pursuant to Part 5522 of 

Act 451, P.A. 1994. (R 336.1213(l)(g» 

15. This RO permit does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h» 

16. For renewal of this RO permit, an administratively complete application shall be considered timely if it is received by the 

department not more than 18 months, but not less than 6 months, before the expiration date of the RO permit. (R 336.1210(7» 

17. For modifications to this RO permit, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the time frames specified in R 336.1216. (R 336.1210(9» 

18. For changes to any emission unit/process group covered by this RO permit which do not require a revision of the RO 

permit, the permittee must provide written notification to the department and the Administrator of the EPA as specified in 

R 336.1215(2) and R 336.1215(3)(c) and keep records as specified in R 336.1215(3)(d). 

19. An RO permit shall be reopened prior to the expiration date and revised by the department under any of the following 

circumstances: 

a) If additional requirements become applicable to this stationary source with three or more years remaining in the term of 

the permit. (R 336.1 217(2)(a)(i» 

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

(R 336.l217(2)(a)(ii» 

c) If the department determines the permit contains a material mistake, that information required by any applicable 

requirement was omitted, or that inaccurate statements were made in establishing emission limits or the terms or conditions 

of the permit. (R 336.1217(2)( a)(iii» 

d) If the department determines the permit must be revised to ensure compliance with the applicable requirements. 

(R 336. 12 I 7(2)(a)(iv» 

20. Any required testing protocol shall conform to a format acceptable to the AQD. (R 336.2003(1» 

21. Any required test results which must be submitted to the AQD shall conform to a format acceptable to the AQD. 

(R 336.2001(4» 
, 

Page: 6 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

Recordkeeping and Reporting 

22. The permittee shall use all emissions monitoring and analysis procedures or test methods required by the applicable 

requirements, including any procedures and methods promulgated pursuant to Section 504(b) of Title V or Section I 14(a)(3) of 

Title I of the CAA. (R 336.1213(3)(a)(i» 

23. Where an applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring, the 

permittee shall use periodic monitoring as required in this RO permit, sufficient to yield reliable data from the relevant time 

period that are representative of the stationary source's compliance with the permit as specified in R 336.1213(3)( a)(ii). 

24. Records of any periodic emission or parametric monitoring required by this RO permit, shall include the information 

specified in R 336. 1213(3)(b)(i) unless the details for such records are otherwise specified in this RO permit. 

(R 336.l213(3)(b» 

25. AIl required documents, monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and made readily available for a period of not less than 5 years from the date of 

generation of the document, data, report, or information. 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 RO permit. (R 336. 1213(3)(b)(ii), R 336. 1213(I)(e» 

26. Semi-annually for the term of the permit as detailed in the requirement tables, or more frequently if specified in an 

applicable requirement in this RO permit, the permittee shall submit certified reports of any required monitoring to the 

appropriate District Office of the AQD. All instances of deviations from permit requirements during the reporting period shall 

be clearly identified in the reports. (R 336. 1213(3)(c)(i» 

27. The permittee shall promptly report any deviations from permit requirements and certify the reports. The prompt reporting 

of deviations from permit requirements is defined in R 336. 1213(3)(c)(ii) as follows, unless otherwise described in this RO 

permit: (R 336. 1213(3)(c» 

a) For deviations that exceed the emissions allowed under the RO permit, prompt reporting means reporting consistent 

with the requirements ofR 336.1912 as detailed in Condition 29. All reports submitted pursuant to this paragraph shall be 

promptly certified as specified in R 336.1213(3)(c)(iii). 

b) For deviations which exceed the emissions allowed under the RO permit and which are not reported pursuant to 

R 336.1912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the semi-annual 

reports required by R 336. 1213(3)(c)(i). The report shall describe reasons for each deviation and the actions taken to 

minimize or correct each deviation. 

c) For deviations that do not exceed the emissions allowed under the RO permit, prompt reporting means the reporting of 

all deviations in the semi-annual reports required by R336.1213(3)(c)(i). The report shall describe the reasons for each 

deviation and the actions taken to minimize or correct each deviation. 

For reports required pursuant to R 336.l213(3)(c)(ii), prompt certification of the reports is described in R 336.1213(3)(c)(iii) 

as follows: 

d) Submitting a certification by a responsible official with each report which states that, based on information and belief 

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

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

deviations from the emissions allowed under the permit were submitted to the department pursuant to R 336.1 2 l3(3)(c)(ii), 

a certification by a responsible official which states that, based on information and belief formed after reasonable inquiry, 

the statements and information contained in each of the reports submitted during the previous month were true, accurate, 

and complete. The certification shall include a listing of the reports that are being certified. Any report submitted pursuant' 

to R336.1213(3)(c)(ii) that will be certified on a monthly basis pursuant to this paragraph shall include a statement that 

certification of the report will be provided within 30 days following the end of the calendar month. 

28. Any document required to be submitted to the department as a term or condition of this RO permit shall contain a 

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» 
Page: 7 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

29. The permittee shall provide notice of an abnonnal condition, start-up, shutdown, or malfunction that results in emissions of a 

hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable standard or limitation, or 

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

R 336.1912, to the appropriate District Office of the AQD. The notice shall be provided not later than two business days after startup, shutdown, or discovery of the abnormal condition 'or malfunction. Written reports, if required, must be filed with the 

appropriate District Supervisor within 10 days after the start-up or shutdown occurred, within 10 days after the abnonnal conditions 

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

The written reports shall include all of the information required in R 336.1912(5) and shall be certified by a responsible official. 

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

each regulated air pollutant actually emitted for each emission unit/process group utilizing the emissions inventory forms 

provided by the department as specified in R 336.1212(7). 

Compliance Reporting and Certification 

31. The responsible official shall certify to the appropriate District Office of the AQD and the EPA, whether the stationary 

source is and has been in compliance with all terms and conditions contained in the RO permit except for deviations that have 

been reported to the appropriate District Office of the AQD pursuant to Condition 27. This certification shall be in an 

acceptable written format as specified in R 336.12 I 3 (4)(c)(i) through (v) and shall state that, based on information and belief 

formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. The EPA 

address is: US EPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL, 

60604. (R336.1213(4)(c» 

32. The certification of compliance shall be submitted annually for the term of this RO permit as detailed in the requirement 

tables, or more frequently if specified in an applicable requirement in this RO permit. (R 336.1213(4)(c» 

Permit Shield 

33. A permit shield is in place for any applicable requirements which are included and specifically identified in this RO permit 

as of the date of permit issuance. Compliance with each condition of this permit shall be deemed compliance with the specific 

applicable requirements identified with that condition. Any requirements identified in Part G of this RO permit have been 

identified as non-applicable to this RO permit and are included in the permit shield. (R 336.12 I 3 (6)(a}(i) and (ii» 

34. Nothing in this RO permit shall alter or affect any of the following: 

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

the Act. (R 336.l213(6)(b)(i» 

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

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

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

(R 336.1 2 13(6)(b)(iii» 

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

(R 336. 1213(6)(b)(iv» 

35. The permit shield shall not apply to provisions incorporated into this permit through procedures for any of the following: 

a) Changes for operational flexibility made pursuant to R 336.1215. (R 336.1215(5» 

b) Administrative amendments made pursuant to R 336.l216(l)(a)(i-iv) until the changes have been approved by the 

department. (R 336. 1216(1)(b)(iii» 

c) Administrative amendments made pursuant to R 336.1216(1)(a)(v) until the amendment has been approved by the 

department. (R 336. 1216(l)(c)(iii» 

d) Minor permit modifications made pursuant to R 336.1216(2). (R 336. I 216(2)(f) 
Page: 8 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

e) State-only modifications made pursuant to R 336.1216(4) until the changes have been approved by the department. 

(R 336. 1216(4)(e» 

36. Expiration of this RO pennit 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 RO permit, but 

the department fails to take action before the end of the permit term, the existing RO permit does not expire until the renewal is 

approved or denied, and the pennit shield shall extend beyond the original permit term until the department takes final action. 

(R 336.1217(1)(c), R 336.1217(1)(a» 

Stratospheric Ozone Protection 

37. If the pennittee services, maintains, or repairs appliances except for motor vehicle air conditioners (MV AC), or disposes of 

appliances containing refrigerant, including MV AC and small appliances, or if the permittee is a refrigerant reclaimer, 

appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall comply with all 

standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F. 

38. If the permittee perfonns a service on motor (fleet) vehicles when this service involves refrigerant in the MV ACt the 

pennittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle 

Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which final assembly of the 

vehicle has not been completed by the original equipment manufacturer. The term MV AC as used in Subpart B does not 

include the air-tight sealed refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses 

using HCFC-22 refrigerant. 

Risk Management Plan 

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

regulatory agency, a risk management plan (RMP) for reducing the probability of accidental releases of any regulated 

substances listed pursuant to Section I 12(r}(3) of the CAA as amended in 68.130. The RMP shall be submitted in a method 

and format as specified by EPA. The list of substances, threshold quantities, and accident prevention regulations promulgated 

under Part 68 do not limit in any way the general duty provisions under Section 112(r)(l). 

40. If subject to Section I 12(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements of Part 68 no 

later than the latest of the following dates as provided in 68.10(a): 

a) June 21, 1999, 

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

c) The date on which a regulated substance is first present above a threshold quantity in an emission unit. 

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

requested by any regulatory agency necessary to ensure compliance with the requirements of 40 CFR Part 68. 

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

requirements of Section Il2(r), including the registration and submittal of an RMP, as detailed in Conditions 31 and 32 of this 

RO permit. (40 CFR Part 68) 
Page: 9 of 65 

Emission Trading 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

43 . The use of Emission Reduction Credits for purposes of compliance with emission standards or limitations contained in this 

pennit is allowed, provided that such usc is in compli ance with Michigan's Part 12 Emission Averaging alld Emission 

Reduction Credit Trading rules (R 336.220 I-R 336.2218). Any changes consistent with these rules do not require a revision to 

this RO Penni!.· (R 336. 12 I 5(2)(b), R 336.2204(7), R 336.2211(3» 

B. Source-Wide Requirements 

At the time of RO pennit issuance, the AQD has detemlincd that there are no addi tional specific source-wide applicable 

requirements which apply to all emission unit/process groups at this source. Therefore, the pennillee is subject to the General 

Requirements in Part A and any other tenns and conditions contained in this RO penni!. 
Page : 10 of 65 

C. Emission UnitlProcess Group Summary Table 

UnltlGroup ID Emission Uliit/PrOCHI Group l\1 od~~~tion 

EG-PAINTLlNE# I Plastic ; 1121199' 

parts cOllting line consisting 

of five dry filter {or 

equivalent contro l) spray 

booths and two bake ovens. 

EG·PAINTLlNEI#2 Plastic ; !12I199' 

pans coating line consisting 

of six dry filt er (or equ ivalent 

control) spray booths and one 

oven. 

~ ~ ",,,iii 

1711990 

1 ,, ~ .,opp" m ik' " "k ("''') 7/ 1990 

and five bright acid copper 

I ,,,k,W15 , ,#19i. 

I~~~ VATORTANKS 1 0", , ctank.!"7), 0", 1

711990 

accelerator tank (#9), and 

one electro less copper tank 

1(# 11). 

EG· One neutral izer tank (#5) nnd 711990 

NEUTRALIZERTANKS I tank (li3'9). and nickel strip 

EG·CHROMEETCH One tank (# I) and 711990 

one etch tank (#2). 

1& 

12 

s""H, An" 1979 

D. Flexible Groupings Summary Table 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

Control De\icc Stac.k/Vcnt ID 

T.bl,N •. 

:.'. , 1 ~~:~~:~~~~~ ;: 1 E-l.l 

equivalent SY·LN1BOOTH3, 

control) SV·LNIBOOT H4, 

SV-LNIBOOTH5, 

SY·LNIOVENI, 

1 SV-LNI 

filt ers (or I ~V- N2. OO~~~: 1 E-!.' 

equivalent SV-LN2-BOOTH3, 

contro l) SY·LN2·BOOTH4 , 

SV·LN2-BOOTH5, 

SV·LN2·BOOTH6, 

~ Is~ ISV, I E·1.3 

I ~~p~:a~~o~e SVCHRMEX HSYS2 E-1.4 , 

F·Ll 

I Packed Bed "" I E-1.5, 

Scrubber F-1.1 

1 P"k,d B,d SVCHRMEXHSYS4 E-I.6, 

Scrubber F·Ll 

Dry mesh pad SYCHR.t\lEXHSYS5 E-1.7 

scrubber on 

I ~ ~:;~ May 

NA NA F-1.2 

Flexible Grouping ID Eminion UnitIProcess Groups Requirement 

Included in Flexib le Groupint: Table No. 

FG·CHROMEPROCESS EG·COPPERT ANKS F·l.l 

EG-ACfIYATORT ANKS 

EG-NEUTRALIZERT ANKS 

FG-COLDCLEARN ERS EG-COLDCLEANERI & 2· F·i.2 
Page: 11 of 65 

E. Emission UnitlProcess Group Requirements 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

The tables in Part E outline the applicable requirements for each emission unit/process group listed in the Emission 

UnitIProcess Group Summary Table. The permittee is subject to the requirements for each emission unit/process group in 

addition to the General Requirements in Part A and any other terms and conditions contained in this RO permit. 

Each emission unit/process group shall meet the design parameters, material usage/emission limitations, monitoring, 

recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in Tables E-l.l 

through E-1.7 as well as other terms and conditions specified in this RO permit to assure compliance with all applicable 

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

requirements cited in the tables. The underlying applicable requirements for the material usage/emission limitations, 

monitoring, recordkeeping, reporting and testing requirements, operational parameters, and any other requirements are 

identified in parentheses. Ifa specific requirement type does not exist for the emission unit/process group, NA (not applicable) 

has been used in the table. Those requirements which are enforceable by the state only are designated by an asterisk. 
Page: 12 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.l EGPAINTLINE#l 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EGPAINTLINE# I Plastic exterior automotive parts coating Jine consisting of five dry filter 

(or equivalent control) spray booths and two bake ovens. 

Flenble Groupine ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control Exhaust filters (or equivalent control) on each spray booth for particulate control. 

Equipment 

B. Stack/Vent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

Stack/Vent a. Minimum b. Maximum Exhaust Co Temperature d. Air Flow AppUcable 

ID Height (feet) Dimension (incheSl (oF) Rate-.lacfm~ Requirement 

1. SV-LNIBOOTHI 36 36 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120l(3)) 

2. SV -LN I BOOTH2 36 36 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120l(3)) 

3. SV-LNIBOOTH3 36 36 NA NA (paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120U3)) 

4. SV -LN I BOOTH4 36 36 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3» 

5. SV-LNlBOOTH5 36 36 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.110l(3)) 

6. SV-LNIOVENI 36 36 NA NA (paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3)) 

7. SV-LNIOVEN2 36 36 NA NA (paragraph B.A, 

Consent Order 

No. 6-1995, 

R336.1201(3» 

C. Other Design Parameters 

NA 

II. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usaee Rate 

NA NA 

B. Pollutant Manmum Emission LImit 

Volatile Organic Compounds 1. 25.2 poundslhour, 2. 604 pounds/calendar day, 3. 3.73 ton/calendar month. 

(VOC) «Paragraph 8.B.l, Consent Order No. 6-1995, R336.1701) 

4. For coating exterior glastic automotive garts-high bake coatings as sgecified in Rule 632 

(20): 1.2.4.~ 

a). Prime-Flexible Coating Category 4.5 Ibs. VOC/gal. of coating (minus water) as applied. 

b). Prime-Non Flexible Category 3.5 lbs. VOC/gal. of coating (minus water) as applied. 

c). Topcoat-Basecoat Category 4.3 Ibs. VOC/gal. of coating (minus water) as applied. 

d). Topcoat-Clearcoat Category 4.0 lbs. VOC/gal. of coating (minus water) as applied. 
Page: 13 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.l EGPAINTLINE#l 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

e). Topcoat-Non-BasecoatlClearcoat Category 

4.3 lbs. VOC/gal. of coating (minus water) as applied. 

(Paragraph 8.8.2, Consent Order No. 6-1995, R336.1702(d» 

5. For coating exterior plastic automotive parts-air dried coatings as specified in Rule 632 ~1.J ••• 5 

a). Prime Coating Category 4.8 Ibs. VOClgal. of coating (minus water) as applied. 

b). Topcoat-Basecoat Category "lilbs. VOCIgal. of coating (minus water) as applied. 

c). Topcoat-Cleareoat Category Ulbs. vec/gal. of coating (minus water) as applied. 

d). Topcoat-Non-BasecoatlClearcoat Category 

5.0 Ibs. VOC/gal. of coating (minus water) as applied. 

(Paragraph 8.8.2, Consent Order No. 6-1995, R336.1702(d» 

6. For touch-up and repair of exterior plastic automotive parts as specified in Rule 632 (20): 

3,5 

5.2 lbs. VeC/gal of coating (minus water) as applied. 

(Paragraph 8.8.2, Consent Order No. 6-1995, R336.1702(d» 

7. For coating automotive parts using resist coatingsCNote: Resist coatings exempt from 

Rule 632 (20) under Rule 632(l5)(d)): 3,5 

6.3 Ibs. VOC/gal of coating (minus water) as applied. 

(Paragraph 8.B.2, Consent Order No. 6-1995, R336.1702(a» 

---------------------------------------------_._-_._----

I For red and black coatings, the emission limitation shall be detcnnined by multiplying the appropriale limit table 

by 1.15. 

2 When method 24 is used to determine the volatile organic compound content of a coating, the applicable 

emission limitation shall be determined by adding 0.5 to the appropriate limit. 

3 When method 24 is used to determine the volatile organic compound content of a coating, the applicable 

emission limitation shall be determined by adding 0.1 to the appropriate limit. 

4 Air-dricd coating means a coating that is dried by the usc of air or forced warm at temperatUreS up to 90 cIcgrees 

Celsius (194 degrees Fahrenheit)-abovc this tempcratun: would be considered a high baked coating 

, Limits arc based on a calendar day averaging period-the limits arc volume weighted by category. 

ill. COMPLIANCE EVALUATION 

Records of all of the following shaD be maintained on rue for a period of 5 yean. (R 336.1213(3)(b)(U)) 

1. Continuous Emission 

Monitoring (CEM) System and 

Recordkeeplng 

2. Process Monitoring System 

and Recordkeeping 

3. Other Monitoring and/or 

Recordkeeping 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements in Part A 

NA 

NA 

I. Identification of the applicable coating category for each coating: daily records. 

(Paragraph 8.B.4, Consent Order No. 6-1995, R336.201(3» 

2. Hours of operation: daily records. 

(Paragraph 8.B.4, Consent Order No. 6-1995, R336.201(3» 

3. Gallons of coating/reducer used: daily records. 

(Paragraph 8.8.4, Consent Order No. 6-1995, R336.2041~ 

4. vec content: daily records of the VOC content of each coating/reducer in pounds/gallon 

as applied. 

(Paragraph 8.8.4, Consent Order No. 6-1995, R336.2041) 

5. IfVOC content is detennined from manufacturer's formulation data, Pennittee shall 

record the mixing ratio of each coating and reducer: daily record. 

(Paragraph 8.B.4, Consent Order No. 6-1995 R336.201(3)) 
Page: 14 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.l EGPAINTLINE#l 

EMISSION UNITIPROCESS GROUP RE~UlREMENTS 

1. Parameter to be 

TestedlRecorded 

2. Method/Analysis 

3. Frequency and Schedule 

of Testfng/RecordkeeJ)ing 

IV. REPORTING 

Reports and Schedules 

6. The VOC content of all solvent based coatings used as applied shall be determined using 

Federal Reference Test Method 24. Upon prior approval of the District Supervisor, Air 

Quality Division, the VOC content may alternatively be determined from manufacturer's 

formulation data. Water based coatings may utilize batch certifications for determination of 

the vec content. 

(Paragraph 8.A, Consent Order No. 6-1995, R336.2040(S)(a» 

7. IfVOC content is determined from manufacturer's formulation data, Permittee shall 

maintain current listing of the manufacturer's formulation data for each coating/reducer. 

. (Paragraph S.A, Consent Order No. 6-1995, R336.201(3» 

8. Cleanup solvents: monthly records of the amount in gallons/month and VOC content in 

pounds/gallon of all purge and/or cleanup solvents used and reclaimed. 

(Paragraph 8.A, Consent Order No. 6-1995, R336.201(3) 

9. Condition of exhaust filters: Daily visible check of the condition of exhaust filters. 

(R336.1213(3» 

1 O. vec Emission rates shall be calculated according to the method outlined in 

Appendix 7. (R336.201(3» 

See Appendix 4 and 7 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

NA 

NA 

NA 

1. Prompt reporting of deviations pursuant to Condition 27 of Part A. 

(R336.1213(3)(c)(il» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July 1 to December 31 and September 15 for reporting period January I 

to June 30. (R336.1213(3)(c)(I» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

4. Within 30 days following the end of each calendar quarter, the Permittee shall submit a 

summary of the coating usage records using the format in Appendix 8 or an equivalent 

method approved by the AQD Shiawassee District Supervisor. 

(Paragraph 8.B.5, Consent Order No. 6-1995, R336.1201(3» 

See Appendix 8 

I. Permittee shall not operate the paint spray booths unless all exhaust filters are in place and operating properly. 

(paragraph 8.B.8, Consent Order No. 6-1995, R336.1910) 

2. The disposal of collected dry filters and/or paint sludge shall be performed in a manner which minimizes the introduction of 
Page: 15 of 65 

TABLE E-l.l EGPAINTLINE#l 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

air contaminants to the outer air. (Paragraph 8.A, Consent Order No. 6-1995, R336.1702) 

3. Solvent based coatings shall be applied utilizing HVLP applicators and/or an electrostatic spray system or equivalent 

technology with a comparable transfer efficiency. All coating applicators shall be properly installed, maintained and operated 

according to manufacturer's specifications. (Paragraph 8.8.9, Consent Order No. 6-1995, R336.1702) 

4. All purge solvents and paints from all manual coating applicators used in the coating line shall be captured and stored in 

closed containers and disposed of in an acceptable manner in compliance with all applicable rules and regulations. 

(Paraeraph 8.A •• Consent Order No. 6-199~ R336.1702) 

VI. OTHER REQUIREMENTS 

NA 

* This requirement is state enforceable only. 
Page: 16 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.l EGPAINTLINE#l 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EGP AINTLINE#2 Plastic exterior automotive parts coating line consisting of six dry filter 

spray (or equivalent control) booths and one oven. 

Flenble Grouping ID NA 

I. DESIGN PARAMETERS 

A. PoUudon Control Exhaust filters (or equivalent control) on each spray booth for particulate control. 

Equipment 

B. Stack/V ent Parameters I Exhaust gases shall be discharged unobstructed vertically llItwards unless otherwise noted. 

Stack/Vent a. Minimum b. Manmum Exhaust c. Temperature d. Air Flow AppUcable 

ID Heieht (feet) Dimension (inches) (oF) Rate (acfm) Requirement 

1. SV -LN2BOOTH 1 44.5 30 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120l(3}) 

2. SV-LN2BOOTH2 44.5 30 NA NA (paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3)) 

3. SV-LN2BOOTH3 44.5 30 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3)) 

4. SV-LN2BOOTH4 44.5 30 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120113}l 

5. SV-LN2BOOTH5 44.5 30 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.120 1(3)) 

6. SV -LN2BOOTH6 44.5 30 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3» 

7. SV-LN20VEN 40 34 NA NA (Paragraph 8.A, 

Consent Order 

No. 6-1995, 

R336.1201(3)) 

C. Other Design Parameters 

NA 

II. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usaee Rate 

NA NA 

B. PoUutant Maximum Emission Limit 

Volatile Organic Compounds 1. 52 poundslhour, 2. 1248 pounds/calendar day, 3. 8.3 tonlcalendar month. 

(VOC) (Paragraph 8.C.l, Consent Order No. 6-1995, R336.1702) 

4. For CQIUing exleriQuinterior nlastjc automQ!ive nart~-bigh hake coatings as sl'lecifjed in 

Rule 632 (20);1,2,4,5 

a). Prime-Flexible Coating Category 4.5 lbs. VOC/gal. of coating (minus water) as applied, 

b). Prime-Non Flexible Category 3.5 lbs. VOC/gal. of coating (minus water) as applied. 

c). Topcoat-Basecoat Category 4.3 Ibs. VOC/gal. of coating (minus water) as applied. 

d). Topcoat-Clearcoat Category 4.0 lbs. VOC/gal. of coating (minus water) as applied. 
Page: 17 of 65 

Pennit Number: 199600451 

Expiration Date: June 2. 2004 

TABLE E-l.2 EGPAINTLINE#2 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

e). Topcoat-Non-BasecoatlClearcoat Category 

4.3 Ibs. VOC/gal. of coating (minus water) as applied. 

5. For coating exterior plastic automotive parts-air dried coatings as specified in Rule 632 

(20): 1,3.4.' 

a). Prime Coating Category 4.8 Ibs. VOCIgai of coating (minus water) as applied. 

b). Topcoat-Basecoat Category 5.0 Ibs. VOCIgal of coating (minus water) as applied. 

c). Topcoat-Clearcoat Category 4.5 Ibs. VOC/gal of coating (minus water) as applied. 

d). Topcoat-Non-BasecoatlClearcoat Category 

5.0 Ibs. VOC/gal of coating (minus water) as applied. 

6. For touch-up and repair of exterior plastic automotive parts as mecified in Rule 632 

(20):: 305 

5.2 lbs. VOCIgal of coating (minus water) as applied. 

( For red and black coatings, the emission limitation shall be detc:nnined by multiplying the appropriate limit table 

by 1.15. 

2 When method 24 is used to determine the volatile organic compound content of a coating, the applicable 

emission limitation shall be determined by adding 0.5 to the appropriate limit 

1 When method 24 is used to determine the volatile organic compound content of a coating, the applicable 

emission limitation shall be detennined by adding 0.1 to the appropriate limit 

4 Air-driecl coating means a coating that is dried by the usc of air or fcm:ed warm at temperatures up to 90 degrees 

Celsius (194 degrees Fahrenheit)-above this temperatun: would be considered a high baked coating 

S Limits are based on a calendar day averaging period-the limits arc volume weiglUed by category. 

(paragraph 8.C.2, Consent Order No. 6-1995 R336.1702(d)) 

UI. COMPLIANCE EVALUATION 

Records of aD of the (oDowina shaD be maintained on me for a period of 5 yean. (R 336.1 213(3)(b)(U» 

I. Continuous Emission 

Monitoring (CEM) System and 

Recordkeeping 

2. Process Monitoring System 

and Recordkeeplng 

3. Other Monitoring and/or 

Recordkeeping 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements in Part A 

NA 

NA 

1. Identification of the applicable coating category for each coating: daily records. 

(paragraph 8.B.4, Consent Order No. 6-1995, R336.201(3» 

2. Hours of operation: daily records. 

(Paragraph 8.B.4, Consent Order No. 6-1995, R336.201(3» 

3. Gallons of coating/reducer used: daily records. 

(Paragraph 8.8.4, Consent Order No. 6-1995, R336.2041) 

4. VOC content: daily records of the voe content of each coating/reducer in 

pounds/gallon as applied. (Paragraph 8.8.4, Consent Order No. 6-1995, R336.2041) 

5. IfVOC content is determined from manufacturer's formulation data. Pennittee shall 

record the mixing ratio of each coating and reducer: daily record. 

(Paragraph 8.8.4, Consent Order No. 6-1995, R336.201(3» 

6. The VOC content of all solvent based coatings used as applied shall be determined using 

Federal Reference Test Method 24. Upon prior approval of the District Supervisor, Air 

Quality Divisio1l. the VOC content may alternativelY be determined from manufacturer's 
Page: 18 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.2 EGPAINTLINE#2 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

1. Parameter to be 

TestedIRecorded 

2. Method! Analysis 

3. Frequency and Schedule 

of Testine/R.ecordkeepin2 

IV. REPORTING 

Reports and Schedules 

formulation data. Water based coatings may utilize batch certifications for determination of 

the VOC content. 

(Paragraph 8.A, Consent Order No. 6-1995, R336.2040(5)(a» 

7. If VOC content is detennined from manufacturer's formulation data, Permittee shall 

maintain current listing of the manufacturer's formulation data for each coating/reducer. 

(Paragraph 8.A, Consent Order No. 6-1995, R336.201(3» 

8. Cleanup solvents: monthly records of the amount in gallons/month and VOC content in 

pounds/gallon of all purge andlor cleanup solvents used and reclaimed. 

(Paragraph 8.A, Consent Order No. 6-1995, R336.201(3) 

9. Condition of exhaust filters: Daily visible check of the condition of exhaust filters. 

(R336.12J3(3» 

1 O. VOC Emission rates shall be calculated according to the method outlined in 

Appendix 7. (R336.201(3» 

See Appendix 4 and 7 

8. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

NA 

NA 

NA 

1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(U» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July 1 to December 31 and September 15 for reporting period January 1 

to June 30. (R336.1213(3)(c)(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.12J3(4)(c» 

4. Within 30 days following the end of each calendar quarter, the Permittee shall submit a 

summary of the coating usage records using the format in Appendix 8 or an equivalent 

method approved by the AQD Shiawassee District Supervisor. 

(Paragraph 8.C.4, Consent Order No. 6-1995, R336.1201(3» 

See Appendix 8 

v. OPERATIONAL PARAMETERS 

1. Permittee shall not. operate the paint spray booths unless all exhaust filters are in place and operating properly. 

(Paragraph 8.8.4, Consent Order No. 6-1995, R336.1910) 

2. The disposal of collected dry filters andlor paint sludge shall be performed in a manner which minimizes the introduction of 

air contaminants to the outer air. (Paragraph 8.8.4, Consent Order No. 6-1995, R336.1201(3» 

3. Solvent based coatings shall be applied utilizing HVLP applicators andlor an electrostatic spray system or equivalent 

technology with a comparable transfer efficiency. All coating applicators shall be properly installed, maintained and operated 

according to manufacturer's specifications. (Paragraph 8.8.4, Consent Order No. 6-1995, R336.1702) 

4. All purge solvents and paints from all manual coating applicators used in the coatin& line shall be captured and stored in 
Page: 19 of 65 

TABLE E·l.2 EGPAINTLINE#2 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

EMISSION UNITIPROCESS GROUP REj2UIREMENTS 

closed containers and disposed of in an acceptable manner in compliance with all applicable rules and regulations. 

(paralraph 8.0.4, Consent Order No. 6-1995, R336.1702) 

VI. OTHER REQUIREMENTS 

NA 

* This requirement is state enforceable only. 
: 

Page: 20 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.3 EG-CHROMETANK32 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EG-CHROMET ANK32 Existing decorative chromium electroplating tank #32. Exhaust 

also includes negligible emissions from one soak cleaner tank (#42), and one electroclean 

tank (#43).) 

Emission UnitlProcess Groups EG-CHROMET ANK32 

I. DESIGN PARAMETERS 

A. Pollution Control Use of a wetting agent for fume suppression and one mesh pad mist eliminator. 

Equipment 

B. StackIV ent Parameters I Exhaust gases shan be discharged unobstructed vertically upwards unless otherwise noted. 

StacklVent a. Minimum b. Maximum Exhaust c. Temperature d. Air Flow Applicable 

m Height (feeft Dimension (Inche~. .(DF) Rate (acfm) Requirement 

1. SV -CHREXHSYS 1 50 32 NA NA R336.120 1 (3» 

C. Other Design Parameters 

NA 

D. MATERIAL USAGEIEMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit 

Hexavalent Chromium 1. 2.9 micrograms per cubic meter, corrected to 70 0 F and 29.92 inches Hg. (Emissions 

from EG-CHROMEETCH are included under this limit until May 1,1999.) 

(R336.1901(a))* 

UL COMPLIANCE EVALUATION 

Records of an of tbe fonowlne shall be maintained on me for a period of 5 years. (R 336.1213(3}(b)(Ii)) 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General R!!(Iuirements In Part A 

1. Continuous Emission NA 

MOnitoring (CEM) System and 

Recordkeepin~ 

2. Process Monitoring System I. The surface tension (dynes/cm) shall be measured once every 4 hours (except as 

and Recordkeeping outlined below) during operation of each tank with a stalagmometer or tensionmeter as 

described in 40 CFR 63 Subpart N 63.343(c)(5). 

(40 CFR 63 Subpart N 63.343(c)(S)(ll)(A» 

2. The Permittee shall follow procedures specified ASTM Method D 1331-0, Standard 

Test Methods for Surface and Interfacial Tension of Solutions of Surface Active Agents for 

proper use of the tensionmeter. 

(40 CFR 63 Subpart N 63 Appendix A, Method 306B) 

3. The time between monitoring can be increased if there have been no exceedances. The 

surface tension shall be measured once every 4 hours of tank operation for the first 40 hours 

of tank operation after the compliance date. Once there are no exceedances during 40 

hours of tank operation, surface tension measurement may be conducted once every 8 hours 

of tank operation. Once there are no exceedances during 40 hours of tank operation, 

surface tension measurement may be conducted once every 40 hours of tank operation on 

an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring . 

allowed is once every 40 hours of tank operation. 

(40 CFR 63 Subpart N 63.343(c)(S)(ii)(B» 

4. Once an exceedance occurs as indicated through surface tension monitoring, the original 

monitoring schedule of once every 4 hours must be resumed. A subsequent decrease in 
Page: 21 of 65 

Permit Nwnber: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.3 EG-CHROMETANlOl 

EMISSION UNITIPROCESS GROUP REOUIREMENTS 

frequency shall follow the schedule outlined in the previous paragraph of this section. (For 

example, if an owner or operator had been monitoring an affected source once every 40 

hours and an exceedance occurs, subsequent monitoring would take place once every 4 

hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation, 

monitoring can occur once every 8 hours of tank operation. Once an exceedance does not 

occur for 40 hours of tank operation on this schedule, monitoring can occur once every 40 

hours of tank operation.)(40 CFR 63 Subpart N 63.343(c)(5)(U)(C» 

5. Once a tank bath solution is drained from a affected tank and a new solution added, the 

original monitoring schedule of once every 4 hours must be reswned. with a decrease in 

monitoring frequency allowed following the procedures of previous paragraphs. 

(40 CFR 63 Subpart N 63.343(c)(5)(ill» 

6. Records of all maintenance performed on the chrome tanks and the tensionmeter. 

(40 CFR 63 Subpart N 63.346(b)(1» 

7. Records of all maintenance performed on mesh pad mist eliminator. (R336.1l13(3» 

8. Records of the occurrence, duration, and cause (if known) of each malfunction of the 

process and the tensionmeter. (40 CFR 63 Subpart N 63.346(b)(3» 

9. Records of the occurrence, duration, and cause (if known) of each malfunction of the 

mesh pad mist eliminator. (R336.1l13(3» 

1 O. Records of actions taken during periods of malfunction when such actions are 

inconsistent with the operation and maintenance plan. 

(40 CFR 63 Subpart N 63.346(b)(4» 

11. Other records, which may take the form of checklists, necessary to demonstrate 

consistency with the provisions of the operation and maintenance plan. 

(40 CFR 63 Subpart N 63.346 (b) (5» 

12. Records of monitoring data that are used to demonstrate compliance with the standard 

including the date and time the data are collected. 

(40 CFR 63 Subpart N 63.346(b)(8» 

13. The specific identification (i.e., the date and time of commencement and completion) 

of each period of excess emissions, as indicated by monitoring data, that occurs during 

malfunction of the process or monitoring equipment. 

(40 CFR 63 Subpart N 63.346(b)(9» 

14. The specific identification (Le., 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 process or monitoring equipment. 

(40 CFR 63 Subpart N 63.346(b)(10» 

15. (factions taken by the Permittee during periods of malfunction are inconsistent with 

the procedures specified in the operation and maintenance plan, the Pennittee shall record 

the actions taken for that event and shall report by phone such actions within 2 working 

days after commencing actions inconsistent with the plan. This report shall be followed by 

a letter within 7 working days after the end of the event. 

(40 CFR 63 Subpart N 63.341(t)(3)(E)(iv» 

16. The total process operating time of the chrome plating tank during the reporting period. 

(40 CFR 63 Subpart N 63.346(b)(1l» 
Page: 22 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.3 EG-CHROMETANlOl 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

17. Records of the date and time that fume suppressant wetting agents are added to the 

tanks. (40 CFR 63 Subpart N 63.346(b}(13» 

See Appendix 4 

3. Other Monitoring and/or 1. Inspect for proper operation of the tensionmeter or stalagmometer at least once a quarter 

Recordkeeping following manufacturers recommendations. The inspection record shall take the fonn of a 

checklist and shall identifY the device inspected, the date of inspection, a brief description 

of the working condition of the device during the inspection, and any actions taken to 

correct deficiencies found during the inspection. 

(40 CFR 63 Subpart N 63.346(b)(I» 

2. Permittee shall monitor and record pressure drop across each mesh pad mist eliminator 

on a weekly basis. . (R336.1213(J» 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

1. Parameter to be NA 

TestedlRecorded 

2. Method/Analvsis NA 

3. Frequency and Schedule NA 

of TestinwRecordkeeping 

IV. REPORTING 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. 

(R336. 1213(3)( c}(U» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July 1 to December 31 and September 15 for reporting period January 

1 to June 30. (R336.1213(3)(c:)(l» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

The following is a summary of additional reporting requirements pursuant to 40 CFR 63 

Subpart N. 

4. Notification of construction or reconstruction. (40 CFR 63 Subpart N 63.345(b» 

5. Notification of compliance status. (40 CFR 63 Subpart N 63.347(e» 

6. Compliance status reports for major sources. (40 CFR 63 Subpart N 63.347(g) 

See Appendix 8 

V. OPERATIONAL PARAMETERS 

1. Surface tension in each of the decorative chromium electroplating tank baths shall not exceed 45 dynes/cm during tank 

operation. (40 CFR 63 Subpart N 63.342(d)(2» 

2. At all times, including periods of startup, shutd0"!'1l, and malfunction, owners or operators shall operate and maintain any 

affected source, including associated monitoring equipment, in a manner consistent with good air pollution control practices, 

consistent with the operation and maintenance plan. (40 CFR 63 Subpart N 63.342(1)(1)(1» 

3. Pennittee shall not operate the decorative chrome plating tanks unless the mesh pad mist eliminators are installed and 

operating properly. (R336.1910) 

4. Malfunctions shall be corrected as soon as practical after their occurrence in accordance with the operation and maintenance 
Page: 23 of 65 

TABLE E-l.3 EG-CBROMETANK32 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

plan. (40 CFR 63 Subpart N 63.342 (I) (1)(ii» 

5. Pennittee shall not operate this emission unit unless the mesh pad mist eliminator is operating properly with a pressure drop 

across the eliminator within the ranR;e detennined under VI. OTHER REQUIREMENTS. 0036.1910) 

VI. OTHER REQUIREMENTS 

1. Pennittee shall implement the Operation and Maintenance Plan which waS submitted on June II, 1997. Any changes made 

to the Malfunction Abatement Plan dated June II, 1997 must have prior approval by the Shiawassee District Supervisor prior 

to implementation. (40 CFR 63 Subpart N 63.342 (I) (3» 

2. The Operation and Maintenance Plan shall include the following elements: 

(a) The plan shall specify the operation and maintenance criteria for the affected source, the air control method, and the 

process monitoring equipment (tensionmeter), and shall include a standardized checklist to document the operation and 

maintenance of this equipment. 

(b) The following work place standard shall be incorporated into the plan: 

(i) Follow manufacturers recommendations for calibration/use of the tensionmeter (calibrate prior to each use). 

(c) The plan shall specify procedures to be followed to ensure that equipment or process malfunction due to poor 

maintenance or other preventable conditions do not occur. 

(d) The plan shall include a systematic procedure for identifying malfunction of process equipment, monitoring 

equipment and for implementing corrective actions to address such malfunctions. 

(40 CFR Subpart N 63.342(1)(3)(1) 

3. If the Operation and Maintenance Plan fails to address or inadequately addresses an event that meets the characteristics of a 

malfunction at the time the plan is initially developed, the owner or operator shall revise the Operation and Maintenance Plan 

within 4S days after such an event occurs. The revised plan shall include procedures for operating and maintaining the process 

equipment, or monitoring equipment during similar malfunction events, and a program for corrective action for such events. 

(40 CFR 63 Subpart N 63.342(1)(3)(ii» 

4. The Pennittee shall implement a Preventative Maintenance Plan which requires inspection and maintenance of various 

system components related to air emissions. See Appendix 9. (R336.1911) 

5. Pennittee shall determine the proper pressure drop operating range for the mesh pad mist eliminator and submit results to the 

AQD District Supervisor within 30 days of the issuance date of this RO pennit. (R336.1213(3» 

* This requirement is state enforceable only. 
/. 

Page: 24 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.4 EGwCOPPERT ANKS 

EMISSION UNITIPROCESS GROUP RE~UIREMENTS 

EMISSION GROUP EG-COPPERTANKS One copper strike tank (#14) and five bright acid copper tanks 

(#15 through #19). 

Flexible Groupine ID FG-CHROMEPROCESS 

I. DESIGN PARAMETERS 

A. Pollution Control 6 Cyclone separators 

EQwDment 

B. StackIV ent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

Stack/Vent a. Minimum b. Maximum Exhaust Co Temperature d.AirFlow Applicable 

ID Heieht (feet) Dimension (inches) _eF) Rate (acfm) ReQuirement 

1. SVCHREXHSYS2 25 42 NA NA 0036.1201(3» 

C. Other Desil!D Parameters 

NA 

n. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usajte Rate 

NA NA 

B. Pollutant Maximum Emission Limit 

Sulfuric Acid See FG-CHROMEPROCESS. 

In. COMPLIANCE EVALUATION 

Records of all of the followin!! shall be maintained on flIe for a Deriod of 5 -'years. ~R 336.1213{3}{1)l{U» 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements in Part A 

I. Continuous Emission NA 

Monitoring (CEM) System and 

Recordkeepine 

2. Process Monitoring System 1. Permittee shall measure and record the bath surface tension in each tank on a weekly 

and Recordkeeping basis. (R336.1213(3» 

2. Pennittee shall determine and record the bath composition in each tank on a weekly basis. 

(R336.1213{3» 

3. Permittee shall measure and record the bath density in each tank on a weekly basis. 

0036.1213(3)) 

3. Other Monitoring andlor 1. Weekly records of sulfuric acid emission calculations in milligrams per cubic meter. 

Recordkeeping See Appendix 7. (R336.1213(3» 

2. Permittee shall monitor and record fan motor electric current for each cyclone on a 

weekly basis. (R336.1213(3» 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

1. Parameter to be NA 

TestedlRecorded 

2. Methodl Analysis NA 

3. Frequency and Schedule NA 

of Testine/Recordkeepine 

IV. REPORTING 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(U» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July I to December 31 and September 15 for reporting period January 1 

to June 30. (R336.1213(3)( c)(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 
Page: 25 of 65 

TABLE E-l.4 EG-COPPERTANKS 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

March 15. 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

See A»endix 8 

V. OPERATIONAL PARAMETERS 

1. Pennittee shall not operate this emission unit unless each cyclone is operating properly with fan motor electric current within 

the ranSte determined under VI. OTHER REQUIREMENTS. (R336.1910) 

VI. OTHER REQUIREMENTS 

I. Permittee shall determine the fan motor electric current range for each cyclone and submit results for approval to the AQD 

District Supervisor within 30 dayS of the issuance date of this RO permit (R336.1213(3» 

* This requirement is state enforceable only. 
Page: 26 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.5 EG-ACTIVATORTANKS 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EG·ACTIV ATORT ANKS One activator tank (#7), one accelerator tank (#9), and one 

electroless copper tank (# II). 

Flexible Groupin2 ID FG·CHROMEPROCESS 

I. DESIGN PARAMETERS 

A. Pollution Control Packed bed scrubber 

Equipment 

B. Stack/V ent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

Stack/Vent a. Minimum b. Maximum Exhaust Co Temperature d. Air Flow AppUcable 

ID Height (feeft Dimension Jinches) (oF) Rate(acfm) Requirement 

1. SVCHREXHSYS3 25 30 NA NA .. {R336. 1201 (3)) 

C. Other Desilln Parameters 

NA 

II. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit 

Hydrochloric Acid See FG·CHROMEPROCESS 

Fonnaldehyde See FG·CHROMEPROCESS 

ill. COMPLIANCE EVALUATION 

Records of all of the followln£ shall be maintained on me for a period of 5 years. (R 336.1213(3}(b)(bl) 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements In Part A 

I. Continuous Emission NA 

Monitoring (CEM) System and 

Recordket!pin~ 

2. Process Monitoring System 1. Permittee shall measure and record the bath surface tension in each tank on a weekly 

and Recordkeeping basis. (R336. 12 13(3» 

2. Pennittee shall detennine and record the bath composition in each tank on a weekly basis. 

(R336.1213(3» 

3. Permittee shall measure and record the bath density in each tank on a weekly basis. 

(R336.1213(3» 

3. Other Monitoring and/or 1. Weekly records of hydrochloric acid emission calculations in milligrams per cubic meter. 

Recordkeeping Hydrochloric acid emissions from this process and EG·NEUTRAlLIZERT ANKS will be 

combined in order to determine compliance with hydrochloric acid limit specified in FG· 

CHROMEPROCESS. See Appendix 7. (R336.1213(3» 

2. Weekly records offormaldehyde emission calculations in milligrams per cubic meter. 

See Appendix 7. (R336.1213(3» 

3. Pennittee shall monitor and record pressure drop across the packed bed scrubber on a 

weekly basis. (R336.1213(3» 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

1. Parameter to be NA 

TestedIRecorded 

2. Method/Analysis NA 

3. Frequency and Schedule NA 

of TestinWRecordkeeping 

IV. REPORTING 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(ll» 
Page: 27 of 65 

TABLE E-l.5 EG-ACTIV ATORT ANKS 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July I to December 31 and September 15 for reporting period January 1 

to June 30. (R336.1213(3)(c)(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213( 4)( c» 

See Appendix 8 

V. OPERATIONAL PARAMETERS 

I. Pennittee shall not operate this emission unit unless the packed bed scrubber is operating properly with a pressure drop 

across the scrubber within the range determined under VI. OTHER REQUIREMENTS. (al36.1910) 

VI. OTHER REQUIREMENTS 

1. Pennittee shall detennine the proper pressure drop operating range for the packed bed scrubber and submit results for 

approval to the AQD District Supervisor within 30 days of the issuance date of this RO pennit. (R336.1l13(3» 

* This requirement is state enforceable only. 
Page: 28 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-l.6 EG-NEUTRALIZERTANKS 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EG-NEUTRAIUZERT ANKS One neutralizer tank (#5) and one copper and nickel strip 

tank_(#391 

Flexible Grouping ID FG-CHROMEPROCESS 

I. DESIGN PARAMETERS 

A. Pollution Control Packed bed scrubber 

Equipment 

B. Stack/Vent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

Stack/Vent a. Minimum b. Maximum Exhaust Co Temperature d. Air Flow AppUcable 

ID Heieht (feet) Dimension (Inches) (oF) Rate (acfm) Requirement 

1. SVCHREXHSYS4 25 30 NA NA 0036.1201(3» 

C. Other Desian Parameters 

NA 

ll. MATERIAL VSAGElEMISSION LIMITS 

A. Material Maximum Usaee Rate 

NA NA 

B. Pollutant Maximum Emission Limit 

Hydrochloric Acid See FG·CHROMEPROCESS 

III. COMPLIANCE EVALUATION 

Records of aU of the following shall be maintained on me for a ~eriod of 5 ~ean. (R 336. 1213(3)(b)(b,» 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements In Part A 

1. Continuous Emission NA 

Monitoring (CEM) System .and 

Recordkeeping 

2. Process Monitoring System I. Permittee shall measure and record the bath surface tension in each tank on a weekly 

and Recordkeeping basis. (R336.1213(3» 

2. Permittee shall determine and record the bath composition in each tank on a weekly basis. 

(R336.1213(3» 

3. Permittee shall measure and record the bath density in each tank on a weekly basis. 

(R336.1213(3» 

3. Other Monitoring and/or I. Weekly records of hydrochloric acid emission calculations in milligrams per cubic meter. 

Recordkeeping Hydrochloric acid emissions from this process and EG-ACTIV ATORT ANKS will be 

combined in order to determine compliance with hydrochloric acid limit specified in FGCHROMEPROCESS. See Appendix 7. (R336.1213(3» 

2. Permittee shall monitor and record pressure drop across the packed bed scrubber on a 

weekly basis. (R336.1213(3)) 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements In Part A 

1. Parameter to be NA 

TestedlRecorded 

2. Method/Analysis NA 

3. Frequency and Schedule NA 

of Testina/Recordkeepine 

IV. REPORTING 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(ii» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July I to December 31 and September 15 for reporting period January 1 

to June 30. (R336.1213(3)( c )(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 
Page: 29 of 65 

TABLE E-l.6 EG-NEUTRALIZERTANKS 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

Permit Nwnber: 199600451 

Expiration Date: June 2, 2004 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4}(c» 

See Appendix 8 

V. OPERATIONAL PARAMETERS 

I. Pennittee shall not operate this emission unit unless the packed bed scrubber is operating properly with a pressure drop 

across the scrubber within the range determined under VI. OTHER REQUIREMENTS. (R336.1910) 

VI. OTHER REQUIREMENTS 

1. Pennittee shall detennine the proper pressure drop operating range for the packed bed scrubber and submit results for 

approval to the AQD District SlJPer!isor within 30 days of the issuance date of this RO permit. (R336.1213(3)) 

* This requirement is state enforceable only. 
Page: 30 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE E-t.' EG-CHROMEETCH 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

EMISSION GROUP EO-CHROMEETCH One pre-etch tank (#1) and one etch tank (#2). 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. PoUutlon Control Dry mesh pad scrubber on or after May I, 1999. 

Equipment Mist eliminator before May I, 1999. 

B. Stack/V ent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

Stack/Vent a. Minimum b. Maximum Exhaust c. Temperature d.Air Flow AppUcable 

ID Height (feet) Dimension (inches) (oF) Rate (acfm) Requirement 

1. SVCHREXHSYS5 25 26 NA NA (R336.1201(3» 

C. Other DesiRn Parameters 

NA 

D. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usatte Rate 

NA NA 

B. PoUutant Maximum Emission Limit 

Hexavalent Chromium 1. a) On and after May I, 1999: 11.5 micrograms per cubic meter, corrected to 70 0 F and 

29.92 inches Hg. (R336.1224, R336.1225»* 

b) Before May I, 1999: See EO-CHROMET ANK32. 

Sulfuric Acid 2. a) On and after May I, 1999: 6.05 milligrams per cubic meter, corrected to 70 0 F and 

29.92 inches Hg. (R336.1224, R336.1225»* 

b) Before May 1 1999: See FO-CHROMEPROCESS. 

UI. COMPLIANCE EVALUATION 

Records of aU of the foUowlnR shall be maintained on file for a period of 5 yean. (R 336.1213(3J(DJ(im 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements In Part A 

1. Continuous Emission NA 

Monitoring (CEM) System and 

RecordkeeJ)intt 

2. Process Monitoring System 1. Pennittee shall measure and record the bath surface tension in each tank on a weekly 

and Rec:ordkeeping basis. (R336.1213(3» 

2. Permittee shall detennine and record the bath composition in each tank on a weekly basis. 

(R336.1213(3» 

3. Pennittee shall measure and record the bath density in each tank on a weekly basis. 

(R336.1213(3» 

3. Other Monitoring and/or 1. Weekly records of sulfuric acid emission calculations in milligrams per cubic meter. See 

Rec:ordkeeping Appendix 7. (R336.1213(3» 

2. Weekly records of hexavalent chromium emission calculations in micrograms per cubic 

meter. See Appendix 7. R336.1213(3» 

3. Pennittee shall monitor and record pressure drop across the two stage mist eliminator on 

a weekly basis. (R336.1213(3» 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

I. Parameter to be NA 

TestedlRecorded 

2. Method/Analysis NA 

3. Frequency and Schedule NA 

of TestiniVRecordkeepinR 

IV. REPORTING 
Page: 31 of 65 

TABLE E-l.7 EG-CHROMEETCH 

EMISSION UNITIPROCESS GROUP REQUIREMENTS 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

Reports and Schedules I. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(U» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March IS 

for reporting period July I to December 31 and September IS for reporting period January I 

to June 30. (R336.1213(3)(c)(I» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15,2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

See Appendix 8 

V.OPERATIONALPARAMETERS 

I. On and after May I, 1999, Permittee shall not operate this emission unit unless the dry mesh pad scrubber is operating 

properly with a pressure drop across the eliminator within the range determined under VI. OTHER REQUIREMENTS. 

(R336.1910) 

VI. OTIlER REQUIREMENTS 

1. The Pennittee shall implement a Preventative Maintenance Plan which requires inspection and maintenance of various 

system components related to air emissions. See Appendix 9. (R336.1911) 

2. Pennittee shall determine the proper pressure drop operating range for the dry mesh pad scrubber and submit results for 

~roval to the AOD District S~ervisor by June I, 1999. (R336.1213(3» 

* This requirement is state enforceable only. 
Page: 32 of 65 

F. Flexible Grouping Requirements 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

The tables in Part F outline the applicable requirements for each flexible grouping listed in the Flexible Groupings Summary 

Table. The permittee is subject to the requirements for each flexible grouping in addition to the General Requirements in Part 

A and any other tenns and conditions contained in this RO permit. 

Each flexible grouping shall meet the design parameters, material usage/emission limitations, monitoring, recordkeeping, 

reporting and testing requirements, operational parameters, and any other requirements listed in Tables F-l.l through F-1.2 as 

well as other tenns and conditions specified in this RO pennit to assure compliance with all applicable requirements. The 

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

tables. The underlying applicable requirements for the material usage/emission limitations, monitoring, recordkeeping, 

reporting and testing requirements, operational parameters, and any other requirements are identified in parentheses. If a 

specific requirement type does not exist for the flexible grouping, NA (not applicable) has been used in the table. Those 

requirements which are enforceable by the state only are designated by an asterisk. 
Page: 33 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE F-l.l FG-CHROMEPROCESS 

FLEXIBLE GROUPING REQUIREMENTS 

FLEXIBLE GROUPING FG-CHROMEPROCESS Non chrome electroplating processes. 

Emission UnitlProeess Groups EG-COPPERT ANKS 

EG-ACTIV ATORT ANKS 

EG-NEUTRALIZERT ANKS 

I. DESIGN PARAMETERS 

A. PoUution Control 

Equipment 

B. StaekIV ent Parameters I Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise noted. 

StacklVent a. Minimum b. Maximum Exhaust Co Temperature d. Air Flow AppUcable 

ID Height (feet) Dimension (inches) (oF) Rate (aerm) Requirement 

NA NA NA NA NA NA 

C. Other Desl2n Parameters 

NA 

II. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usa2e Rate 

NA NA 

B. Pollutant Manmum Emission Limit 

Sulfuric acid 1. 4.65 milligrams per cubic meter, corrected to 70 OF and 29.92 inches Hg. 

(R 336.1901(a))* 

Hydrochloric acid 2. 4.65 milligrams per cubic meter, corrected to 70 OF and 29.92 inches Hg. 

(R336.901(a))* 

Fonnaldehyde 3. 1.02 milligrams per cubic meter, corrected to 70 OF and 29.92 inches Hg. (Tank #11 

only.) (R 336.1901(a»* 

IlL COMPLIANCE EVALUATION 

Records of all of tbe foUowin2 sball be maintained on me for a period of 5 Yean. (R 336.1213(3)(b)(U)) 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements in Part A 

1. Continuous Emission NA 

Monitoring (CEM) System and 

Recordkeepin2 

2. Process Monitoring System NA 

and Recordkeepin2 

3. Other Monitoring and/or NA 

Recordkeepin2 

B. TESTINGIRECORDKEEPING (R 336.1213(3» 

In Addition to General Requirements in Part A 

1. Parameter to be NA 

TestedlRecorded 

2. Metbod/Analysis NA 

3. Frequency and Schedule NA 

of Testing/Recordkeepin2 

IV. REPORTING 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1213(3)(c)(U» 

2. Semi-annual reporting of deviations pursuant to Condition 26 of Part A. Due March 15 

for reporting period July I to December 31 and September IS for reporting period January I 

to June 30. (R336.1213(3)(e)(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 
Page: 34 of 65 

TABLE F-l.l FG-CHROMEPROCESS 

FLEXIBLE GROUPING REQUIREMENTS 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

See Appendix 8 

V. OPERATIONAL PARAMETERS 

NA 

VI. OTHER REQUIREMENTS 

l. The Pennittee shall implement a Preventative Maintenance Plan which requires inspection and maintenance of various system 

components related to air emissions. See Appendix 9. (R336.1911) 

* This requirement is state enforceable only. 
Page: 35 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

TABLE F-l.l FG-COLDCLEANER 

FLEXIBLE GROUPING REQUIREMENTS 

FLEXIBLE GROUPING FG-COLDCLEANER- All new cold cleaners (placed into operation after 7/1179) that are 

exempt from NSR pennitting by R336.1281 (b) or R336.128S (r)(iv) and not required to be 

in compliance with the Halogenated Solvent Cleaner MACT standard. 

Emission UnitlProcess Groups EGCOLDCLEANERI&EGCOLDCLEANERl 

I. DESIGN PARAMETERS 

A. Pollution Control NA 

Equipment 

NA 

B. StackIV ent Parameten INA 

StacklVent a. Minimum b. Maximum Exhaust c. Temperature d. Air Flow AppUeable 

ID Heieht (feet) Dimension (inches) fl1 Rate (aefm) Requirement 

NA NA NA NA NA NA 

C. Otber Design Parameters 

1. Equipment must meet one of the following parameters: 

(a) Cold Cleaner with air/vapor interface of 10 square feet or less. (R336.1281(h» 

(b) Equipment for the cleaning of metal which has process emissions released only into the general in-plant environment. 

(R336.128S(r)(iv» 

2. A cover shall be installed and the cover shall be closed whenever parts are not being handled in the cleaner. 

(R336.1707(3)(a» 

3. A device shall be available for draining cleaned parts. (R336.1707(3b» 

4. The cover shall be mechanically assisted if the Reid vapor pressure of the solvent is more than 0.3 psis, the solvent is agitated 

or the solvent is heated. (R336.1707(3)(a)) 

U. MATERIAL USAGElEMISSION LIMITS 

A. Material Maximum Usaee Rate 

NA NA 

B. Pollutant Maximum Emission Limit 

NA NA 

IlL COMPLIANCE EVALUATION 

Records of aU of tbe following shall be maintained on me for a period of 5 yean. (R 336.1213(3)(b)(U) 

A. MONITORINGIRECORDKEEPING (R 336.1213(3» 

In Addition To General Requirements in Part A 

1. Continuous Emission NA 

Monitoring (CEM) System and 

Recordkeepin2 

2. Process Monitoring System NA 

and Recordkeepin2 

3. Otber MonitOring and/or 1. The name, make/model, size, description, date of installation and air/vapor interface area 

Recordkeeping of the machine(s) and type of solvent (including VOC content and Reid vapor pressure) shall 

be maintained for each cold cleaner. (R336.1213(3» 

2. If the solvent is heated, as noted in R336.1707(2), monitor and record the solvont 

temperature on a monthly basis, during peak operating conditions. (R336.1213(3» 

3. Option chosen to comply with R336.l707(2) (as noted in Operational Parameters 

Section), if applicable. (R336.1213(3» 

B. TESTlNGIRECORDKEEPlNG (R 336.1213(3» 

In Addition to General Requirements In Part A 
Page: 36 of 65 

TABLE F-l.2 FG-COLDCLEANER 

FLEXIBLE GROUPING REQUIREMENTS 

1. Parameter to be NA 

TestedlRecorded 

2. Method/Analysis NA 

3. Frequency and Schedule NA 

of Testing/Recordkeepina 

IV. REPORTING 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 27 of Part A. (R336.1l13(3)(c)(il» 

2. Semi-annual reporting of deviations pursuant tQ Condition 26 of Part A. Due March 15 

for reporting period July 1 to December 31 and September 15 for reporting period January 1 

to June 30. (R336.1213(3)(c)(i» 

3. Annual certification of compliance pursuant to Conditions 31 and 32 of Part A. Due 

March 15, 2000 for calendar year 1999 and each March 15 for the previous calendar year 

thereafter. (R336.1213(4)(c» 

See Appendix 8 

V.OPERATIONALPARAMETERS 

1. Waste solvent shall be stored only in closed containers, unless the stored solvent is demonstrated to a safety hazard and is 

disposed so that not more than 20%, by weight, is allowed to evaporate into the atmosphere. 

(R336.1707(3)(c» 

2. A person responsible for the provisions of this rule shall develop written procedures for the operation of such provisions, 

and such procedures shall be posted in an accessible, conspicuous location near the cold cleaner. (R336.1707(4» 

3. Parts shall be drained not less than 15 seconds or until dripping ceases. (R336.1707(3)(b» 

4. The cold cleaner shall not be operated using a solvent having a Reid vapor pressure of more than 0.6 psia or heated above 

120 degrees Fahrenheit, unless at least one of the following is met: (R336.1707(2» 

(a) The cold cleaner is designed such that the ratio of the freeboard height to the width of the cleaner is equal to or greater 

than 0.7. (R336.1707(2)(a» 

(b) The solvent bath is covered with water if the solvent is insoluble and has a specific gravity of more than 1.0. 

(R336.1707(2)(b» 

(c) The cold cleaner is controlled by a carbon adsorption system, condensation system. or other method of equivalent control 

approved by the AQD. (R336.1707(2)(c» 

5. Each cold cleaning machine shall be properly maintained. (R336.1213(3» 

VI. OTHER REQUIREMENTS 

1. The provisions of R336.1707 do not apply to cold cleaning machines that are required to be in compliance with 40 CFR Part 

63 Subpart T (National Emission Standards for Halogenated Solvent Cleaning (MACT Standard)). (R336.1707(S» 

* This requirement is state enforceable only. 
Page: 37 of 65 

G. Non-Applicable Requirements 

Pennit Number: 199600451 

Expimtion Date: June 2, 2004 

At the time of RO pennit issuance, the AQD has detennined that no non-applicable requirements have been identified for 

incorpomtion into the pennit shield provision set forth in Part A (Conditions 33 through 36) of this RO permit pursuant to 

R 336. 1213(6)(a)(ii). 

Appendices 

Appendix 1. Abbreviations Used in This Permit 

The following is an alphabetical listing of all abbreviations/acronyms used in this RO pennit. 

acfin 

AQD 

CAA 

CEM 

CFR 

DEQ 

EPA 

of 

HCFC 

HVLP 

ID 

MVAC 

NA 

RMP 

RO 

SRN 

Actual cubic feet per minute 

Air Quality Division 

Fedeml Clean Air Act 

Continuous Emission Monitor(ing) 

Code of Fedeml Regulations 

Michigan Department of Environmental Quality 

United States Environmental Protection Agency 

Degree Fahrenheit 

Hydrochlorofluorocarbon 

High Volume Low Pressure 

Identification (Number) 

Motor vehicle air conditioner 

Not applicable 

Risk Management Plan 

Renewable Operating 

State Registmtion Number 

Appendix 2. Schedule of Compliance 

The permittee has certified that this source is in compliance with all applicable requirements as of the date of issuance of this 

RO permit and the pennittee shall continue to comply with all applicable requirements listed in this RO pennit. A detailed 

Schedule of Compliance is not required. (R 336. 12I3(4)(a), R 336.1119(a)(ii» 

Appendix 3. Monitoring Requirements 

Specific monitoring requirement procedures, methods or specifications are detailed in Part A or the appropriate Requirement 

Tables. Therefore, this appendix is not applicable. 
Page: 38 of 65 

Appendix 4. Recordkeeping 

Permit Number: 19960045 I 

Expiration Date: June 2, 2004 

The permittee shall use the following approved formats and procedures for the recordkeeping and/or reporting requirements 

referenced in Tables E-1.l, E-l.l, aod F-l.l. 

I. For EG-I.I and EG-I.2 (separate records shall be kept for each line), the Permittee shall record the following infonnation: 

On a daily basis: 

I. Record the identification of the applicable coating category for each coating used; 

2. Record the number of hours of operation; 

3. Record the number of gallons of each coating/reducer used; 

4. Record the VOC content of each coating batch is pounds per gallon (plus water) as applied. (This will be 

generated from on site U.S. EPA Method 24 testing of coating batches.) 

5. Record the VOC content of each coating batch is pounds per gallon (minus water) as applied. (This will be 

generated from on site U.S. EPA Method 24 testing of coating batches.) 

6. Record the daily volume-weighted average VOC content in pounds per gallon, minus water, as applied, for each 

coating category; 

7. The VOC emission rate in pounds per hour and pounds per calendar day: and 

8. IfVOC content in pounds per gallon (Plus water and minus water) as applied is determined from Manufacturer's 

formulation data then the following additional data must be maintained: 

a) Current listing of the formulation data for each. 

b) Mixing ratio of each coating and reducer. 

c) VOC content in pounds per gallon of coating (minus water) as received and as applied for each coating used. 

d) VOC content in pounds per gallon of coating (Plus water) as applied, for all water based coatings. 

On a monthly basis: 

9. Record the amount in gallons/month and VOC content of all purge solvent and/or cleanup solvents used and 

reclaimed. 

2. For FGCHROMET ANKS, the Permittee shall use the Fume Suppressant Monitoring Data Record Form, and the Daily 

Process Operations Record form. 
Page: 39 of 65 

Pennit Number: 199600451 

Expimtion Date: June 2, 2004 

FUME SUPPRESSANT MONITORING DATA RECORD 

This InfonnatJon is required by Article II, Part 55 (Air Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean 

Air Act of 1990. Failure to provide this Infonnatfon may result In penalties and/or Imprisonment. 

Applicable Rule: 40 CFR Part 63, Subpart N-National Emission Standards for Chromium Emissions from Hard 

and Decorative Chromium Electroplating and Chromium Anodizing Tanks. 

NOTE: Use this form to document the additions of fume suppressants (i.e., wetting agents and foam blankets) and 

the measurements of surface tension and foam blanket thickness. Records must be maintained on file for five 

years and made available upon request for inspection by the Michigan Department of Environmental Quality. 

/1. Plant Name 12. Plant LocaUon 

Fume Suppressant Addition of Wetting Agent or Foam Surface Tension Measurement 

(dynes/cm) or Foam Blanket Thickness (wetting agent or foam blanket) Blanket Cinches) 1 

Date TIme 

1 Surface tension and foam depth measurements must be initially taken once every 4 hours and every hour, 

respectively. Once 40 hours of measurements have passed without any exceedances from the appropriate 

standard (Le., surface tension s 45 dynes/cm or minimum foam blanket thickness of 1 inch), measurements can 

be reduced to 8 hours and 4 hours, respectively. Following another 40 hours of compliance, measurements can 

be reduced to 40 hours and 8 hours for surface tension and foam depth, respectively. 

THIS IS A MASTER COPY. PLEASE MAKE COPIES FROM THIS MASTER COPY. 
Page: 40 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

3. EXCESS EMISSIONS. Record date, be~inninR and endin~ time of each period of emissions exceedinR emission limit 

Excess emissions occur when the surface tension exceeds 45 dynes/cm if using wetting agents or when the foam blanket 

thickness is less than 1 inch. Describe the corrective actions taken durin!l periods of excess emissions. 

Date I Starting Time I Ending Time I Initials Date I Starting Time I Ending Time J Initials 

Corrective Action Taken: Corrective Action Taken: 

Date I Starting Time I Ending Time I Initials Date 1 Starting Time T Ending Time I Initials 

Corrective Action Taken: Corrective Action Taken: 

Date I Starting Time I Ending Time I Initials Date I Starting Time I Ending Time I Initials 

Corrective Action Taken: Corrective Action Taken: 

Date I Starting Time I Ending Time I Initials Date 1 Starting Time 1 Ending Time I Initials 

Corrective Action Taken: Corrective Action Taken: 
Page: 41 of 6S 

DEQ 

• 

Pennit Number: 199600451 

Expiration Date: June 2. 2004 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUAlllY, AIR QUALIlY DIVISION 

DAILY PROCESS OPERATIONS RECORD 

This in(onnaUon Is required by Article II, Part 55 (Air Pollution Control) o( P.A. 451 o( 1994, as amended, and the Federal Clean 

Air Act o( 1990. Failura to provide this in(onnation may result in penalUes and/or imprisonment. 

Applicable Rule: 40 CFR Part 63, Subpart N-National Emission Standards for Chromium Emissions from Hard 

and Decorative Chromium Electroplating and Chromium Anodizing Tanks. 

All affected facilities must maintain records of the amount of time each affected tank is in operation. If an affected 

facility is using a nonresettable ampere-hr meter to demonstrate that it is a small, hard chromium electroplating 

facility, records of the actual rectifier usage (amp-hrs) must be maintained. Records must be maintained on file for 

fIVe years and made available upon request for inspection by the Michigan Department of Environmental Quality. 

1. Plant Name and Location 

Tank 10# Date Hours of Operation 

THIS IS A MASTER COPY. PLEASE MAKE COPIES FROM THIS MASTER COPY.. 

EQP 5711 (04/97) 
Page: 42 of 65 

Appendix S. Testing Procedures 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

Specific testing requirement plans, procedures, and averaging times are detailed in the appropriate Requirement Tables. 

Therefore, this appendix is not applicable. 

Appendix 6. Voided Permits 

Except as provided in Section 91(2) of Act 306 of the Public Acts of 1969, as amended, being §24.291(2) of the Michigan 

Compiled Laws, and known as the Administrative Procedures Act, the Permits to Install and Permits to Operate listed below 

shall be void as of the effective date of this RO permit. A petition on this RO permit may be filed pursuant to the 

Administrative Procedures Act, as provided in Section 5506(14) of Act 451 of the Public Acts of 1994, amended, being 

§324.5S06(14) of the Michigan Compiled Laws, and known as the Natural Resources and Environmental Protection Act. If 

such petition involves conditions from one or more of the aforementioned Permits to Install andlor Permits to Operate, said 

permits remain in effect until final action is taken by the DEQ at the conclusion of the appeals process. At the point where said 

permits are voided, all processes and process equipment at this stationary source will be covered by and subject to the 

requirements of this RO permit. 

Pennltto Corresponding Emission Unit 

InstaUlOperate Description of Equipment or 

Number FledbIe Groupin2 m 

lO53-90A Exterior automotive plastic parts coating line. EO-P AINTLINE# 1 

157-94 Exterior automotive plastic parts coating line. EO-P AINTLINE#2 

177-90A Decorative chromium plating process. EO-CHROMET ANK32. 

FO-CHROMEPROCESS 
Page: 43 of 65 

Appendix 7. Emission Calculations 

Pennit Nwnber: 199600451 

Expiration Date: June 2, 2004 

The permittee shall use the following calculations in conjunction with monitoring. testing or recordkeeping data to detennine 

compliance with the applicable requirements referenced in Tables E-l.l, E-1.2, E-l.3, E-l.4, E-l.5, E-l.6, E-1.7 and F-l.l 

For E-l.l and E-1.2 

VOC, less water, less exempt solvent (lbs/gal, as appUed). Calculation using U.S. EPA Method 24: 

rooo -% Wt. Solids - %Wt. Water - %Wt. Exempt Solvent> x Density of coating] 

100-[( %Wt. Water + %Wt. Exempt Solvent ) x Density of Coating] 

Density of Water Density of Exempt Solvent 

Where: 

% Wt. Solids is obtained from Method 24 

%Wt. Water is obtained from Method 24 

%Wt. Exempt solvent from fonnulation as applied 

Density of Exempt Solvent from literature 

Density of Water from literature 

Density of coating from U.S. EPA Method 24 

VOC, plus water (lbs/gal as appUed). Calculation using U.S. EPA Method 24: 

(100% - %Wt. Nonvolatile) x Density of Coating 

Where: 

%Wt. Nonvolatile is obtained from Method 24 

Density of coating from u.S. EPA Method 2 

Dally volume-weighted average VOC content in pounds per gallon, minus water, as appUed, for each coating category: 

i-n 

W= :rcV x Yli 

;-1 LVi 

;"1 

where: 

W = Daily volume weighted average pounds ofVeC per gallon of coating (minus water), as applied. 

V = Gallons of coating (minus water), as applied, used during the averaging period (ie. one day). 

Y = Pounds of vec per gallon of coating (minus water), as applied. 

i = Individual coatings applied during the averaging period. 

VOC Emission Rate Calculation (lbs/day): 

Pounds VeC/day = = 

where: 

V = Gallons of coating(minus water), as applied, used during the reported day. 

Y = Pounds of VOC per gallon of coating (minus water), as applied, used during the reported day. 

i = Individual coatings applied during the averaging period. 

VOC Emission Rate Calculation (Ibs/hr): 

Pounds VOC/hour = Ibs VeC/1 day x 1 day/(Actual daily hours of operation) 

VOC Emission Rate Calculation (tons/month): 

.i-m 
Page: 44 of 65 

Tons VOe/month = [L(lbs VOClday);] x 1 tonl2000 Ibs 

';-1 

Where: 

j = The day of the month 

m = Number of days during the reported month. 

For E-1.3, E-I.4, E-1.5, E-1.6, E-1.7 and F-l.l 

Pennit Nwnber: 199600451 

Expiration Date: June 2, 2004 

Weekly Sulfuric Acid, Hydrochloric Acid, Formaldehyde, and Hexavalent Chromium Emission Compliance 

Calculations: 

1) Measure surface tension on a weekly basis from tanks #1, #2, #14, #15, #16, #17, #18, and #19. 

2) Measure Specific Gravity of solution on a weekly basis from tanks #1, #2, #14, #15, #16, #17, #18, and #19. 

3) Record concentration of sulfuric acid solution on a weekly basis from tanks # I, #2, # 14, #15, # 16, # 17, # 18, and # 19. 

4) Record concentration of hydrochloric acid solution on a weekly basis from tanks #5, #7, and #9. 

5) Record concentration of formaldehyde solution on a weekly basis from tank # II. 

6) Record concentration of chromic acid solution on a weekly basis from tanks #1, #2. 

7) Input the above data into following spreadsheets in order to calculate weekly emissions. 

Note: Sulfuric acid emission from tanks #1, #2, #14, #15, #16, #17, #18, and #19 are due to 1) electrical current loss, and 2) air 

agitation. Since the process cathode efficiency is approximately 98%, current loss is negligible; consequently sulfuric acid mist 

emissions due to electrical current loss is considered to be negligible. Mist generated due to air agitation can be estimated using 

Equation 4, AP-42, Section 12.20.2. Hydrochloric acid and formaldehyde emissions can be estimated using the same equation. 

Chromium (VI) emissions from the etch tanks are mainly due to air agitation (or air sparging). No electrical current is passed 

through these tanks and gassing caused by current loss is not a factor. Calculations is started first by calculating the chromic 

acid (cr03) emissions using the approach described for sulfuric acid. Cr(VI) emissions are then calculated by multiplying the 

cr03 emission rate by the ratio of the chromic acid and Cr (VI) molecular weights. 
Page: 45 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

FOR Fe-CHROME PROCESS-SULFURIC ACID CALCULATIONS: 

a = (3.60335"-5*62.4*S.G.*32.2*R"2)/o 

E2 = (1.9*olR)*«(1-2*a+9*a"2),,0.5+(a-1 »/«1 + 3*a)-(I-2*a+9*a"2)"O.5»"0.5 

Tank #14 

Surface Tension = 

Bubble Radius = 

Mixing Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Conc. of H1SO .. = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution = 

(InputJ dynes/em 

IJlbf7ft 

0.25 in 

0.35 eu ftlmin - sq ft 

54 sq ft 

(InputJ 

(InputJ Ib/gal 

( J oz.lgal 

[] 

[ ] grainS/cu ft 

[ ] grains/min 

[ ] Ib/cu ft 

[] Ib/gal 

[] wt. % 

[ ] grains/min 

[ J pounds/min 

Total Uncontrolled H1S04 Emissions 

Emaust Air Flow 

UncontroUed H1SO .. Emaust Conc. 

Cyclone Control Efficiency 

Controlled H2SO.. Emissions 

from tanks #14 - #19 

Tanks #15 through #19 

Surface Tension = 

Bubble Radius = 

Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Conc. of H1SO .. = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution = 

For all five tanks = 

[ ] pounds/min 

26080 scrm, corrected to 70 F 

26080 actin, @ T = 70 F 

[ ] pounds/cu ft 

[] mglml 

40% 

(Inputl dynes/em 

IJlbf7ft 

0.25 in 

0.35 eu ftlmin - sq ft 

54 sq ft 

[InputJ 

(Inputllb/gal 

( J oz.lgal 

[ ] 

[ ] grains/cu ft 

[ ] grains/min 

[ ] Ib/cu ft 

[] Ib/gal 

[]wt.% 

[ ] grainslmin 

[ J pounds/min 

[ ] pounds/min 
Page: 46 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

FOR EG-CHROMEETCH-SULFURIC ACID CALCULATIONS: 

Tank #1 

Surface Tension = 

Bubble Radius == 

Mixing Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Cone. of H2SO .. = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution == 

Weight % H2SO .. = 

HzSO .. Emissions = 

Exhaust Air Flow 

(Input) dynes/cm 

1)lbfjlft 

0.25 in 

0.35 cu ftlmin - sq ft 

45 sq ft 

(Input) 

(Input) Ib/gal 

( ) gil 

() N 

[] 

[ ] grainslcu ft 

[] grains/min 

[ ] Ib/cu ft 

[ ] Ib/gal 

[]wt.% 

[ ] grains/min 

[ ] pounds/min 

Exhaust Demister Control Efficiency 

Controlled HzSO.. Emissions 

from Tanks #1 and #2 

Permit Limit 

Tank #2 

Surface Tension == 

Bubble Radius = 

Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Cone. of H2SO .. = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution = 

Weight % H2SO .. = 

H2SO .. Emissions = 

[ ] pounds/min 

13800 scfin, @ T == 70 F 

[ ] pounds/cu ft 

[] mglm3 

97% 

6.05 109! 103 

(Input) dynes/cm 

Illbfjlft 

0.25 in 

0.35 cu ftlmin - sq ft 

85.5 sq ft 

(Input) 

(Input) Ib/gal 

( ) gil 

()N 

[ ] 

[ ] grains/cu ft 

[ ] grains/min 

[ ] Ib/cu ft 

[ ] Ib/gal 

[]wt.% 

[ ] grains/min 

[ ] pounds/min 
Page: 47 of 65 

FOR FG-CHROMEPROCESS - HYDROCHLORIC 

ACID EMISSIONS CALCULATIONS: 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

E2 = (1.9*0'1R)·«(1-2·a+9·a"2)"0.5+(a-1 »/« 1+ 3·a)-(1-2·a+9·a"2)"0.5»"0.5 

a = (3.60335"-5*62.4·S.0. ·32.2·R"2)/0' 

Surface Tension = 

Bubble Radius = 

Mixing Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Conc. of HCI = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution = 

Weight % HCl 

HCI Emissions 

Total HCl Emissions 

Exhaust Air Flow 

Tank #7 

[Inputl dynes/em 

[ Ilbflft 

0.25 in 

0.35 eu ftlmin - sq ft 

45 sq ft 

[Input) 

(Input) Ib/gal 

[ ) gil 

[) N 

( ) 

( ) grains/eu ft 

( I grains/min 

( )Ib/eu ft 

( ] lb/gal 

[) wt. % 

[ I grains/min 

(I pounds/min 

Packed Bed Scrubber Control Efficiency 

Controlled HCI Emissions 

From Tanks #7 & #9 

Tank #f) 

Surface Tension = 

Bubble Radius = 

Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

ConCo of HCI = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Solution = 

Weight%HCI 

HCI Emissions 

[) mgfmin 

11158 sefiD. @ T = 70 F 

12000 aefiD. @ T = 110 F 

95 % 

(I mgfmin 

[Input) dynes/em 

( )lbflft 

0.25 in 

0.35 eu ftlmin - sq 

ft 

22.5 sq ft 

(Input) 

[Input] Ib/gal 

[) %v/v 

[ ) 

II grains/eu ft 

( ] grains/min 

[)Ib/eu ft 

[ lib/gal 

()wt.% 

[ ) grains/min 

[ I pounds/min 
Page: 48 of 65 

Surface Tension = 

Bubble Radius = 

Mixing Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Cone. of HCI = 

Outputs: 

Tank #5 

(Inputl dynes/em 

[ Ilbflft 

0.25 in 

0.35 eu ftlmin - sq ft 

22.5 sq ft 

(Inputl 

(Inputllb/gal 

[ ] gil 

(] N 

a = (I 

E2 = [ I grains/eu ft 

Mist Emissions = I ] grains/min 

Density of Solution = [I Ib/eu ft 

[] Ib/gal 

Weight % HCI [I wt. % 

HCI Emissions II grains/min 

[ I pounds/min 

[] mg/min 

Exhaust Air Flow 10759 selin, @ T = 70 

F 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

11368 aelin, @ T = 100 F 

Packed Bed Scrubber 95 % 

Control Efficiency 

Controlled HCI Emissions II mg/m3 

Overall Exhaust air flow 

Overall Emission 

Overall Concentration 

Permit Limit 

21917 scfin 

mg/min 

II mglm3 

4.65 mglm3 

(Combine Exhaust from Tanks #5, #7, & #9) 

(Combine Tanks #5, #7, & #9) 
Page: 49 of 65 

FOR FG-CHROMEPROCESS 

EMISSIONS CALCULATIONS: 

FORMALDEYHDE 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

E2 = (l.9*alR)*(((1-2·a+9·a"2)"O.5+(a-1 »/« I +3 *a)-(1-2 *a+9*8"2)"0.5»,,0.5 

a = (3.60335"-5*62.4*S.G. *32.2*R"2)1a 

Surface Tension = 

Bubble Radius = 

Mhlng Air Rate = 

Tank Surface Area = 

S.G. of Soludon = 

Conc. of RCRO = 

Outputs: 

a= 

E2= 

Mist Emissions = 

Density of Soludon = 

Weight % RCRO 

RCRO Emissions 

Total RCRO Emissions 

Exhaust Air Flow 

RCRO Exhaust Conc. 

Tank #11 

Packed Bed Scrubber Control 

Effidency 

Controlled HCRO Emissions 

Emission Limit 

(Input) dynes/em 

() Ibflft 

0.25 in 

0.35 eu ftlmin - sq ft 

45 sq ft 

[Input) 

() Ib/gal 

() gil 

( I 

(I grains/eu ft 

( I grains/min 

(I Ib/eu ft 

(I Ib/gal 

(I wt. % 

( ] grains/min 

( J pounds/min 

( I pounds/min 

11158 selin, @ T = 70 F 

12000 aelin, @T= 110 F 

[ ] pounds/cu ft 

(I mglm3 

95% 
Page: 50 of 65 

FOR FG-CHROMEPROCESS - HEXAVALENT 

CHROMIUM EMISSIONS CALCULATIONS: 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

E2 = (l.9*0'/R)*«(1-2*a+9*aI\2)"0.5+(a-l»/(1+3*a)-(I-2*a+9*aI\2)"0.5»A0.5 

a = (3.603351\-5*62.4*8.0. *32.2*RI\2)/0' 

Tank #1 

Surface Tension = 

Bubble Radius = 

Mixing Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Cone. of Cr03 = 

[Inputl dynes/em 

( Ilbflft 

0.25 in 

0.35 eu ftlmin - sq ft 

45 sq ft 

[Inputl 

(Input) Ib/gal 

( I oz.lgal 

Tank #2 

Surface Tension = 

Bubble Radius = 

Air Rate = 

Tank Surface Area = 

S.G. of Solution = 

Cone. of Cr03 = 

(Input) dyneslem 

Illbflft 

0.25 in 

0.35 cu ftlmin - sq ft 

85.5 sq ft 

[Input) 

Iinputllb/gal 

II oz.lgal 

Outputs: Outputs: 

a= [ I 

E2= ( I grains/eu ft 

Mist Emissions = ( I grains/min 

Density of Solution = ( I Ib/eu ft 

( ) Ib/gal 

Weight % Cr03 = II wt. % 

Cr03 Emissions = [ I grains/min 

( I pounds/min 

Cr Emissions = II pounds/min 

Total Cr Emissions 

Exhaust Air Flow 

Cr Exhaust Cone 

Exhaust Demister Control Efficiency 

Controlled Cr Emissions 

EG-CHROMEETCH Emission Limit 

a = (I 

E2 = [ ) grains/eu ft 

Mist Emissions = 

Density of Solution = 

Weight % Cr03 = 

CrOJ Emissions = 

Cr Emissions = 

pounds/min 

13800 selin, @ T = 70 F 

9046 aefin, @ T = 135 F 

[ I pounds/eu ft 

[) l1g1m3 

97% 

II grains/min 

[ ) Ib/eu ft 

( lib/gal 

[I wt. % 

II grains/min 

[ ) pounds/min 

( I pounds/min 
Page: 51 of 65 

I'ennll Numoer: J YYOUV4:> J 

Expiration Date: June 2, 2004 

FOR EG-CHROMETANK32 - HEXAVALENT CHROMIUM EMISSIONS CALCULATIONS: 

For surface tensions at or below 45 dynes/em, the chromium (VI) emission fact (1.2 • 10-6gr/dscO published in the 

"Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volwne I: Stationary Point and Area Sources" (tlAP_ 

42"), Chapter 12, Table 12.20-1 applies. 

Cr(VI) Emissions =(1.2 • 10-6 gr/dscf) • (453.6 • 106 J,lgl7000 gr). (I ft3/O.0283m3 )=2.75 J,lglm3 

The rated control efficiency for the mesh pad is 99%. Assuming 97%. the controlled CR (VI) emissions are equal to: 

=2.75 J,lg/mJ • (1-0.97)=0.082 J.lglm3 

The emission limit for EG-CHROMETANK32=2.9 J,lglm3 
Page: 52 of 65 

Appendix 8. Reporting 

A. Annual and Deviation Certification Reporting 

l"ermn Numoer: 1 YYOUUlt:> 1 

Expiration Date: June 2, 2004 

The Permittee shall use the attached Report Certification fonn (EQP5736) and Deviation Report fonn (EQP 5737) for the 

annual and deviation certification reporting referenced in Section IV and described in Rules 336.l213(4)(c) and 

336.1213(3)(c)(i). Alternative fonnats must be approved by the AQD District Supervisor. 

B. Other Reporting 

For E-I.l, and E-1.2 

Example Format: 

Line: 

Mix Mixed 

Date Product Used 

1101199 45.25 

1102/99 

1103/99 

Line: 

Mix Mixed 

Date Product Used 

1101199 17.75 

1102199 

1/03/99 

For E-l.3: 

Mask Line (Line I) 

Gal Gal VOCs 

Paint used Solvent Used Produced 

22.11 21.88 251.7 

Line Total: 251.7 

Tons VOC: 0.12 

A Line (Line 2) 

Gal Gal VOCs 

Paint used Solvent Used Produced 

8.7 8.7 99.4 

Line Total: 99.4 

Tons VOC: 0.05 

Hours 

In Use 

24 

Hours 

In Use 

8 

VOCs 

per Hour 

10.5 

VOCs 

per Hour 

14. 

Pennittee shall use the NOTIFICATION OF CONSTRUCTIONIRECONSTRUCTION REPORT FORM and the ONGOING 

COMPLIANCE STATUS REPORT FORM as appropriate. 
Page: 53 of 65 

t'enrut Numoer: I !:I!:IOUU4:> I 

Expiration Date: June 2, 2004 

Diet 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

RENEWABLE OPERATING PERMIT 

REPORT CERTIFICATION 

Authorized by 1994 P.A. 451, as amended. Failure to provide this infonnatlon may result In civil and/or criminal penalties. 

Reports submitted pursuant to R 336.1213 (Rule 213), subrulea (3)(c) andlor (4)(c), of Michigan's Renewable Operating (RO) Pennlt 

program must be certlfled by a responsible official. Additional Information regarding the reports and documentaUon listed below 

must be kept on file for at least 5 years, as described In General Condition No. 25 in the RO Permit and be made available to the 

Department of environmental Quality, Air Quality Division upon request. 

Source Name County ________ _ 

Source Address City 

AQD Source 10 (SRN) RO Permit No. RO Permit Section No. 

(General Condition No. 31 and No. 32 of the RO Permit) 

Reporting period (provide inclusive dates): From To 

1. During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the RO Permit, 

each term and condition of which is identified and included by this reference. The methodes) used to determine compliance 

islare the method(s) specified in the RO Permit. 

2. During the entire reporting period this source was in compliance with all terms and conditions contained In the RO Permit, 

each term and condition of which Is identified and included by this reference, EXCEPT for the deviations Identified on the 

enclosed deviation report(s). The method used to determine compliance for each term and condition is the method specified in 

the RO Permit, unless otherwise indicated and described on the enclosed deviation report(s). 

Seml·Annual (or More Frequent) Report Certlflcatlon (General Condition No. 26 ofthe RO Permit) 

Reporting period (provide inclusive dates): From To 

1. During the entire reporting period, ALL monitoring and associated recordkeeplng requirements in the RO Permit were met 

and no deviations from these reqUirements or any other terms or conditions occurred. 

2. During the entire reporting period, all monitOring and associated recordkeeping requirements in the RO Permit were met and 

no deviations from these requirements or any other terms or conditions occurred, EXCEPT for the deviations identified on the 

enclosed deviation report(s). 

Other Report Certification 

Reporting period (provide Inclusive dates): From To 

Additional monitOring reports or other applicable documents required by the RO Permit are attached as described: 

I certify that. based on information and belief formed after reasonable inquiry, the statements and information in this report and 

the supporting enclosures are true. accurate and complete, and that any observed, documented or known Instances of 

noncompliance have been reported as deviations, including situations where a different or no monitoring method is specified by 

the RO Permit. 

Name of Responsible Official (print or type) Title Phone Number 

Signature of Responsible Official Date 
Page: 54 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

DEe 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

RENEWABLE OPERATING PERMIT 

DEVIATION REPORT 

Authorized by 1994 PA 451. as amended. Failure to provide this information may result in civil andlorcriminal penalties. 

This form may be submitted in conjunction with the Renewable Operating Permit Report Certification form (EQP 5736) to report 

deviations from all general conditions and special conditions In the Renewable Operating (RO) Permit for which deviations required 

to be reported by Rule 213(3)(c) have occurred. Additional information regarding the reports and documentation listed below must be 

kept on file for at least 5 years, as described In General Condition No. 25 In the RO Permit and be made available to the Department of 

Environmental Quality, Air Quality Division, upon request. Items 1 • 8 must be completed for all deviations being reported. 

Source Name County ________________ __ 

Source Address City 

AQD Source 10 (SRN) RO Permit No. RO Permit Section No. 

RO Permit Section Contact Contact Phone No. 

Reporting Period (provide inclusive dates): From to 

Report Type: D Annual D Semi Annual 0 Other (Describe) 

1. Group or 2. Table/Condition No. 3. Date(s) of Occurrence 4. Previously reported? 5. Duration of 

Source Wide 10 DYes D No Deviation 

If Yes, Date 

6. Method Used to Determine Compliance Status 7. Description of Deviation 

(if different from method specified in RO Permit) 

8. Reason for Deviation and Description of Corrective Action Taken 

1. Group or 2. Table/Condition No. 3. Date(s) of Occurrence 4. Previously reported ? 5. Duration of 

Source Wide 10 DYes D No Deviation 

If Yes, Date 

6. Method Used to Determine Compliance Status 7. Description of Deviation 

(if different from method specified in RO Permit) 

8. Reason for Deviation and Description of Corrective Action Taken 

1. Group or 2. Table/Condition No. 3. Date(s) of Occurrence 4. Previously reported? 5. Duration of 

Source Wide 10 DYes 0 No Deviation 

If Yes, Date 

6. Method Used to Determine Compliance Status 7. Description of Deviation 

(if different from method specified in RO Permit) 

8. Reason for Deviation and Description of Corrective Action Taken 
Page: 55 of 65 

Pennit Number: 199600451 

Expiration Date: June 2. 2004 

INSTRUCTIONS FOR COMPLETING THE 

RENEW ABLE OPERATING PERMIT 

REPORT CERTIFICATION 

A Renewable Operating (RO) Pennit Report Certification form (EQP 5736) shall be submitted with each report required to be certified by a 

responsible official for the pertinent section of the RO Pennit. Additional information regarding the reports and documentation listed below 

must be kept on file for at least 5 years, as described in General Condition No. 25 in the RO Permit, and be made available to the Department 

of Environmental Quality, Air Quality Division, upon request. A single certification form may be used for multiple reports, if submittal dates 

coincide. (For example, a semi-annual and an annual report with coinciding reporting dates can be reported using the same fonn.) 

Before completing the form, make additional photocopies as needed. 

Source Name 

COUDtyName 

Source Address 

City 

AQD Source ID (SRN) 

RO Permit No. 

RO Permit Section No. 

Provide the name of the source as it appears in the RO Permit. 

Provide the name of the county in which the permitted source is located. 

Provide the address for the physica1location of the source or source section as it appears in the RO Permit. 

Provide the name of the city in which the permitted source is located. 

Provide the source's AQD Source Registration Number (SRN). 

Provide the source's RO Permit Number as it appears in the permit. 

If applicable, provide the RO Permit Section Number. 

Note: Most RO Permits will have only one section. For permits with multiple sections. a responsible official 

must sign a RO Permit Report Certification form for his/her respective section(s). 

Annual Com Hance Certification General Conditions No. 31 and No. 31 of the RO Permit 

This box should be selected if information is being submitted to satisfy the annual compliance certification requirements as described in 

General Conditions No. 31 and No. 32 of the RO Permit. Enter the starting and ending dates of the reporting period in the space provided. 

The reporting period for annual compliance certification is January 1 to December 31, unless an alternate reporting period is specified by the 

RO Permit special conditions. 

Select Box I, ifDQ deviations have occurred from any of the general conditions or special conditions of the applicable section(s) of the RO 

Permit at any point during the above stated reporting period. If this box is checked, no other forms or attachments are necessary. 

Note: The method(s) used to determine compliance l11H:f1 be the method(s) specified in the RO Permit. 

OR 

Select Box 2, if one or more deviations have occurred from any of the general conditions or special conditions of the RO Permit during the 

above stated reporting period. A description of each deviation must be included with this report using the Renewable Operating Permit 

Deviation Report form (EQP 5737), unless an alternate deviation reporting format has received prior approval from the appropriate AQD 

District Supervisor. 

Note: A copy of the report and any supporting documentation must also be sent to the US EPA at the address stated in General 

Condition No. 31 of the RO Permit. 

Semi-Annual or More Fr ~ent Re ort Certification General Condition No. 16 oUhe RO Permit 

This box should be selected if information is being submitted to satisfy the semi-annual (or more frequent if specified in an applicable 

requirement of the RO Permit) certification requirements as described in General Condition No. 26 of the RO Permit. Enter the starting and 

ending dates of the reporting period in the space provided. The reporting periods for semi-annual certification are January 1 to June 30 and 

July 1 to December 31, unless an alternate reporting period is specified by the RO Permit special conditions. 

Select Box I, if all monitoring and associated recordkeeping requirements have been met and if!lQ deviations have occurred from these or 

any of the other general or special conditions of the RO Permit at any point during the above stated reporting period. If this box is checked, 

no additional forms or attachments are necessary. 

OR 

Select Box 2, if one or more deviations has occurred from any monitoring or recordkeeping requirement or any of the other general 

conditions or special conditions of the RO Permit during the above stated reporting period. A description of each deviation must be included 

with this report using the Renewable Operati!lg Permit Deviation Report form (EQP 5737), unless an alternate deviation n;porting format has 

received prior approval from the appropriate AQD District Supervisor. 
Page: 56 of 65 

Other Report Certification 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

This box should be selected if infonnation is being submitted to satisfy RO Pennit reporting requirements other than the annual compliance 

or semi-annual (or more frequent) report certification requirements described above. Enter the starting and ending dates of the reporting 

period in the space provided. Also, give a description of the infonnation that is being submitted in the space provided. 

Other reports required by the RO Permit may include, but are not limited to, the following: 

• Prompt reporting of deviations as described in General Condition No. 27 of the RO Permit. 

• Material usage records, operating schedule records, and calculated emission data. 

• CEM or other monitoring data. 

• Sampling or stack testing data and results. 

• Calibration and maintenance data for process monitoring equipment. 

• Records of required preventative maintenance or malfunction abatement activities. 

• Any other reports required by the special conditions listed in Sections B, E, or F of the RO Permit. 

Signature of Responsible Omdal: 

The Renewable Operating Pennit Report Certification form must be signed by a responsible official for the applicable section(s) of the RO 

Pennit. 

In accordance with the federal Clean Air Act, federal Credible Evidence Rule (62 FR 8314, February 24, 1997) and US EPA White Paper 

Number 2 (Lydia Wegman to Regional Air Directors, March S, 1996). the responsible official for the facility must certify that all observed. 

documented. or known instances of noncompliance were reported as deviations, including situations where a different or no monitoring 

method is specified by the RO Permit. 

The completed Renewable Operating Permit Report Certification form and any attachments should be submitted to the attention of the 

appropriate Air Quality Division District Supervisor or the Wayne County Renewable Operating Program Manager. 
Page: 57 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

INSTRUCTIONS FOR COMPLETING THE RENEWABLE OPERATING PERMIT 

DEVIATION REPORT 

This fonn may be submitted for deviations required to be reported pursuant to Rule 213(3)(c)(i) of Michigan's Renewable Operating (RO) 

Pennit program. The permittee is required to promptly report any deviations from RO Permit requirements during the reporting period. A 

Renewable Operating Permit Report Certification form (EQP 5736) must accompany all deviation reports. 

Before compledng the form, make addJdonaJ photocopies as needed. 

The prompt reporting of deviations from RO Permit requirements must be reported consistent with General Condition No. 27 of the RO 

Permit, which states: 

• Deviations that exceed the emissions allowed under the RO Permit must be reported consistent with the 

requirements of Rule 912. 

• Deviations that exceed the emissions allowed under the RO Permit but were not required to be reported pursuant to 

Rule 912 due to the duration of the deviation must be reported on the semi-annual report, or other report as required 

in the RO Permit. 

• Deviations that did not exceed the emissions allowed under the RO Permit must be reported on the semi-annual 

report, or more frequently if required by the RO Permit. 

Note: Submittal of the Deviation Report does not necessarily constitute a written report under Rule 912(5). 

Source Name Provide the name of the source as it appears in the RO Permit. 

County 

Source Address 

City 

AQD Source ID (SRN) 

RO PermJt No. 

RO Permit Seedon No. 

Seedon Contact 

Contact Phone Number 

Provide the name of the county in which the permitted source is located. 

Provide the address for the physical location of the source or source section as it appears in the RO Permit. 

Provide the name of the city in which the permitted source is located. 

Provide the source's AQD Source Registration Number (SRN). 

Provide the source's RO Permit Number as it appears in the RO Permit 

If applicable, provide the RO Permit Section Number. 

Note: Most RO Permits will have only one section. For RO Permits with multiple 

sections, a responsible official must sign an RO Permit Report Certification form for 

hislher respective section(s). 

Provide the name of the contact person identified in the RO Permit Application for the RO Permit Section 

to which this report applies. 

Provide the phone number of the Section Contact. 

Reporting Period Enter the starting and ending dates of the reporting period. The reporting period for annual reporting will 

Report Type 

typically be January I to December 31, unless an altemate reporting period is specified by the RO Permit special 

conditions. The reporting periods for semi-annual report certification will typically be January I to June 30 

and July I to December 31, unless an alternate reporting period is specified by the RO Permit special 

conditions. The starting date for the fnldal report(s) should be the date of issuance of the RO Permit. 

Note: If this form is being used for more than one reporting period. list the dates for the 

longest period. For example. if the form is used for the annual and semi-annual report. 

the reporting periodfor the annual report should be used. 

Select the report type for which this report is being submitted. The RO Permit may require reporting other 

than annually or semi-annually. Describe the report type ifnot annual or semi-annual. Other reports required by 

the RO Permit may include, but are not limited to, the following: 

• Prompt reporting of deviations as described in General Condition No. 27 of the RO Permit. 

• Material usage records, operating schedule records and calculated emission data. 

• CEM or other monitoring data. 

• Sampling or stack testing data and results. 

• Calibration and maintenance data for process monitoring equipment. 

• Records of required preventative maintenance or malfunction abatement activities. 

• Any other reports required by the special conditions listed in Sections B. E or F of the RO Permit. 
Page: 58 of 65 

Commete Items 1-8 for each deviadon. 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

I. Enter the Emission Group or Flexible Group 10, as it appears on the RO Permit, for which the deviation has occurred. If this is a 

deviation from a Source Wide requirement, "Table B" is the Source Wide 10. 

2. Enter the Table number and RO Permit condition number of the requirement for which the deviation has occurred. If the deviation 

applies to a general condition. enter "NA" in place of the Table number. See Attachment A for an example of the current numbering 

system. If there is an "A" in the "Pollution Control Equipment" box. as indicated by the arrow in this example, then the RO Permit uses 

the current numbering system. If the RO Permit is not labeled in this manner, describe the RO Permit condition in detail or contact the 

appropriate Air Quality Division District or Wayne County office for instruction on the numbering protocol of your RO Permit 

3. Enter the date(s) on which the deviation occurred or time period covered by a referenced monitoring or compliance report(s). (For 

example: 1101198 to 1104/98) 

4. Indicate whether this deviation was previously reported to the Air Quality Division. If so, provide the date on which it was reported. 

Note: Previously submitted information should have included the Source Name. City. AQD Source ID. RO Permit Number and RO Permit 

Section Number. 

S. Indicate the duration of the deviation. (For example: 2 hours, 4 days, etc.) 

6. Describe the compliance method used to determine the compliance status. If the compliance method used was the same as specified in 

the RO Permit, then this box may be left blank. 

Note: This is the only box that may be left blanlc. 

7. Describe the deviation in sufficient detail to show how the deviation differs from the requirement. 

8. Explain the reason for the deviation and describe the actions taken to correct the deviation. 

9. Provide additional supporting information for Items 6, 7, & 8, as needed. If submitting additional information. please give a brief 

description in the appropriate box(es) and note that additional supporting information is being submitted. 

Write in the page numbering at the bottom ofthe page. For example, "Page 3 of 6", 
Page: 59 of 65 

DIQ 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUAliTY, AIR QUALITY DIVISION 

NOTIFICATION OF CONSTRUCTION/RECONSTRUCTION REPORT 

This information is required by Article II, Part 55 (AIr Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean 

Air Act of 1990. Failure to provide this Information may result In penalties and/or imprisonment. 

Applicable Rule: 40 CFR Part 63, Subpart N-National Emission Standards for Chromium Emissions from 

Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. 

NOTE: All affected facilities must complete and submit this report to the Michigan Department of Environmental Quality prior to 

the construction or reconstruction of chromium electroplating or chromium anodizing tanks. Please complete and send to the 

appropriate office listed on the last page of this report. 

Please print or type al/lnfonnatlon. 

1. COMPLETE THIS SECTION FOR EACH PLANT IN WHICH A CHROMIUM ELECTROPLATING ANDIOR CHROMIUM 

ANODIZING TANK IS BEING CONSTRUCTED OR RECONSTRUCTED. 

OWNERIOPERATOR NAME AND TITLE PLANT NAME 

STREET ADDRESS PLANT TELEPHONE AREA CODE & NUMBER 

CITY I STATE I ZlPCODE PLANT CONTACT NAME AND TITlE 

PLANT STREET ADDRESS (if different Ihan Owner/Operator's) CITY I STATE I ZlPCODE 

2. COMPLETE THIS SECTION FOR EACH TANK FOR WHICH CONSTRUCTION OR RECONSTRUCTION IS PLANNED. If 

additional space is needed, make copies of this page. 

Expec:ted Expected Estimaled Total 

Type of Control Chromium Tank Type of Tank Beginning Dale Completion Date Anllcipated Control System Emissions After 10# for Construction! for Construction! Startup Date Technique to be 10# 

Reconstruction Reconstruction Used 1 Control Is 

Applied 2 

1 Attach deSign information from vendor, including design drawings and deSign capacity. 

2 Attach engineering calculations to support estimate. These calculations may be from the vendor. Emissions estimates should be 

expressed in units consistent with the emission limits in the regulation. 

EXAMPLE RESPONSE' . 

Expected Expected Estimated Total 

Type of Control Chromium Tank Type of Tank Beginning Date Completion Dale Anticipated Control System Emissions After 10# for Construction! for Constructionl Startup Date Technique to be 10# 

Reconstruction Reconstruction Used 1 Control Is 

Applied 2 

1 Hard chrome 10/94 1195 1/95 CompoSite mesh- 5 0.01mgJdscm 

plating pad system 

2 Decorative 2195 6195 6/95 Wetting-agent NlA Will meet 45 

chrome plating fume suppressant dynes/em 

3. This form is being completed because a chromium electroplating and/or chromium anodizing tank is being: 

0 Constructed 0 Reconstructed 

4. After construction/reconstruction occurs, tanks will be located at a facility which is a: 

0 Major Source (emits greater than 10 tons per year of any 0 Area Source (all sources which are 

one hazardous air pollutant [HAP] or 25 tons per year of not Major Sources) 

multiple HAP's. 

NOTE: The major/area source determination is based on all HAP emission points inside the facility fenceline, not justlhe chromium electroplating 

and anodizing tanks. 
.. Page: 60 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

5. If hard chromium electroplating tanks are being operated, check all boxes that apply. 

The maximum cumulative potential rectifier capacity of the hard chromium electroplating tanks 

(Total installed Rectifier Capacity [amperes] X 8400 HoursJYr X .70 for Each Tank) is: 

o greater than or equal to 60 million amp-hr/yr 0 less than 60 million amp-hr/yr 

o Records show that the facility's previous 12-month cumulative current usage for the hard chromium electroplating tanks 

was less than 60 million amp-hr. 

o The facility wishes to accept a federally-enforceable limit of less than 60 million amp-hr/yr on the maximum cumulative 

tential rectifier ca aci of the hard chromium electro lati tanks. 

6. Attach a brief description of the proposed emission control technique(s), including design drawings, design capacity. and 

emissions estimates with supporting calculations. 

7. If reconstruction is to occur, attach a brief description of the source and the components to be replaced. 

B. Complete the following if reconstruction is to occur and the facility believes that there are economic or technical limitations 

to prevent the facility from complying with all relevant standards or requirements. 

A. Attach a discussion of any economic or technical limitations of complying with the relevant standards or reqUirements. 

The discussion must be sufficiently detailed to demonstrate how these limitations will affect the facility's abilitv to 

comply. 

B. Provide an estimate of the fixed capital cost of the replacements and of constructing a comparable entirely new 

source: Replacements $ ; New source $, ____ _ 

C. Provide the estimated life of the source after the replacements: ____ _ 

NOTE: The NOTIFICATION OF CONSTRUCTIONIRECONSTRUCTION REPORT does not replace the Permit to Install 

requirement identified in Rule 201 of the Michigan Administrative Rules for Air Pollution Control (or the Installation Permit 

required by the Wayne County Air Pollution Control Ordinance). Permits to Install (or Installation Permits) are to be obtained 

prior to a facility installing. constructing, reconstructing. relocating. altering or modifying any process or process equipment. 

including control equipment, that emits air contaminants. The purpose of the permit requirements is to ensure that new or 

modified sources of air contaminants will operate in compliance with all applicable state and federal requirements. 

9. Print or type the name and title of the Responsible Official for the plant: 

(Name) (Title) 

A Responsible Official can be: 

• The preSident, vice-president, secretary, or treasurer of the company who owns the plant; 

• The owner of the plant; 

• The plant engineer or supervisor; 

• A govemment official if the plant is owned by the Federal. State, City. or County government; or 

• A ranking military officer if the plant is located on a military base. 

I Certify the Information Contained in this Report to be Accurate and True to the Best of my Knowledge. 

(Signature of Responsible Official) (Date) 
.. " 

Page: 61 of 65 

Permit Number: 199600451 

Expiration Date: June 2. 2004 

Dlt\ MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALllY, AIR QUALllY DIVISION 

ONGOING COMPLIANCE STATUS REPORT 

This Information Is required by Article II. Part 55 (Air Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean 

Air Act of 1990. Failure to provide this information may result in penalties and/or imprisonment. 

Applicable Rule: 40 CFR Part 63. Subpart N-National Emission Standards for Chromium Emissions from 

Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. 

NOTE: This report is used to demonstrate ongOing monitoring of the operating parameter established during the 

performance test. Affected facilities must begin monitoring on and after the date of their performance test. Major 

sources must submit this report to the Michigan Department of Environmental Quality. Please complete and send 

to the appropriate office listed on the last page of this report. 

Please print or type allinfonnation. 

1. COMPLETE THIS SECTION FOR EACH PLANT IN WHICH CHROMIUM ELECTROPLATING ANDIOR CHROMIUM 

ANODIZING OPERATIONS ARE PERFORMED. 

OWNER/OPERATOR NAME AND TITLE PLANT NAME 

STREET ADDRESS PLANT TELEPHONE AREA COCE & NUMBER 

CITY I STATE I ZIP CODE PLANT CONTACT NAME AND TITLE 

PLANT STREET ADDRESS (If different than Owner/Operator'S) CITY I STATE I Z1PCOCE 

2. COMPLETE THIS SECTION. If additional space is needed, make copies of this page. 

Operating Acceptable 

Tank Applicable Type of Control Control System Parameter Value or Range Total Operating 

Type of Tank Monitored to of Values for Time During 10# Emission Limit Technique 10# Demonsllate Monitored Reporting 

Compliance Parameter(s) Period 

EXAMPLE RESPONSE,' . Operating Acceptable 

Tank Applicable Type of Control Control System Parameter Value or Range Total Operating 

Type of Tank Monitored to of Values for Time During 10# Emission Limit Technique 10# Demonstrate Monitored Reporting 

Compliance Parameter(s) Period 

1 Hard chrome plating 0.015 mg/dscm Composite 10 pressure drop 7 in. w.c. ± 1 in. 1,040 hr. 

mesh-pad 

sYStem 

2 Chrome anodizing 45dyneslcm Wetting agent N/A surface tension S45 dynes/ern 1,040 hr. 

fume 

sUPllressant 

3 Hard chrome plating 0.015 mg/dscm CompoSite 10 pressure drop 7 in. w.c. ± 1 in. 1,040 hr. 

mesh-pad 

SYStem 

3. IDENTIFY THE BEGINNING AND ENDING DATES OF THE REPORTING PERIOD, 

Beginning Date: I Ending Date: 
" 

Page: 62 of 65 

Pennit Number: 199600451 

Expiration Date: June 2. 2004 

4. COMPLETE THIS SECTION FOR THIS REPORTING PERIOD FOR HARD CHROMIUM ELECTROPLATING TANKS THAT 

ARE LIMITING THEIR MAXIMUM CUMULATIve RECTIFIER CAPACITY IN ACCORDANCE WITH 40 CFR 63.342 (C) (2). 

Ampere-Hours Consumed By Month Total Ampere-Hours 

Tank Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Consumed During Reporting 

10# Period 

Total 

For All 

Tanks 

EXAMPLE RESPONSE 

Ampere-Hours Consumed By Month Total Ampere-Hours 

Tank Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Consumed During Reporting 

10# Period 

1 400,000 400,000 400,000 200,000 200,000 200,000 1,800,000 

3 300,000 300,000 300,000 300,000 300,000 300,000 1,800,000 

Total 700,000 700,000 700,000 500,000 500,000 500,000 3,600,000 

For All 

Tanks 

5. Attach all MONITORING DATA RECORD KEEPING FORMS for the reporting penod. Based on the data on 

excess emissions and the data on operating times, calculate the following hours: 

Duration of excess emissions caused by: 

Process upsets 

Control equipment malfunctions 

Other known causes 

Unknown causes 

Total duration of excess emissions 

Percent of total 

Hours operating time 

6. In accordance with the OPERATION AND MAINTENANCE PLAN for this source, during this reporting period the 

work practices identified in 40 CFR 63.342(f) were: 

D Followed D Not Followed 

7. If the OPERATION AND MAINTENANCE PLAN was not followed during the reporting period, please provide an 

explanation of the reasons for not following the proviSions in the plan, an assessment of whether any excess 

emissions and/or parameter monitoring exceedances are believed to have occurred, and a copy of the 

appropriate records documenting that the operation and maintenance plan was not followed. Please state 

whether or not the plan is being revised accordingly. 
t. 

Page: 63 of 65 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

8. Please describe any changes in monitoring, processes, or controls since the last reporting period. 

9. Print or type the name and title of the Responsible Official for the plant: 

(Name) (Title) 

A Responsible Official can be: 

• The president, vice-president, secretary, or treasurer of the company who owns the plant; 

• The owner of the plant; 

• The plant engineer or supervisor; 

• A government official if the plant is owned by the Federal, State, City, or County government; or 

• A ranking military officer if the plant is located on a military base. 

I Certify The Information Contained In This Report To Be Accurate And True To The Best Of My Knowledge. 

(Signature of Responsible Official) (Date) 

NOTE: Major sources are required to submit the ONGOING COMPLIANCE STATUS REPORT to the Michigan 

Department of Environmental Quality. Air Quality Division, semi-annually. If exceedances occur, the report must be 

completed and submitted quarterly. Area sources are required to complete this report annually, retain the report on 

site, and make the report available to the Michigan Department of Environmental Quality, Air Quality Division, upon 

request. If exceedances occur, the report must be completed semi-annually. Area sources must keep the reports 

on file for five years. Major sources must submit the ONGOING COMPLIANCE STATUS REPORT to the Michigan 

Department of Environmental Quality, Air Quality Division. 
I. ., 

• 

Page: 64 of 65 

Appendix 9. Preventive Maintenance Plan-Air Exhaust Equipment 

Permit Number: 199600451 

Expiration Date: June 2, 2004 

The supervisory person responsible for inspection and repair of all air cleaning devices shall be the "Maintenance Manager". 

A listing of each air cleaning device to be inspected and repaired is as follows: 

I. CHROME MIST ELIMINATOR 

This system has one blower with two eliminators, one for the sidearm chrome tank. This system has a 

programmable timer that runs five minutes each weekend or when a shutdown has lasted more than 10 hours to 

spray water on the mist eliminator media. 

Our inspection and service shall consist of: 

a. Visual inspection of blower belts (3) and shives. 

b. Visual inspection of blower, bearings and shafts. 

c. Visual inspection of water nozzles. 

d. Visual inspection of electric motor. 

Parts to be kept in stock will be: 

a. 3 belts. 

b. Spray nozzles. 

2. NITRIC WET AIR SCRUBBER 

This system has one air blower and a pump to supply a constant source of spray over the fume collection media. 

Our inspection of this scrubber will consist of: 

a. Visual inspection of blower belts (3) and shives. 

b. Visual inspection of blower, bearings and shafts. 

c. Visual inspection of water nozzles. 

d. Visual inspection of electric motor. 

e. Visual inspection of pump. 

Parts to be kept in stock will be: 

a. 3 belts. 

b. Spray nozzles. 

c. Water spray pump. 

NOTE: A constant feed of 2 gpm of city water is flushing the water reservoir. 

3. ETCH MIST ELIMINATOR 

This system consists of a cry scrubber powered with a blower and manually washed down (with a spray nozzle 

system) media. This media is washed down once per week for three minutes. 

Our inspection of this system will consist of: 

a. Visual inspection of belts. 

b. Visual inspection of blower, bearings and shaft. 

c. Visual inspection of spray nozzles. 

d. Visual inspection of electric motor. 

Parts to be kept in stock will be: 

a. 3 belts. 

b. Spray nozzles . 

4. PREPLATE WET SCRUBBER 

This system is identical to the nitric wet scrubber and will be serviced and stocked the same. 
Page: 65 of 65 

Pennit Number: 199600451 

Expiration Date: June 2, 2004 

5. ACID COPPER DRY MIST ELIMINATOR 

This system depends only on the movement of copper fumes to collect on the fume media (walls) at the outside of 

the chamber and gravity drain down in to a waste treatment collection pit. No water is used on this fume 

collection system. 

Our inspection of this system will consist of: 

a. Visual inspection of belts. 

b. Visual inspection of blower, bearings and shaft. 

c. Visual inspection of electric motor. 

Parts to be kept in stock will be: 

a. Belts. 

The two wet air scrubbers (Nitric, Prep late) variables will be detennined by the water spray nozzles and blower/motor belts. 

1. For the Nozzles: 

A full "fan" cone-shaped spray that meets the nozzle spray next to it or overlaps is considered "OK". If they 

don't meet or overlap they must be repaired. 

2. For the BlowerlMotor Belts: 

A timing strobe will be used to observe the belt slippage. As long as belt slippage is less than one foot per 15 

seconds the RPM of the blower is sufficient to move the rated air flow. Our aim will be "0" belt slippage 

however. 

For the Chrome Mist Eliminators, we will use blower belt slippage as the variable to detennine the proper function of the air 

blower. Our goal will be zero slippage. However, twelve inches per fifteen seconds (12"/155) is the point after which air 

volumes will begin to be affected and will be used as the unacceptable limit. The spray nozzles for the three chrome mist 

eliminators (1 main line, 1 side arm. 1 etch) are operated by time (mainline, sidearm) and by hand (etch). While operating, we 

will observe the spray pattern to be sure all media is being completely covered. Any deviation outside these variables will be 

repaired. 

For the Acid Copper Dry Mist Eliminator, the blower belts are the only item that has operational variables, as there are no 

nozzles in this unit. The same variables apply here as in the ahove units. The goal is to have zero belt slippage, however, the 

maximum allowable slippage before blower volume is appreciably affected is twelve inches in fifteen seconds (12"/15s). Again 

a strobe timing scope will be used to check this. Anything over this variable will be repaired. 

All reasonable, necessary repair parts such as belts, pumps and nozzles are kept in stock to be used immediately to affect 

repairs. All large and more costly items such as motors, shafts, etc. are available within a fifty mite radius and are stock items 

with our suppliers. Therefore, we will not stock these seldom needed items. 

All checks and service will be done by the maintenance department. The checks will be on a BI-WEEKLY basis and repairs 

will be done upon detennination of a problem.