Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
B1606
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-B1606-2014
General Motors LLC, Flint Assembly
SRN: B1606
Located at
G-3100, Van Slyke, Flint, Michigan 48551
Permit Number:
MI-ROP-B1606-2014
Staff Report Date: July 14, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution
Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act
451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ),
Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions
of the Renewable Operating Permit (ROP).
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TABLE OF CONTENTS
STAFF REPORT
3
August 8, 2014 STAFF REPORT ADDENDUM
8
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
B1606
STAFF REPORT
ROP Number
MI-ROP-B1606-2014
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s
Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to
the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a
stationary source’s applicable requirements and compliance with them by consolidating all state and
federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the
draft permit terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any
determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the
stationary source.
General Information
Stationary Source Mailing Address:
General Motors LLC, Flint Assembly Plant
G-3100 Van Slyke Road
Flint, Michigan 48551
B1606
336112
Source Registration Number (SRN):
North American Industry Classification System
(NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial Issuance?
Application Number:
Responsible Official:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
1
Renewal
201400005
Amy Farmer, Complex Director
810-236-1393
Robert Byrnes, Senior Environmental Engineer
517-284-6632
January 10, 2014
January 10, 2014
Yes
July 14, 2014
August 13, 2014
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Source Description
General Motor’s Flint Assembly plant is principally involved in the manufacturing of light-duty trucks.
Significant emission sources at the facility include VOC emissions from the application of primer and
topcoat coatings to truck bodies. These emissions are controlled with a regenerative thermal oxidizer.
In addition, the facility has two natural gas fired boilers and three dual fuel steam generating boilers
equipped with low NOx burners.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2012 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
Tons per Year
13.8
not reported
66.3
1.3
0.3
790.9
Not Calculated
Not Calculated
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases in tons per year of CO2e is 747,378. CO2e is a calculation of the combined global
warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are
subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff
Report and identified in Part E of the ROP.
The stationary source is located in Genesee County, which is currently designated by the United States
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because
the potential to emit Volatile Organic Compounds and Nitrogen Oxides exceeds 100 tons per year; the
potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is equal to or
more than 10 tons per year; and the potential to emit of all HAPs combined is more than 25 tons per year
and the potential to emit of Greenhouse Gases is 100,000 tons per year or more calculated as carbon
dioxide equivalents (CO2e) and 100 tons per year or more on a mass basis.
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory
Greenhouse Gas Reporting Rule under 40 CFR Part 98 is not an ROP applicable requirement and is not
included in the ROP.
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The stationary source has emission units that were subject to Act 451, Part 55, Rule 220 for Major
Sources Impacting Nonattainment Areas at the time of New Source Review permitting.
EU-12PRIMERSURF and EU-14TOPCOAT at the stationary source are subject to the Standards of
Performance for Automobile and Light Duty Truck Surface Coating Operations promulgated in 40 CFR,
Part 60, Subparts A and MM. However, these requirements have been subsumed as described in the
Streamlined/Subsumed Requirements listed in the table below.
EU-11ELPO, EU-12PRIMERSURF, EU-14TOPCOAT, EU-15SEALADHESIV, EU-16MISCSOLVENT,
and EU-MDFINALREPAIR at the stationary source are subject to the National Emission Standard for
Hazardous Air Pollutants for Surface Coating of Automobiles and Light-Duty Trucks promulgated in 40
CFR, Part 63, Subparts A and IIII.
EU-FIREPUMPENGINE#1, EU-FIREPUMPENGINE#2, EU-NATGASGENERATOR#1,
EU-NATGASGENERATOR#2, EU-NATGASGENERATOR#3, EU-NATGASGENERATOR#4,
EU-NATGASGENERATOR#5, and EU-NATGASGENERATOR#6, at the stationary source are subject to
the National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines (RICE) promulgated in 40 CFR, Part 63, Subparts A and ZZZZ.
EU-BOILER5, EU-BOILER6, EU-BOILER7, and EU-BOILER8 at the stationary source are subject to the
National Emission Standard for Hazardous Air Pollutants for Industrial, Commercial, and Institutional
Boilers and Process Heaters promulgated in 40 CFR, Part 63, Subparts A and DDDDD.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring
Submittals".
EU-12PRIMERSURF and EU-14TOPCOAT at the stationary source is subject to the federal Compliance
Assurance Monitoring (CAM) rule under 40 CFR, Part 64. This emission unit has a control device and
potential pre-control emissions of Volatile Organic Compounds greater than the major source threshold
level. The monitoring for the control device is continuously recording the thermal oxidizer combustion
temperature during coating operations, recording a description of why and the length of time any bypass
line is opened during coating operations and records of maintenance inspections for the thermal oxidizer
and the dates and reasons for repairs.
Please refer to Parts B, C, and D in the draft ROP for detailed regulatory citations for the stationary
source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a
footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-B1606-2014 are identified in Appendix 6 of the ROP.
226-80D
1032-78A
PTI Number
1013-91
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241-83B
Streamlined/Subsumed Requirements
The following table lists explanations of any streamlined/subsumed requirements included in the ROP
pursuant to Rules 213(2) and 213(6). All subsumed requirements are enforceable under the streamlined
requirement that subsumes them.
Emission
Unit/Flexible
Group ID
EU12PRIMERSURF
Condition
Number
EU-14TOPCOAT
SC I.4
12.2 lbs
VOC/GAC (Rule
702(c) state
BACT in a PTI)
EU12PRIMERSURF
and
EU-14TOPCOAT
SC VI.1
FG-COATLINE
SC VI.1
Records under
SC VI.1 to
calculate
emissions
according to the
“Auto Protocol” in
publication EPA450/3-88-018.
Testing SC V.1
and Monitoring
SC VI.1
FG-COATLINE
EU12PRIMERSURF
and
EU-14TOPCOAT
SC VII.2
SC I.4
Streamlined
Limit/
Requirement
9.0 lbs VOC/GAC
(Rule 702(c) state
BACT in a PTI)
Semi-annual
reporting of
deviations under
SC VII.2
Subsumed Limit/
Requirement
Stringency Analysis
1.4 kg VOC/LAC
equivalent to 11.66
lbs VOC/GAC.
Standards for Volatile
Organic Compounds
under 40 CFR
60.392(b)
1.47 kg VOC/LAC
equivalent to 12.24
lbs VOC/GAC.
Standards for Volatile
Organic Compounds
under 40
CFR60.392(c)
Performance test and
Compliance
provisions under 40
CFR 60.393.
Streamlined requirement
is 2.66 lbs VOC/GAC
lower.
Monitoring of
emissions and
operations under 40
CFR 60.394.
Records that show the
subsumed limit in SC I.4
is met, and is equivalent
to records required
under 40 CFR Subpart
MM.
Semi-Annual reporting
of deviations is
equivalent as it has
more detailed
information than simply
reporting emissions are
over or under the limit.
Reporting and
recordkeeping
requirements under
40 CFR 60.395
Streamlined requirement
is .04 lbs VOC/GAC
lower or essentially
equivalent.
Compliance provisions
under the Auto Protocol
are considered more
stringent as they are
equivalent to keeping a
daily record of VOC
emissions.
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the
AQD, if any were proposed in the application. These determinations are incorporated into the permit
shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
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Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under
Rule 212(4). These processes are not subject to any process-specific emission limits or standards in
any applicable requirement.
Exempt
Emission Unit ID
EU-Natural Gas
EU-Tank-5N
EU-Tank-13N
EU-Tank-14N
EU-TANK-RECLAIM
Description of
Exempt Emission Unit
Natural gas-fired equipment such as
space heaters, door heaters, and
water heaters
Antifreeze storage tank (UST)
Antifreeze storage tank (UST)
Purge solvent tank (UST)
Reclaim purge solvent tank (AST)
Rule 212(4)
Exemption
Rule 282(b)(i)
Rule 201
Exemption
Rule 212(4)(b)
Rule 284(i)
Rule 284(i)
Rule 284(i)
Rule 284(i)
Rule 212(4)(c)
Rule 212(4)(c)
Rule 212(4)(c)
Rule 212(4)(c)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree
upon pursuant to Rule 214(2).
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public
and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit.
In addition, the USEPA is allowed up to 45 days to review the draft permit and related material. The
AQD is not required to accept recommendations that are not based on applicable requirements. The
delegated decision maker for the AQD is Michael F. McClellan, Lansing District Supervisor. The final
determination for ROP approval/disapproval will be based on the contents of the permit application, a
judgment that the stationary source will be able to comply with applicable emission limits and other terms
and conditions, and resolution of any objections by the USEPA.
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
B1606
August 8, 2014 STAFF REPORT ADDENDUM
MI-ROP-B1606-2014
Purpose
A Staff Report dated July 14, 2013, was developed in order to set forth the applicable requirements and
factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by
R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments
received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In
addition, this addendum describes any changes to the draft ROP resulting from these pertinent
comments.
General Information
Responsible Official:
AQD Contact:
Amy Farmer, Complex Director
810-236-1393
Robert Byrnes, Senior Environmental Engineer
517-284-6632
Summary of Pertinent Comments
GM Comment:
Page 14 of the Draft ROP – EU-BOILER7 is not subject to requirements of FG-BOILERS and therefore
reference to Flexible Group ID FG-BOILERS should be removed. See attached page 14 with suggested
correction.
AQD Response:
The AQD agrees with these changes and has removed the reference to Flexible Group ID FG-BOILERS.
GM Comment:
Page 37 of the Draft ROP – EU-BOILER7 is not subject to requirements of FG-BOILERS and therefore
reference to EU-BOILER7 should be removed from Associated Emission Unit IDs. See attached page
37 with suggested correction.
AQD Response:
The AQD agrees with these changes and has removed the reference to EU-BOILER7.
EPA Comment:
EU-12PRIMERSURF SC VI.5 (page 20 of the draft ROP) is a streamlined permit requirement that
ensures compliance with the volatile organic compound compliance provisions of 40 C.F.R.§60.393.
Please include within the Staff Report a discussion of the streamlined requirement, the subsumed
requirements, and a justification explaining why the streamlined requirement is as stringent as the
subsumed requirements.
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AQD Response:
The AQD has added to the Streamlined/Subsumed Requirements table to better describe the subsumed
requirements. The performance tests and compliance provisions required under 40 CFR 60.393 are
subsumed by the requirement to use the EPA “Auto Protocol”. The Auto Protocol is recognized as daily
recordkeeping which is more stringent than NSPS MM. The Auto Protocol also specifically outlines how
emission limits in Lbs VOC/GAC are to be calculated.
EPA Comment:
FG-COATLINE SC VI.1 (page 39 of the draft ROP) is a streamlined permit requirement that will
determine compliance with regenerative thermal oxidizer monitoring requirements in 40 C.F.R.§§60.394
and 60.395. Please include within the Staff Report a discussion of the streamlined requirement, the
subsumed requirements, and a justification explaining why the streamlined requirement is as stringent as
the subsumed requirements.
AQD Response:
The AQD has added to the Streamlined/Subsumed Requirements table to better describe the subsumed
requirements. The performance tests and compliance provisions required under 40 CFR 60.394 are
subsumed by the continuous oxidizer temperature monitoring requirements. The Reporting and
Recordkeeping requirements under 40 CFR 60.395 are subsumed by the Semi-Annual reporting of all
deviations under the General Conditions of the ROP and under SC VI.2 of all EU and FG portions of the
ROP.
EPA Comment:
FG-MACT LIGHT DUTY SC III.1 (page 43 of the draft ROP) cites, in part, 40 C.F.R.§63.4493(b) and (c)
as its origin and authority. 40 C.F.R.§63.4493 is part of 40 C.F.R.63, Subpart PPPP. However, on page
5 of the Staff Report, the emission units within FG-MACT LIGHT DUTY were instead determined to be
subject to 40 C.F.R. 63, Subpart IIII. The citation to origin and authority should be corrected to reflect the
appropriate applicable requirements from 40 C.F.R. 63 Subpart IIII.
AQD Response:
The AQD has removed the reference to 40 CFR 63.4493 and has added the applicable requirement of
40 CFR 63.3094.
EPA Comment:
FG-BOILERS SC VI (page 66 of the draft ROP) includes monitoring and recordkeeping requirements
intended to demonstrate compliance with the Sulfur Dioxide (SO2) limits in SC I.1 through I.4. SC VI
requires the Permittee to record the sulfur content and BTU value of for each shipment of fuel oil in the
boilers but does not require the applicant to record the amount of fuel used by each boiler or otherwise
require the Permittee to calculate SO2 emissions from the boilers. Please explain how monthly and
annual SO2 emissions from the boilers are determined and add monitoring and recordkeeping
requirements to the ROP as necessary to ensure compliance with the SO2 emission limits.
AQD Response:
The AQD has added to conditions to the recordkeeping portion of FG-BOILERS. The permittee shall
keep records of the monthly hours of operation and fuel usage. The permittee shall also calculate the
SO2 Lbs per hour and 12 month rolling mass emissions on a monthly basis.
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