Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
B1991
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-B1991-2015
GENERAL MOTORS, LLC
General Motors, LLC - Saginaw Metal Casting
SRN: B1991
Located at
1629 North Washington, Saginaw, Saginaw County, Michigan 48601
Permit Number:
MI-ROP-B1991-2015
Staff Report Date:
June 15, 2015
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
JUNE 15, 2015 STAFF REPORT
3
AUGUST 5, 2015 STAFF REPORT ADDENDUM
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10
Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
B1991
RENEWABLE OPERATING PERMIT
JUNE 15, 2015 STAFF REPORT
ROP Number
MI-ROP-B1991-2015
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 - Saginaw Metal Casting
1629 North Washington
Saginaw, Michigan 48601
B1991
331524
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
201400023
John Lancaster, Plant Manager
989-757-1433
Kathy Brewer, Environmental Quality Analyst
989-894-6214
January 29, 2014
January 29, 2014
Yes
June 15, 2015
July 15, 2015
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Source Description
General Motors, LLC – Saginaw Metal Casting (SMCO), is located at 1629 North Washington, Saginaw,
Michigan. The facility operates an aluminum casting foundry for the production of engine blocks and
heads for the automotive market. The facility operates one green sand aluminum line and is in the
process of starting a new precision sand aluminum line and new semi-permanent molding aluminum
lines. The site has pre-machining, sand handling and casting, aluminum melting, pouring, cooling, and
cast finishing.
Support operations include powerhouse operations and industrial wastewater
pretreatment.
SMCO ceased the lost foam aluminum lines operations at the site in 2012. Additionally, 2 boilers that
operated at the site and part of the former GM Global Energy and Utilities Services been
decommissioned and all existing utilities equipment is owned and operated by SMCO.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2014 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Tons per Year
42.4
41.3
88.6
0.3
206.6
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 402,923. 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 Saginaw County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants. The
stationary source is subject to 40 CFR, Part 70 because of the potential to emit nitrogen oxides, carbon
monoxide, and volatile organic compounds (VOC), and particulate matter (PM) exceeds 100 tons. The
stationary source is subject to Prevention of Significant Deterioration (PSD) (40 CFR 52.21) regulations
because the stationary source has the potential to emit nitrogen oxides, carbon monoxide, VOC, and PM
greater than 250 tons per year. The stationary source is considered a major source of Hazardous Air
Pollutant (HAP) emissions because the potential to emit any single HAP regulated by the Clean Air Act,
Section 112 is greater than 10 tons per year and the potential to emit all HAPs combined is greater than
25 tons per year. The stationary source 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 is not subject to the National Emission Standard for Hazardous Air Pollutants
(NESHAP) for Secondary Aluminum Production promulgated in 40 CFR, Part 61 Subparts A and RRR.
The facility has undergone changes in production activity since the last ROP issuance in 2009. The site
ceased lost foam operation in July 2012 and a precision sand operation has been shut down. PTI No.
36-12 was issued for new precision sand aluminum casting and new semi-permanent molding aluminum
casting operations. Mold Line 6 remains and much of the existing air pollution control equipment
remains in use with the new production processes.
Fuel Oil capability has been permanently dismantled for each emission unit under FG-BOILER. Two of
the four boilers have been decommissioned.
The facility signed Consent Order AQD No. 53-2014 on October 23, 2014, to resolve reported emission
limit exceedances for particulate matter and VOCs based on emission test report results.
EU-RWTF, EU-PATTERNSHOP, EU-FIREPUMP1, and EU-FIREPUMP2 at the stationary source are
subject to the NESHAP for Stationary Reciprocating Internal Combustion Engines promulgated in 40
CFR, Part 63, Subparts A and ZZZZ
EU-Boiler3 and EU-Boiler4 at the stationary source are subject to the NESHAP 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."
The following emission units at the stationary source are subject to the federal Compliance Assurance
Monitoring (CAM) rule under 40 CFR, Part 64. These emission units have a control device and potential
pre-control emissions of greater than the major source threshold level.
Description
Permit
Condition
CAM
Threshold
Pollutant
PM
EU-6ML-DC-67
VI. 3 through 5
FG-6ML-MOLDSAND
1. EU-6CR-ISO-04
2. EU-6CR-DC-69
FG-6ML-WASTESAND
1. EU-6ML-DC-01
2. EU-6ML-DC-66
3. EU-6ML-DC-77
4. EU-6ML-DC-78
VI. 3 through 7
1. VOC
2. PM
VI. 2 through 4
PM
EUPSANDCOREROOM
Core making 6 cold box
core machines.
VI. 4 through 10
VOCs
Page: 5
Control
Equipment
Monitoring
47,000 scfm
wet dust
collector
Acid scrubber,
Wet dust
collector
(4) wet dust
collectors
DP, liquid flow
25,000 scfm
cyclone &
packed tower
acid scrubber
DP, liquid flow, plus
pH on scrubber
DP, liquid flow
liquid flow, pH, DP
EU-PSANDCASTLINE
1. Shake out
2. Pouring &
Cooling,
Shakeout
VI. 3 through 9
1. PM
2. VOCs
EU-PSANDSCCSH
Casting cooling & sand
handling
EU-SPMCASTLINE
VI. 3 through 8
PM
VI. 3 through 9
PM
1. 30,000 scfm
fabric filter
2. 30,000 scfm
cartridge
collector
Both exhaust to
60,000 scfm
RTO
35,000
cartridge
collector
(3) 60,000 scfm
fabric filters
DP on fabric filter,
Temp on RTO
DP
DP
EU-PSANDPROCESS is subject to the Standards of Performance for Calciners and Dryers promulgated
in 40 CFR, Part 60, Subparts A and UUU. The precontrol particulate emissions from each of the two
sand claim units with individual control devices in EU-PSANDPROCESS are expected to be less than 11
tons per year, are less than the major threshold levels, and do not require visible emission monitoring per
40 CRF Part 60.734 (c) and USEPA ADI No.0000056. The facility has an approved Malfunction
Abatement Plan (MAP) that contains control device monitoring requirements.
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-B1991-2009 are identified in Appendix 6 of the ROP.
PTI Number
100-73
101-73
102-73
103-73
307-74
24-75
96-84
191-84
553-86A
68-90
455-91
456-91
457-91
458-91
368-94A
412-97D
42-02
109-03
110-03
192-08
148-00
186-01
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and
213(6).
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
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shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
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
Description of
Exempt Emission Unit
Cold cleaner that has air/vapor
EU-COLDCLNR
interface of not more than10 square
feet
Portable blast cleaning equipment
used during construction to clean
new water tanks or other new
structures if the tank or structure is
not located closer than the lesser of
EU750 feet or 5 times the height of the
PORTABLEBLAST
structure to nearest residential,
commercial, or public facility and the
abrasive media is low dusting
material that does not contain more
than 5% crystalline silica.
Containers, reservoirs, or tanks used
exclusively for any of the following:
Gasoline or natural gas storage and
handling equipment, as follows:
EU-BULKSTORAGE
Gasoline storage and handling
equipment at loading facilities
handling less than 20,000 gallons per
day or at dispensing facilities.
Containers, reservoirs, or tanks used
exclusively for any of the following:
Storage or transfer operations of
volatile organic compounds or
noncarcinogenic liquids in a vessel
EU-BULKSTORAGE
that has a capacity of not more than
40,000 gallons where the contents
have a true vapor pressure of not
more than 1.5 psia at the actual
storage conditions.
Internal combustion engines that
FGhave less than 10,000,000 Btu/hour
EMERGENCYRICE
maximum heat input.
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Rule 212(4)
Exemption
Rule 201
Exemption
R 336.1281(h)
R 336.1212(4)(a)
R 336.1281(j)
R 336.1212(4)(a)
R 336.1284(g)(i))
R 336.1212(4)(c)
R 336.1284(i)
R 336.1212(4)(c)
R 336.1285(g)
R 336.1212(4)(d)
EUSPACEHEATERS
EUMAINMACH, EUSHOP
EU-MAINMACH
EU-SHOP
Fuel-burning equipment which is
used for space heating, service water
heating, electric power generation, oil
and gas production or processing, or
indirect heating and which burns only
the following fuels: Sweet natural
gas, synthetic gas, liquefied
petroleum gas, or a combination
thereof and the equipment has a
rated heat input capacity of not more
than 50,000,000 BTU per hour.
The following equipment and any
exhaust system or collector
exclusively serving the equipment:
Equipment for carving, cutting
routing, turning, drilling, machining,
sawing, surface grinding, sanding,
planing, buffing, sand blast cleaning,
shot blasting, shot peening, or
polishing ceramic artwork, leather,
metals, plastics, concrete, rubber,
paper stock, wood, or wood products
which meets any of the following:
Equipment used on a nonproduction
basis.
The following equipment and any
exhaust system or collector
exclusively serving the equipment:
Equipment for carving, cutting,
routing, turning, drilling, machining,
sawing, surface grinding, sanding,
planing, buffing, sand blast cleaning,
shot blasting, shot peening, or
polishing ceramic artwork, leather,
metals, plastics, concrete, rubber,
paper stock, wood, or wood products
which meets any of the following:
Equipment has emissions that are
released only into the general inplant environment.
The following equipment and any
exhaust system or collector
exclusively serving the equipment:
Equipment for carving, cutting,
routing, turning, drilling, machining,
sawing, surface grinding, sanding,
planing, buffing, sand blast cleaning,
shot blasting, shot peening, or
polishing ceramic artwork, leather,
metals, plastics, concrete, rubber,
paper stock, wood, or wood products
which meets any of the following:
Equipment has externally vented
emissions controlled by an
Page: 8
R 336.1282(b)(i)
R 336.1212(4)(b)
R 336.1285(l)(vi)(A)
R 336.1212(4)(d)
R 336.1285(l)(vi)(B)
R 336.1212(4)(d)
R 336.1285(l)(vi)(C)
R 336.1212(4)(d)
EUMAINPAINTBOOTH
EU-MOLDCOAT
appropriately designed and operated
fabric filter collector that, for all
specific operations with metal, is
preceded by a mechanical
precleaner.
A surface coating line if all of the
following conditions are met: The
coating use rate is not more than 200
gallons, as applied, minus water, per
month.
A surface coating line if all of the
following conditions are met: Any
exhaust system that serves only
coating spray equipment is supplied
with a properly installed and
operating particulate control system.
R 336.1287(c)(i)
R 336.1212(4)(c)
R 336.1287(c)(ii)
R 336.1212(4)(e)
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 U.S. Environmental Protection Agency (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 Chris Hare, Saginaw
Bay 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
B1991
AUGUST 5, 2015 STAFF REPORT ADDENDUM
MI-ROP-B1991-2015
Purpose
A Staff Report dated June 15, 2015, 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:
John Lancaster, Plant Manager
989-757-1433
Sydney Bruestle, Environmental Quality Analyst
989-894-6216
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
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