Technical Support Document 

Application for a Permit to Install 

Proposed Modification to an Existing 

Decorative Chromium Plating Operation 

Lapeer, Michigan 

for 

Dott Industries, Inc. - Deco Plate Manufacturing 

395 DeMille Road 

Lapeer, MI 48446 

submitted by 

Horizon Environmental Corporation 

4595 Broadmoor SE, Suite 200 

Grand Rapids, Michigan 49512 

January 8, 2001 
• 

,I 

TABLE OF CONTENTS 

1. INTRODUCTION ................................................................................................................................................... 1 

2. DESCRIPTION OF PROCESS AND PROPOSED CHANGES ....................................................................... 3 

2.1 PROCESS DESCRIP110N AND PROPOSED CHANGES ................................................................................................ 3 

2.2 AlR EMISSIONS CONTROL EQUIPMENT .................................................................................................................. 4 

2.3 PROPOSED PROCESS CHANGES .............................................................................................................................. 6 

3. ESTIl\IATION OF El\fi"SSIONS ............................................................. _ ............................................................. 9 

3.1 CHROME ELECTROPLATING TANK. ........................................................................................................................ 9 

3.1.1 Chromium (VI) Emissions ........................................................................................................................... 9 

3.1.2 Sulforie Acid Emissions ............................................................................................................................ 10 

3.1.3 Cumulative System 1 Emissions Summary ............................................................................................... 10 

3.1.4 Regulatory Statusjor the Proposed Chrome Plating Tank ..................................................................... 11 

3.2 BRIGHT ACID COPPER TANK ............................................................................................................................... 11 

. 3.2.1 Sul.furic Acid Emissions ............................................................................................................................ 11 

3.2.2 Cumulative System 2 Emissions Summary ............................................................................................... 12 

3.2.3 Regulatory Status for the Proposed Bright Acid Copper Tank ................................................................ 13 

3.3 COPPERINICKEL STRIP TANK .............................................................................................................................. 13 

3.3.1 Cumulative System 4 Emissions Summary ............................................................................................... 14 

3.3.2 Regulatory Status for the Proposed CopperlNickel Strip Tank ............................................................... 14 

3.4 PRE-cQNDmONERTANK ..................................................................................................................................... 15 

3.4.1 Amino-Saturated Butrolactone Emissions ................................................................................................ 15 

3.4.2 Cumulative System 5 Emissions Summary ............................................................................................... 16 

3.4.3 Regulatory Status for the Preconditioner Tank ........................................................................................ 16 

3.5 SEMI-BRIGHT NICKEL AND BRIGHT NICKEL TANKS ........................................................................................... 17 

3.6 EMISSION SUMMARY AND COMPARISON TO FACILITY'S CURRENTROP LIMITS ............................................... 18 

4. APPLICABLE REGULATORY REQUIREMENTS ................... _ .............................................. _ ............... 20 

4.1 MICHIGAN AIR QUAJ.JTY REQUIREMENTS .......................................................................................................... 20 

4.1./ MAR 201 - Permits to Install .................................................................................................................... 20 

4.1.2 MAR 2J 6 - Modifications to Renewable Operating Permits ................................................................... 21 

Dott Iodustrfes, Inc:. 

Pennit to Install Application 

Lapeer, Michigan 

-iHorizoD Environmental Corporadon 

Technical Support Document 

October 3,2000 
·1 

4.1.3 MAR 225 - Health-Based Screening Level Requirement for New or Modified Sources of Air Toxies ... 21 

4.2 NATIONAL EMISSIONS STANDARDS FOR HAzARDOUS AIR POLLur ANTS ........................................................... 22 

S. Al\mIENT AIR QUALITY Il\fP ACT ANALYSIS ........................................................................................... 24 

5.1 DESCRIPTION OF SITE AREA ........................................... : .................................................................................... 24 

5.1.1 Land Use Classijication ............................................................................................................................ 24 

5.1.2 Topography ............................................................................................................................................... 25 

5.2 DISPERSION MODEL ............................................................................................................................................. 26 

5.2.1 BUilding Downwash Effects ...................................................................................................................... 27 

5.3 DATABASES USED IN AIR QUALITY IMPACT ANALySiS ...................................................................................... 27 

5.3.1 Meteorological Data ................................................................................................................................. 28 

5.3.2 Receptor Points ............................................................................................ , ............................................ 28 

5.3.3 Emission Inventory .................................................................................................................................... 29 

5.5 AIR QUAUTY IMPACT .......................................................................................................................................... 29 

TABLE OF CONTENTS (CONT'D) 

FIGURES 

1 Bun.OING PROJECllONS IN RELATION TO EMISSION POINTS 

2 RECEPTOR GRID 

TABLES 

lA SULFURIC ACID EMISSIONS FROM THE NEW BRIGHT ACID COPPER TANK 

(SYSTEM #2) 

1 B SYSTEM #2 - SULFURIC ACID EMISSIONS FROM COPPER STRIKE AND ACID 

COPPER TANKS 

2A SULFURIC ACID EMISSIONS FROM THE NEW COPPERINICKEL STRIP TANK 

(SYSTEM #4) 

2B SYSTEM #4 - NITRIC ACID EMISSIONS FROM NITRIC STRIP TANKS 

(PROPOSED TANK AND TANK #39) 

2C SYSTEM #4 - HYDROCHLORIC ACID EMISSIONS FROM NEUTRALIZER TANK 

(TANK #5) 

Dott IDdustrles, Inc. 

Permit to Install Application 

Lapeer, Michigan 

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Horizon EDvironmental CorporatloD 

Technical Support Document 

October 3, 2000 

, 
.) 

3A AMINO-SATURATED BUTROLACTONE EMISSIONS FROM THE NEW 

PRECONDITIONER TANK (SYSTEM 5) 

3B SYSTEM #5 - CHROME VI EMISSIONS FROM PRE-ETCH AND ETCH TANKS 

(TANKS # 1, #2A, AND #2B) 

3C SYSTEM #5 - SULFURIC ACID EMISSIONS FROM PRE-ETCH AND ETCH TANKS 

(TANKS #1, #2A, AND#2B) 

4 SUMMARY OF AIR POLLUTANTS EMISSIONS FROM THE MODIFIED PLATING 

PROCESS 

5 AVER LAND USE CLASSIFICATION SCHEME 

6 COMPARISON OF PREDICTED HEXAVALENT CHROMIUM IMPACTS TO MAR 225 

SCREENING LEVELS 

APPENDICES 

A PERMIT TO INSTALL APPLICATION FORM 

B FACfl..I1Y PLOT PLANS 

C RELEvANT MA 1ERlAL SAFE1Y DATA SHEETS 

D DISPERSION MODELING INPUT/OUTPUT Fll..ES (DISKETIE) 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

- 1I1 -

Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
.. 

1. INTRODUCTION 

Dott Industries, Inc. - Deco Plate Manufacturing ("Dott" ) owns and operates a metallic 

plating process for applying a chrome finish on plastic parts at their facility located at 395 

DeMille Road, Lapeer, Michigan. The plating process is comprised of a number of stages 

(i.e., tanks) that include pre-etching, etching, and activator/accelerator tanks fOT preparing 

parts for plating, and subsequent copper, nickel, and chrome plating tanks, which are used 

in differing combinations to provide the desired swface finish. The plating process also 

contains copper/nickel strip and chrome strip tanks used to clean the parts racks following 

removal of the plated plastic parts. The plant operates in accordance with the terms and 

conditions of State of Michigan Renewable Operating Permit ("ROP") Number 

199600451, issued by the Air Quality Division (" AQD" ) of the Michigan Department of 

Environmental Quality ("MDEQ" ) on June 2, 1999. 

Dott proposes to make a change at the facility, by installing additional tanks to increase the 

capacity and efficiency of the plating process. The proposed tanks include: one (1) two-bay 

preconditioner tank; two (2) two-bay semi-bright nickel plating tanks; one (l) single-bay 

bright nickel plating tank; one (1) two-bay acid copper plating tank; one (l) single-bay 

chrome plating tank; and one (1) single-bay copper/nickel strip tank. Only the chrome 

plating tank installation is required to obtain an air use permit for construction. The rest of 

the proposed tanks are considered exempt from permitting according to Rules 285(r)(vii) 

and 290 of Michigan's Administrative Rules ("MARs" ) for Air Pollution Control (P A 451 

of 1991). 

Pursuant to Rule 201 of MAR for Air Pollution Control (PA 451 of 1991), a Permit to 

Install covering the proposed chrome plating tank must be issued by the AQD prior to 

installation. This technical support document constitutes the Permit to Install application 

package for the proposed chrome plating tank for the Dott facility. Infonnation necessary 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

- 1 -

Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
to demonstrate compliance with a11 applicable air quality requirements, as specified in 

MAR 203, is presented within this document. 

An analysis of the proposed operation, including a description of the process, emissions 

control devices, and equipment specifications, is presented in Section 2.0 of this document. 

Applicable state and federal air quality requirements are introduced in Section 3.0, while 

Section 4.0 summarizes emissions estimates. Ambient air quality dispersion modeling 

analyses demonstrating that potential toxic air contaminant ("T AC" ) emissions due to the 

proposed modification will not exceed applicable MAR 225 health-based screening levels is 

presented in Section 5.0. 

The required Pennit to Install application form is submitted as Appendix A to this 

document. Detailed facility plot plans are submitted with this docwnent as Appendix B. 

Relevant Material Safety Data Sheets are provided in Appendix C and dispersion modeling 

input/output files (in electronic fonnat) are submitted as Appendix D. 

Dott indUstries, Ine. 

Pennit to Install Application 

Lapeer, Michigan 

-2-

Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
'. 

2. DESCRIPTION OF PROCESS AND PROPOSED CHANGES 

Dott proposes to make a change at its Lapeer facility, by installing an additional chromeplating tank to increase the capacity of the plating process. The facility is located at 395 

DeMille Road, in the City of Lapeer, Lapeer County, Michigan. A description of the 

plating process, emissions controls, and proposed changes is provided below. 

2.1 PROCESS DESCRIPTION AND PROPOSED CHANGES 

The plating process is a multiple stage operation, consisting of a number of sequential 

tanks, which is utilized in producing a metallic coating on plastic parts. Depending on the 

coating desired, differing sequences of the surface preparation and plating tanks may be 

used. This process description covers all tank stages in the sequence. 

The initial stages in the plastic part plating process deal with preparation of the substrate to 

be plated (i.e. the plastic parts). Preparatory stages include pre-etch (Tank I), etch (Tank 2), 

neutralizer (Tank 5), activator (Tank 7), and accelerator (Tank 9) tanks, and intennediate 

water rinse tanks. Each of these stages generally contain a solution of acids and reducing 

agents designed to prepare the plastic parts to better accept the metallic plating. Dott 

proposes to add an additional preconditioner tank to the surface preparation tank group. 

The next tank grouping in the plating process is comprised of those tanks that are used for 

application of a copper base coat. The stages include electro less copper (Tank 11), copper 

strike (Tank 14), and bright acid copper (Tanks 15, 16, 17, 18, 19) tanks, and intennediate 

water rinse tanks. Dott proposes to add one additional bright acid copper tank to the copper 

plating tank group. 

The next tank grouping in the plating process is comprised of those tanks that are used for 

application of a nickel intermediate coat. The stages include semi-bright nickel (Tanks 24, 

Dott IDdustries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

-3-

Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
25,26), bright nickel (Tank 28), microporosity nickel (Tanks 29, ?), and pearl nickel (Tank 

?) tanks, and intennediate water rinse tanks. Dott proposes to add two additional semibright nickel and one additional bright nickel tank to the nickel plating tank group. 

The following tank grouping in the plating process is comprised of those tanks that are used 

for application of a chrome surface coat. The stages include a chrome plating tank (Tank 

32), and final parts water rinse tanks. Dott proposes to add one additional chrome tank to 

the chrome plating tank group. 

The final tank grouping in the plating process is comprised of those tanks that are used for 

removal of the metallic plating accumulated on the racks utilized to hold the plastic parts to 

be plated. The stages include chrome strip (Tank 37) and copper/nickel strip (Tank 39) 

tanks, and intermediate water rinse tanks. Dott proposes to add one additional 

copper/nickel strip tank to the rack cleaning tank group. 

2.2 AIR EMISSIONS CONTROL EQUIPMENT 

Chemical fume suppressants containing wetting agents are utilized in all plating tanks at the 

Dott facility. The fume suppressants minimize emissions of metals and acid mists to the 

atmosphere by maintaining the surface tension of the plating baths at low levels at all times 

during operation of the plating tanks 

In addition, emissions from the plating process are captured and controlled by one of five 

existing emission control systems. Each control system is designed to remove aerosol 

emissions of acids and metals released from the surface of the plating tanks. Capture of the 

aerosol emissions is accomplished by use of push-pull lateral exhaust hoods at the edges of 

plating tanks requiring control. The five capture and control systems are currently 

configured to control emissions from multiple tanks, as follows: 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

-4-

Horizon Environmental Corporatfon 

Technical Suppon Document 

October 3, 2000 
System 1: Emissions captured from one chrome electroplating tank (Tank 32) and treated 

by a water-washed mesh pad mist eliminator with a rated aerosol control 

efficiency of 99 percent. The air contaminant controlled by the mesh pad mist 

eliminator is hexavalent chromium. 

System 2: Emissions captured from one copper strike tank (Tank 14) and five bright 

copper tanks (Tanks 15 through 19) and treated by six cyclonic mist eliminators 

with a rated aerosol control efficiency of 40 percent. The air contaminant 

controlled by the cyclonic mist eliminator is sulfuric acid. 

System 3: Emissions captured from one activator tank (Tank 7), one accelerator tank (Tank 

9) and one electroless copper tank (Tank 11) and treated by a packed-bed water 

scrubber with a rated aerosol control efficiency of 96 percent. The air 

contaminants controlled by the packed-bed scrubber are hydrochloric acid and 

fonnaldehyde. 

System 4: Emissions captured from one neutralizer tank (Tank 5) and one copper/nickel 

strip tank (Tank 39) and treated by a packed-bed water scrubber with a rated 

aerosol control efficiency of 96 percent. The air contaminant controlled by the 

packed-bed scrubber is hydrochloric acid 

System 5: Emissions captured from one pre-etch tank (Tank 1) and one etch tank (Tank 2) 

and treated by a dry mesh pad scrubber with a rated aerosol control efficiency of 

99 percent. The air contaminants controlled by the dry mesh pad scrubber are 

hexavalent chromium and sulfuric acid. 

All other tanks included in the plating process, including the chrome strip tank, and all 

water rinse tanks, do not require capture and control of their emissions and are vented 

directly into the general building air space. 

Dott Industries, Ine. 

Permit to Install Application 

Lapeer, Michigan 

- 5-

Horizon Environmental Corporation 

Technical Suppon Dccument 

October 3, 2000 
" 

... 

2.3 PROPOSED PROCESS CHANGES 

As noted in Section 2.1, Dott proposes to install seven additional tanks to the existing 

plating process. The following section provides a description of the proposed new tanks. 

New Preconditioner Tank (1) 

• Dimensions: 108" x 72" x 68" (LxWxD) 

• Solution Temperature: 103-1650 F 

• Surface Tension: 50 dynes/em 

• 15% MicroEtch etching solution; balance is water 

• Equipped with air agitation system for mixing (0.35 ft3 air/min-fil) 

• Emissions collected and treated by Control System 5 

The new preconditioner tank will act as an additional substrate preparation step prior to 

plating of the plastic parts. The active ingredient in the tank will be MicroEtch, produced 

by CRT, Inc of Okemos, Michigan. A MSDS for the material is presented as Appendix C. 

New Bright Acid Copper Tank (1) 

• Dimensions: 108" x 72" x 68" (LxWxD) 

• Solution Temperature: ambient 

• Surface Tension: 55 dynes/em 

• 25 ozJgal copper sulfate; 15 ozJgal sulfuric acid; balance is water 

• Equipped with air agitation system for mixing (0.35 ft3 air/min-fill 

• Emissions collected and treated by Control System 2 

The new bright acid copper tank will operate in the same manner as existing Tanks 15 

through 19. 

New Semi-Bright Nickel Tanks (2) 

• Dimensions: 108" x 72" x 68" (LxWxO) 

• Solution Temperature: 1450 F 

• Surface Tension: Uncontrolled 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

-6-

HorizoD Environmental Corporation 

Technical Support Document 

October 3, 2000 
• 10 ozJgal nickel metal; 6.5 ozJgal boric acid; balance is water 

• Equipped with air agitation system for mixing (0.35 Wair/min-fil) 

• Emissions vented to general building airspace 

The new semi-bright nickel tanks will operate in the same manner as existing Tanks 24 

through 26. 

New Bright Nickel Tanks (1) 

• Dimensions: 108" x 42" x 68'~ (LxWxD) 

• Solution Temperature: 1450 F 

• Surface Tension: Uncontrolled 

• 10 ozJgal nickel metal; 6.5 ozJgal boric acid; balance is water 

• Equipped with air agitation system for mixing (0.35 Wair/min-fil) 

• Emissions vented to general building airspace 

The new bright nickel tank will operate in the same manner as existing Tank 28. 

New Chrome Tank (1) 

• Dimensions: 108" x 42" x 68" (LxWxD) 

• Solution Temperature: 1100 F 

• Surface Tension: 40 dynes/em 

• 40 ozlgal chromic acid (crO); 0.13 ozlgal sulfuric acid; balance is water 

• No air agitation 

• Emissions captured and treated by Control System 1. 

The new chrome tank will operate in the same manner as existing Tank 32. 

New CopperlNickel Strip Tank (1) 

• Dimensions: 108" x 42" x 68" (LxWxD) 

• Solution Temperature: 1300 F 

• Surface Tension: Uncontrolled 

• 20 ozlgal total metals (copper and nickel); 10 N nitric acid; balance is water 

• Equipped with air agitation system for mixing (0.35 Wair/min-fil) 

• Emissions captured and treated by Control System 4. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

- 7 -

HorizoD Environmental Corporation 

Technical Support Document 

October 3, 2000 

• 
The new copper/nickel strip tank will operate in the same manner as existing Tank 39. 

Dott Industries, IDe. 

Permit to Install Application 

Lapeer, Michigan 

-8-

Horizon Environmental Corporadon 

Technical Support Document 

October 3, 2000 
3. ESTIMATION OF EMISSIONS 

This section presents emission estimates of toxic air pollutants from the proposed tanks. 

Based on emission levels and/or type of process, a determination is made of whether a tank 

is exempt from permitting or subject to the permitting requirements of MAR Rule 201. 

3.1 CHROME ELECTROPLATING TANK 

This tanks composition will be 40 oz.lgal er03 and 0.14 oz.lgal H2S04, The surface tension 

will be maintained at a maximum of 40 dynes/em. The tank will be vented through Control 

System 1 consisting of a mesh pad mist eliminator and a control efficiency of99%. 

3.1.1 Chromium (VI) Emissions 

According to the US EPA publication "Compilation of Air Pollutant Emission Factors, AP42, Fifth Edition, Volume 1: Stationary Point and Area Sources" ("AP-42" ), Chapter 12, 

Table 12.20-1, the chromium (VI) ("Cr (VI)" ) emission factor for decorative chromium 

electroplating with fume suppressant is 1.2·10-6 grains/dscf. Using this emission factor, Cr 

(VI) emissions from the new chrome tank is equal to: 

1.2.10-6 ~ X 453.6.106 

pg Cr (VI) Emissions = x 

dscf 7,000 gr 

1 ft3 IIg 

= 2.75 -""-'3 

0.0283 m3 m 

The rated control efficiency for the mesh pad is 99%. However, for a control efficiency was 

used in the calculation for conservatism. Using an actual control efficiency of 97%, the 

controlled Cr (VI) emissions are equal to: 

Dott IDdustrles, IDe. 

Pennit to Install Application 

Lapeer, Michigan 

-9-

Horizou EDviroDmentaJ CorporadoD 

Technical Support Document 

October 3,2000 
Controlled Cr (VI) Emissions = 2.75 ,u~ x (I - 0.97) = 0.082 ,u~ m m 

3.1.2 Sulfuric Acid Emissions 

According to AP-42, the majority of the emissions consist of Cr (VI). Sulfuric acid 

emission is considered negligible since the H2S04 concentration in the plating tanks is low 

(0.13 oz.lgal) as compared to erO) concentration of 40 oz./gal. 

3.1.3 Cumulative System 1 Emissions Summary 

System 1 will consist of two chrome electroplating tanks (#32 and the new chrome tank). 

Both tanks are exhausted through a mesh pad mist eliminator with a rated control efficiency 

of99%. 

Chrome VI Emissions 

Chrome VI emissions from the existing chrome tank (Tank 32) is equivalent to new tank's 

emissions, so the total chromium emissions from System 1 are double the emissions from 

the new tank, or 0.164 Jlglml

. 

Sulforic Acid Emissions 

Sulfuric acid emission is considered negligible since the H2S04 concentration in the plating 

tanks is low (0.13 oz./gal) as compared to erO) concentration of 40 oz./gal. 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer. Michigan 

- 10-

Horizon Environmental Corporation 

Technical Support Document 

October 3. 2000 
3.1.4 Regulatory Status for the Proposed Chrome Plating Tank 

Since Chrome emissions from this tank are not released into the general in-plant 

environment and the corresponding IRSL is less than 0.04 mglm3, the proposed chrome 

tank is not considered exempt per MAR Rules 284r)(vii) and 290(a)(ii) and 290(a)(iii). 

Therefore, the proposed chrome plating tank is subject to permitting requirements under 

Rule 201. 

3.2 BRIGHT ACID COPPER TANK 

This tanks composition will be 25 oz.lgal CuS04 and 15 oz.lgal H2S04• Nonnal operating 

surface tension is 55 dynes/em. The tank will be vented through Control System 2 

consisting of a cyclonic mist eliminators and an aerosol control efficiency of a minimum of 

40%. Potential emission from this tank is expected to only consist of sulfuric acid mist. 

3.2.1 Sulfuric Acid Emissions 

Sulfuric acid emissions from the new acid copper tank is 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. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

- 11 -

Horizon Environmental Corporation 

Technical Suppan Document 

October 3, 2000 
E misl = 

x [(1 - 2a + 9a 

2 t 5 

+ (a - 1) ]°05 

(I + 3a) - (1 - 2a + 9a 2 )005 

where: 

E mist = Mist emission factor in grains I ft 3 of aeration air; 

Rb = Average bubble radius, in. = 0.25 inches 

(j = Surface tension of bath, lb r 1ft 

a = 

0.072 x S.G. x R~ 

(j 

S. G. = Specific gravity of the bath 

This correlation allows the calculation of the mist emission rate generated due to air 

agitation. The mist composition is considered to be the same as the bath composition. 

Using this equation, total controlled sulfuric acid emissions from the new bright acid copper 

tank are calculated at 5.2'10'" lblhr, 3.8'10'\ lb/month, and 5.2 J.1g/m3

• The calculation 

details are presented in Table 1 A. 

3.2.2 Cumulative System 2 Emissions Summary 

System 2 will consist of one copper strike tank (# 14) and six bright acid copper tanks (# 15 

through #19 and the new bright acid copper tank), The tank solutions used in each of the 

existing bright acid copper tanks (Tank #15 through #19) are identical to the new tank 

composition. All tanks are exhausted through a cyclone. The control efficiency is 

conservatively estimated at 40%. 

Cumulative Sulforic Acid Emissions 

Sulfuric acid emissions from System 2 are calculated at 3.1'10-3 Iblhr, 2.3 lb/month, and 

31.8 llg/m3, The calculation details are presented in Table 1 B. 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

- 12-

Horizon Environmental Corporation 

Technical Support Docwnent 

October 3,2000 
· 3.2.3 Regulatory Status for the Proposed Bright Acid Copper Tank 

Based on sulfuric acid (ITSL = 10 J.1g!m3

, 8-hour average) emission levels, the proposed 

bright acid copper tank is exempt from pennitting per Rule 290(a)(ii)(A) which state: 

"(a) An emission unit which meets any of the following criteria: 

(i) ... 

(ii) Any emission unit that the total uncontrolled or controlled emissions of air 

contaminants are not more than 1,000 or 500 pounds per month, respectively. and 

all of the following criteria are met: 

(A) For noncarcinogenic air contaminants, excluding noncarcinogenic 

volatile organic compounds and noncarcinogenic materials which are listed in 

R 336.1122(f) as not contributing appreciably to the formation of ozone, with 

inilialthreshold screening levels greater than or equal to 2.0 micrograms per 

cubic meter, the uncontrolled or controlled emissions shall not exceed J, 000 or 

500 pounds per month, respectively. JJ 

3.3 COPPERINICKEL STRIP TANK 

This tank's composition will be made up of nitric acid and water. The nitric acid bath 

concentration will be maintained at a nonnality equal to ION. The tank will be vented 

through Control System 4 consisting of a packed bed scrubber having a rated control 

efficiency of 96% (For purposes of conservative emission calculations, a 95% control 

efficiency was used). 

Only nitric acid mist is expected to be emitted released from this new copper/nickel strip 

tank. Emissions of nitric acid from the new copper/nickel strip tank are mainly due to air 

agitation. The nitric acid emissions are calculated using the approach described above for 

sulfuric acid (Section 3.2.1). Using this approach, nitric acid emissions from the new tank 

are calculated at 1.8'10-4 Iblhr, 1.3'10,1 lb/month, and 4.4 J-lg/m3

, The calculation details are 

presented in Table 2A. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

- 13 - Horizon Environmental Corporadon 

Technical Suppon Document 

October 3, 2000 
3.3.1 Cumulative System 4 Emissions Summary 

System 4 will consist of one neutralizer tank (#5) and two copper/nickel strip tanks (#39 

and the new strip tank). The solution used in Tank 5 contains hydrochloric acid and the 

solution used in Tank 39 and the new tank contains nitric acid. Potential air emissions 

consist of hydrochloric acid from Tank 5 and nitric acid from Tanks #39 and the new tank. 

The tanks are exhausted through a packed bed scrubber having a rated control efficiency of 

96% (For purposes of conservative emission calculations, a 95% control efficiency was 

used). 

Cumulative Nitric Acid Emissions 

Nitric acid emissions from System 4 are calculated at 3.6·10-4 lblhr, 2.6·} 0.1 lb/month, and 

8.8 fJglml

. The ca1culation details are presented in Table 2B. 

Cumulative Hydrochloric Acid Emissions 

Hydrochloric acid emissions from System 4 are calculated at 2.9·10-6 Iblhr, 2.1 .10-3 

Ib/month, and 0.07 fJglm3

• The calculation details are presented in Table 2e. 

3.3.2 Regulatory Status for the Proposed CopperlNickel Strip Tank 

Based on nitric acid (ITSL = 50 fJglm3

, 8-hour average) emission levels, the proposed bright 

copper/nickel strip tank is exempt from permitting per Rule 290(a)(ii)(A) which state: 

"(a) An emission unit which meets any of the follOWing criteria: 

(i) .. : 

Dolt Industries, IDCo 

Permit to Install Application 

Lapeer, Michigan 

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HorizoD EDvironmental CorporatioD 

Technical Support Document 

October 3, 2000 
(ii) Any emission unit that the total uncontrolled or controlled emissions of air 

contaminants are not more than 1,000 or 500 pounds per month, respectively, and 

all of the following criteria are met: 

(A) For noncarcinogenic air contaminants, excluding noncarcinogenic 

volatile organic compounds and noncarcinogenic materials which are listed in 

R 336.JJ22(f) as not contributing appreciably to the formation of ozone, with 

initial threshold screening levels greater than or equal to 2.0 micrograms per 

cubic meter, the uncontrolled or controlled emissions shall not exceed 1,000 or 

500 pounds per month, respectively . .. 

3.4 PRE-CONDITIONER TANK 

This tank's composition will be made up of 15% MicroEtch etching solution and the 

balance is water. Nonnal operating surface tension for this tank will be 55 dynes/em. 

The MicroEtch Solution contains amino-saturated butrolactone. Potential air emissions 

from this tank consist of amino-saturated butrolactone which makes 100% of the Micro Etch 

Solution. The tank will be vented through Control System 5 consisting of a dry mesh pad 

mist eliminator having a rated control efficiency of 99% (For purposes of conservative 

emission calculations, a 97% control efficiency was used). 

3.4.1 Amino-Saturated Butrolactone Emissions 

Emissions of amino-saturated butrolactone from the new preconditioner tank are mainly 

due to air agitation. The amino-saturated butrolactone emissions are calculated using the 

approach described above for sulfuric acid (Section 3.2.1). Using this approach, aminosaturated butrolactone emissions from the new preconditioner tank are calculated at .1.9'10'" 

lblhr, 1.4'10'\ lb/month, and 3.77 J.1g1m3

• The calculation details are presented in Table 3A. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

- 15-

Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
3.4.2 Cumulative System 5 Emissions Summary 

System 5 will consist of one pre-etch tank (#1), two etch tanks (#2A and #2B), and one 

preconditioner tank (new). The tank solutions used in Tanks 1, 2A, and 2B consist of a 

mixture of chromic acid and sulfuric acid. The solution in the new preconditioner tank 

contains amino-saturated butrolactone. Potential air emissions from these tanks include Cr 

(VI), sulfuric acid, and butrolactone. The tanks are exhausted through a dry mesh pad mist 

eliminator having a rated control efficiency of 99% (For purposes of conservative emission 

calculations, a 97% control efficiency was used). 

Cumulative Chrome VI Emissions 

Chrome VI emissions from System 5 are calculated at 1.0·10-4 Iblhr, 7.5.10-2 Ib/month, and 

2.2 J-lglm3

• The calculation details are presented in Table 38. 

Cumulative Sulforic Acid Emissions 

Sulfuric acid emissions from System 5 are calculated at 2.0·10-4 Iblhr, 1.4.10-1 Ib/month, and 

4.3 J-lglm3

• The calculation details are presented in Table 3C. 

Cumu/atiye Amino-Saturated Butro/actone Emissions 

Amino-saturated butrolactone emissions from the new preconditioner tank are calculated at 

1.9·10-4 lblhr, 1.4.10-1 lb/month, and 3.77 J.1g1ml

• The calculation details are presented in 

Table 3A. 

3.4.3 Regulatory Status for the Preconditioner Tank 

Dott Industries, Inc. 

Pennitto Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
Based on amino-saturated butrolactone (ITSL = 0.1 J,lglml, annual trace level) emission 

levels, the proposed bright copper/nickel strip tank is exempt from permitting per Rule 

290(a)(ii)(A) which state: 

"(a) An emission unit which meets any of the following criteria: 

(i) ... 

(U) Any emission unit that the total uncontrolled or controlled emissions of air 

contaminants are not more than 1.000 or 500 pounds per month. respectively, and 

all of the following criteria are met: 

(B) For noncarcinogenic air contaminants. excluding noncarcinogenic 

volatile organic compounds and noncarcinogenic materials which are listed in 

R 336.1122(f) as not contributing appreciably to the formation of ozone, with 

initial threshold screening levels greater than or equal to 0.04 micrograms per 

cubic meter and less than 2.0 micrograms per cubic meter. the uncontrolled or 

controlled emissions shall not exceed 20 or 10 pounds per month. 

respectively . .. 

3.5 SEMI-BRIGHT NICKEL AND BRIGHT NICKEL TANKS 

As stated in Section ??? the semi-bright and bright nickel tanks are used for application of a 

nickel intennediate coat. Air emissions associated with these tanks are considered 

negligible and released into the general in-plant environment. Per MAR Rule 285(r)(vii), 

these tanks are exemtp from the permitting requirements of Rule 201. 

Rule 285(r)(vii) states: 

"(r) Equipment used for any of the following metal treatment processes if the process 

emissions are only released into the general in-plant environment: 

(vii) Electrolytic stripping or electrolytic plating . .. 

Dott Industries, InCo 

Permit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporadon 

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October 3, 2000 
.. 

3.6 EMISSION SUMMARY AND COMPARISON TO FACILITY'S CURRENT ROP LIMITS 

According to the facility's RO Pennit No. 199600451, emission limits for hexavalent 

chromium, sulfuric acid, hydrochloric acid, and fonnaldehyde are either specified by an 

emission unit consistent with an existing Control Systems, or by a flexible grouping 

consisting of several Control Systems. The breakdown is as follows: 

EMISSION LIMITS BY RENEWABLE OPERATING PERMIT GROUP ID 

ROP Control Chrome (VI) H2SO4 HCI Formaldehyde 

GroupID Systems Limit Limit Limit Limit 

Included (J.Lglml

) (mglml) (mglml) (mglml) 

E-l.3 System I 2.9 NA NA NA 

F-l.l System 2 

(contains E-1.4, System 3 NA 4.65 4.65 1.02 

E-l.S, E-1.6) System 4 

E-l.7 System 5 11.5 6.05 NA NA 

All emission limit values are corrected to 70 degrees F and 29.92 inches of mercury. 

Therefore, the estimated air pollutant concentrations were calculated, on a per pollutant 

basis, for each of the three applicable ROP groups. For Group ID numbers E-l.3 and E-l. 7, 

the emissions were consistent with those estimated previously for Control Systems I and 5, 

respectively. Air pollutant concentrations from Group ID F-l.l were calculated by 

summing the mass emission rate of the individual pollutants from each applicable control 

system and dividing by the corresponding total airflow through the applicable systems. For 

example, sulfuric acid mass emissions from Control Systems 2,3, and 4 are added together 

and divided by the sum of the volumetric airflow rates for Control Systems 2, 3, and 4. 

This calculation is shown in Table 4. 

Dott Industries, Inc:. 

Pennit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

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The final ROP group emissions including the proposed equipment are as follows: 

ESTIMATED EMISSION CONCENTRA nONS BY RENEWABLE OPERATING PERMIT GROUP ID 

ROP Control Chrome (VI) H2SO4 HCl Fonnaldehyde 

GroupID Systems Emissions Emissions Emissions Emissions 

Included ijlg/ml) (mg/ml) (mglml) (mglml) 

E-l.3 System 1 0.164 NA NA NA 

F-l.l System 2 NO 

(contains E-1.4, System 3 NA 0.032 0.00003 PROPOSED 

E-1.S, E-1.6) System 4 Changes 

E-l.7 System 5 2.2 0.004 NA NA 

As shown in this table which include emission increases due to the proposed modification, 

chromium (VI) emissions, sulfuric acid emissions, and hydrochloric acid emissions are in 

compliance with the corresponding emission limits specified in RO Pennit No. 199600451. 

Dott Industries, Inc:. 

Pennit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
4. APPU,CABLE REGULATORY REQUIREMENTS 

The proposed chrome plating tank installation will be subject to certain state and federal air 

quality regulations. Requirements applicable to the proposed modification are summarized 

below. 

4.1 MICmGAN AIR QUALITY REQUIREMENTS 

Michigan's Administrative Rules for Air Pollution Control set forth requirements for new or 

modified sources of air contaminants, including sources of TACs. As described below, the 

proposed installation has been designed to comply with all applicable MARs. 

4.1.1 MAR 201- Permits to Install 

Pursuant to MAR 201. '~person shall not install, construct. reconstruct. relocate, alter, or 

modify any process or process equipment, including control equipment pertaining thereto, 

which may emit an air contaminant, unless a permit to install which authorizes such action 

is issued by the department." The proposed addition of a chrome plating tank constitutes a 

modification; consequently, a Permit to Install must be issued by the AQD prior to the 

installation and trial operation of the proposed modification. This technical support 

document constitutes the Permit to Install application for the proposed modification. In 

accordance with MAR 203 (Information Required), the Pennit to Install application form 

(Appendix A) and supporting documentation for the proposed installation are included in 

this submittal. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Support Document 

October 3,2000 
• 

4.1.2 MAR 216 - Modifications to Renewable Operating Permits 

The Dott facility is classified as a major stationary source pursuant to MAR 21 1 (a)(ii) 

(Renewable Operating Permit Applicability). The AQD has issued a Renewable Operating 

Pennit ("ROP" ) for the facility. The tenns and conditions of a Pennit to Install issued after 

receipt of an ROP must be incorporated into the ROP. Of the three possible procedures for 

modifying an ROP, as provided for in MAR 216 and described in detail in AQD 

Operational Memorandum No.2, a Minor Permit Modification will be applicable to the 

requested Pennit to Install. Dott will comply with all applicable Minor Permit Modification 

submittal requirements. 

4.1.3 MAR 225 - Health-Based Screening Level Requirement for New or Modified 

Sources of Air Toxies 

MAR 225 presents emission limitations and control technology requirements for all new or 

modified sources ofTACs. MAR 225 states: 

(1) ':.4 person who is responsible for any proposed new or modified emission 

unit ... which emits a toxic air contaminant (l' A C) shall not cause or allow the 

emission of the toxic air contaminant ... in excess o/the maximum allowable emission 

rate which results in a predicted maximum ambient impact that is more than the 

initial threshold screening level or the initial risk screening level. or both ... 

As required under MAR 225, a conservatively based ambient air quality impact analysis 

was conducted demonstrating compliance with applicable health-based screening levels. 

The results of the impact analysis are summarized in Section 5.0. 

Dott Industries, Inc. 

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• 

4.2 NATIONAL EMISSIONS STANDARDS FOR HAzARDous AIR POLLUTANTS 

The proposed modification is subject to National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for Chromium Emissions from Hard and Decorative Chromium 

Electroplating and Chromium Anodizing Tanks, Subpart N (40 CFR 63.340). This 

standard applies to each chromium electroplating or chromium anodizing tank at facilities 

performing hard chromium electroplating, decorative chromium electroplating, or 

chromium anodizing. Process tanks associated with chromium electroplating or anodizing, 

but in which neither chromium electroplating nor anodizing take place, are not subject to 

the provisions of this subpart. 

The NESHAP requirements listed in Subpart N are summarized as follows: 

• §63.342(a) - "Each owner or operator of an affected source subject to the provisions of 

this subpart shall comply with these requirements on and after the compliance dates 

specified in §63.343(a). All affected sources are regulated by applying maximum 

achievable control technology . .. 

• §63.342(b)(2) - "If an owner or operator is controlling a group of tanks with a common 

add-on air pollution control device, the emission limitations of paragraphs (c), (d), and 

(e) of this section apply whenever one affected source is operated. OJ 

• §63.342(d) - "Standards/or decorative chromium electroplating tanks using a chromic 

acid bath and chromium anodizing tanks. During tank operation, each owner or 

operator of an existing, new, or reconstructed affected source shall control chromium 

emissions discharged to the atmosphere from that affected source by either: 

(1) Not allowing the concentration of total chromium in the exhaust gas stream 

discharged to the atmosphere to exceed O.O} mg/dscm (4.4x}U6 gr/dscf); or 

(2) If a chemical fUme suppressant containing a wetting agent is used, by not 

allowing the surface tension of the electroplating or anodizing bath contained 

Dott Industries, Ine. 

Pennitto Install Application 

Lapeer. Michigan 

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Horizon EDvironmentai Corporation 

Technical Support Document 

October 3, 2000 
within the affocted source to exceed 45 dynes per centimeter (3.1.xl(JJ poundsforce per foot) at any time during operation of the tank. " 

• §63.343(b)(2) - "If the owner or operator of an affected source meets all of the 

following criteria, an initial performance test is not required to be conducted under this 

subpart: 

(i) The affected source is a decorative chromium electroplating tank or a chromium 

anodizing tank; and 

(ii) A wetting agent is used in the plating or anodizing bath to inhibit chromium 

emissions from the affocted source; and 

(iii) The owner or operator complies with the applicable surface tension limit of 

§63.342(d)(2) as demonstrated through the continuous compliance monitoring 

required by paragraph (c)(5)(ii) of this section. " 

§63.343(c)(5)(ii) states that operation of the affected source at a surface tension greater than 

the value established during a performance test, or at a surface tension of greater than 45 

dynes/em if this default value is utilized, shall constitute noncompliance with the standards. 

A specific schedule for bath surface tension testing intervals during operation of the plating 

tank is indicated. 

The standard under §63.342 that applies to the proposed modification is that for surface 

tension. Previous performance testing of the existing decorative chromium-plating tank 

surface tension during normal operations has indicated compliance with the listed standard 

of 45 dynes/em. Since the new decorative chromium-plating tank will use a fume 

suppressant in the bath, and emissions from the new tank will also be treated by the existing 

water-washed mesh pad mist eliminator; the facility is anticipated to remain in compliance 

with the standard following the proposed modification. 

The proposed chromium-plating tank has been designed to comply with all applicable 

NESHAPs. 

DoH Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Suppon Document 

October 3, 2000 
5. AMBIENT AIR QUALI1Y IMPACT ANALYSIS 

Ambient air quality dispersion modeling analyses have been conducted in support of the 

proposed installation of a new chrome plating tank. Utilizing procedures in accordance 

with MARs 240 and 241, AQD1

, and U.S. EPA guidance2

, potential emissions of 

hexavalent chromium due to the operation of the existing and proposed chrome tanks were 

modeled to demonstrate compliance with applicable MAR 225 health-based screening 

levels. This section characterizes the area surrounding the Dott facility and presents the 

dispersion model and modeling databases utilized to demonstrate compliance. 

Dispersion modeling input and output files are submitted in electronic fonnat (diskette) as 

AppendixD. 

5.1 DESCRIPTION OF SITE AREA 

Characteristics of the site area surrounding the Dott facility applicable to the air quality 

impact analysis include land use classification and local topography. A detailed discussion 

of each of the aforementioned characteristics is provided below. 

5.1.1 Land Use Classification 

Annospheric conditions affecting the downwind dispersion of air contaminants may be 

influenced by localized land use. Dispersion coefficients have been developed for both 

rural and urban environments. Based on U.S. EPA guidance, the selection of either rural or 

I Michigan Air Use Permit Manual, Air Quality Division, MDEQ, 1995. 

2 Guideline on Air Quality Models (Revised), Appendix W of 40 CFR Part 51, U.S. EPA, 

1995. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

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October 3, 2000 
urban dispersion coefficients should follow one of the procedures suggested by Irwin3

• 

These include a land use classification procedure, based on a typing scheme recommended 

by Auer\ or a population based procedure. Of the two methods, the land use classification 

procedure is considered more definitive. 

The land use classification procedure is conducted as follows: 

I) Classify the land use within the total area, Ao, circumscribed by a 3 Ian radius circle 

about the source using Auer's land use typing scheme; 

2) If land use type 11, 12, CI, R2, and R3 account for 50 percent or more of Ao, use 

urban dispersion coefficients; otherwise, use appropriate rural dispersion 

coefficients. 

Table 5 summarizes Auer's land use typing scheme. Utilizing a U.S.G.S. topographic 

projection (Lapeer Quadrangle), land use surrounding the Dott facility has been assessed 

and can be considered rural. Consistent with previous modeling analyses conducted in 

support of the Dott facility, rural dispersion coefficients were used in the dispersion model 

simulations. 

5.1.2 Topography 

Elevated terrain features may affect the transport of atmospheric contaminants as well as 

serve as areas of potentially higher pollutant impacts. Where appropriate, terrain features 

should be included in the modeling analysis. The AQD generally recommends that terrain 

3 Proposed Criteria for Selection of Urban Versus Rural Dispersion Coefficients, Draft Staff 

Report, u.s. EPA, 1978. 

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Permit to Install Application 

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October 3, 2000 
elevations exceeding ~ the height of the shortest stack at a facility be included in the 

modeling analysis. 

Terrain immediately surrounding the Dott facility may be characterized as relatively flat 

with few distinguishable terrain features. Consequently, terrain elevations were not 

included in the dispersion modeling analysis. 

5.2 DISPERSION MODEL 

U.S. EPA's Industrial Source Complex Model, Version 3 ("ISC3" , Release No. 98356) 

was utilized in the air quality impact analysis. ISC3 is a steady-state Gaussian plume model 

recommended by U.S. EPA for assessing pollutant impacts from facilities with emission 

points influenced by building downwash, such as the Dott facility. 

ISC3 consists of a short-term and a long-term model. The short-tenn model utilizes hourly 

meteorological data while the long-term model processes a frequency distribution of wind 

speed, wind direction, and atmospheric stability. In accordance with AQD guidanceS, the 

short-tenn version of ISC3 was employed in the air quality impact analysis. 

Major features of ISC3 applicable to this air quality impact analysis include: 

• Rural dispersion coefficients; 

• Concentration estimates for 24-hour and annual averaging times; 

• Concentration estimates over flat terrain; 

• Consideration of building downwash effects; and 

4 Correlation of Land Use and Cover with Meteorological Anomalies, Journal of Applied 

Meteorology, 1978. 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Suppon Document 

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• Treatment of calm wind conditions. 

5.2.1 Building Downwash Effects 

Plumes potentially emitted from the proposed baghouse exhaust stack may be influenced by 

aerodynamic downwash. Consequently, u.s. EPA's recommended Building Profile Input 

Program ("BPIP" , Release No. 95086) was utilized to estimate maximum projected lateral 

and vertical building dimensions on a wind direction-specific basis. Dimensions of all 

existing structures that could potentially influence emissions from the Control System 1 

stack (serving the two chrome electroplating tanks) were input to BPIP. Maximum 

projected lateral and vertical building dimensions, as estimated by BPIP, were subsequently 

input to ISC3. 

Building projections in relation to emission points are illustrated in Figure 1. Input/Output 

files for the BPIP simulations are submitted in electronic fonnat (diskette) as Appendix D to 

this document. 

5.3 DATABASES USED IN AIR QUALIlY IMPACT ANALYSIS 

Databases required as input to the air quality dispersion model consist of meteorological 

data, receptor points and emission inventory data. A discussion of the databases utilized in 

the ambient air quality impact assessment is presented below. 

S Michigan Air Use Permit Manual, Air Quality Dispersion Modeling, Air Quality Division, 

1995. 

Dott Industries, Inc. 

Pennit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

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, 

5.3.1 Meteorological Data 

The AQD generally requires the use of the most spatially and temporally representative 

one-year meteorological databases when conducting dispersion model simulations in 

support of MAR 225 compliance demonstrations. The most spatially representative off-site 

meteorological database available for general use consists of surface and coincident upper 

air observations measured at the Flint Bishop Airport located in Flint, Michigan (Station 

No. 94826). The most recently available year (1991) was obtained from the AQD's web 

site and subsequently employed in the modeling demonstration. 

5.3.2 Receptor Points 

ISC3-predicted concentrations may be estimated at discrete receptor locations. A discrete 

receptor grid was designed to identify maximum predicted impacts due to the proposed 

modification. The following methodology was utilized in designing the receptor grid: 

• Receptors were located along property boundaries at distances not exceeding 25 meters; 

and 

• Additional receptors were located off-property 10 a manner sufficient to identify 

maximum impacts. 

The receptor grid used in the air quality impact analysis extends 800 meters from the 

Control System 1 stack. Consisting of 362 discrete points, the receptor grid is illustrated in 

Figure 2. 

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Horizon Environmental Corporation 

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, 

5.3.3 Emission Inventory 

Emission inventory data required as input to ISC3 includes emission rate, stack location, 

stack height, inside diameter, exit temperature, and exit velocity. Potential pound per hour 

and gram per second hexavalent chromium emission rates were derived from emission 

estimates calculated in Section 3.1.3. Exhaust characteristics of the Control System I stack, 

are summari zed as follows: 

Emission Rate: 

Stack Location: 

Stack Height: 

Inside Diameter: 

Exit Temperature: 

Flow Rate: 

Exit Velocity: 

5.5 AIR Q UALtTY IMPAct 

0.0000079 pounds per hour 

0.000000992 grams per second 

(13.6 meters easting, 4.4 meters northing) 

50.0 rcct (15.24 metcrs) 

32.0 inches (0.8 1 meters) 

90 dcg. Fahrcnheit (305.4 Kelvin) 

13,300 actual cubic fect per minute (at stack) 

39.6 fee t per second (12.07 meters per second) 

MAR 225(1} requires new or modified sources ofTAC emissions to demonstrate that the 

ambient impact of each regulated TAC emitted is less than its corresponding initial 

threshold screening level (" ITSL"), initial risk screening level (" IRSL" ), or both. The 

AQD has published a hexavalent chromium ITSL of 8.0 x 10·) yiglm) (24-hour averaging 

period) and an IRSL of8.3 x 10" g/ J (annual avcraging period). 

Utilizing ISC3 over a one-year meteorological database (199 1 Flint/Flint), the Control 

System 1 stack was modeled and resultant maximum predicted concentrations compared 

against the published screening values. Maximum predicted hexavalent ehromiwn impacts 

are summari zed in Table 6. As shown in Table 6, the maximum predicted 24-hour average 

hexavalent chromium impact of2 x 10·' yiglm) is well under the published ITSL of 8.0 x 10· 

Dott InduSlritS, Inc. 

PumillO Insm]] Applicalion 

Lapeer, '\1ichigun 

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Ilorb.on En"ironmenlal Carponlton 

Technical Suppon Documenl 

Oclober 3,2000 
3 J.1g1m3

; while, the maximum predicted annual average hexavalent chromium impact of 2 x 

10-6 Jlg/m3 is well under the published IRSL of 8.3 x 10·s Jlglm3

• 

As described above, the conservatively based dispersion modeling analyses indicate that the 

proposed modification will not threaten published hexavalent chromium health-based 

screening levels. 

Dott Industries, Inc. 

Permit to Install Application 

Lapeer, Michigan 

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Horizon Environmental Corporation 

Technical Support Document 

October 3, 2000 
APPENDIXA 

Permit to Install Application Form 
APPENDIXB 

Facility Plot Plans 
.. 

APPENDIXC 

Material Safety Data Sheets 
• 

APPENDIXD 

Dispersion Modeling Input/Output Files (Diskette)