Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
A5496
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-A5496-2014
PRECISION COATINGS, INC.
SRN: A5496
Located at
8120 Goldie Street, Walled Lake, Oakland, Michigan 48390-0155
Permit Number:
MI-ROP-A5496-2014
Staff Report Date:
April 21, 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
April 21, 2014 STAFF REPORT
3
July 16, 2014 STAFF REPORT ADDENDUM
7
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
A5496
April 21, 2014 STAFF REPORT
ROP Number
MI-ROP-A5496-2014
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:
Precision Coatings, Inc.
8120 Goldie Street
Walled Lake, Michigan 48390
A5496
326113 (SIC 3081)
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:
One (1)
Renewal
201300202
Mr. Robin Van Tilburg
Vice President, Operations
Phone: 248-363-8321, Ext. 349
Cell: 248-766-0727
E-mail: rvantilburg@pcicoatings.com
Mr. Iranna Konanahalli
Senior Environmental Engineer
586-753-3741 or konanahallii@michigan.gov
12/13/2013
12/26/2013
Yes
4/21/2014
5/21/2014
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Source Description
Founded in 1970, Precision Coatings, Inc. is located in City of Walled Lake (Plant: Walled Lake, MI
48390, P.O. Commerce Township, MI 48390-4107), County of Oakland (at 8120 Goldie Street just west
of Haggerty Road and north of Pontiac Trail and Oakley Park Road). Precision Coatings is a specialty
chemical and web coating company. Precision Coatings applies coatings to extremely specialized
substrates, usually some type of film. Precision Coatings accomplishes film coating with four (4) web
coating lines. The coatings contain organic solvents that are known as volatile organic compounds if the
solvents are photochemically reactive to form atmospheric ozone or smog. Each web coating line has an
enclosed room, where web coating takes place, to capture volatile organic compounds for eventual
destruction. Each web coating line is also equipped with a laminator and a curing oven. Each curing
oven emissions of volatile organic compounds are captured as well for destruction. The destruction of
volatile organic compounds takes place in a combination of the three regenerative thermal oxidizers (3
RTOs).
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the MAERS-2012 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Tons per Year
Carbon Monoxide (CO)
NA
Lead (Pb)
NA
Nitrogen Oxides (NOx)
NA
Particulate Matter (PM)
NA
Sulfur Dioxide (SO2)
NA
Volatile Organic Compounds (VOCs)
6
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
1
Note: Please refer to the addendum for additional emissions information.
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
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 less than 100,000. 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.
8-hour ozone standard: The ozone National Ambient Air Quality Standard was revised by the EPA on
March 12, 2008 to 0.075 ppm and became effective on May 27, 2008. To attain this 2008 standard, the
3-year average of the 4th highest daily maximum 8-hour average concentration within an area must not
exceed 0.075 ppm. On June 29, 2009, the Southeast Michigan area was redesignated to
attainment. These counties are St. Clair, Livingston, Washtenaw, Lenawee, Monroe, Oakland, Macomb,
and Wayne. Allegan county was redesignated to attainment on September 24, 2010. Every county in
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Michigan is currently designated as attainment. The old 1-hour ozone standard was revoked for Michigan
on July 15, 2005.
PM2.5: Oakland (63) County is currently designated by the U.S. Environmental Protection Agency
(USEPA) as a non-attainment area with respect to the 2.5 micron size particulate matter standard (PM
2.5). The EPA established a new standard for very fine particles (2.5 micrometers or less), which are a
particular concern for lung and cardiovascular effects. Annual arithmetic mean not to exceed 15
micrograms per cubic meter (µg/m3) (based on a three-year average); or 98th percentile of 24-hour
concentration not to exceed 35 µg/m3 (based on a three-year average). Under the Clean Air Act, those
areas that violate the NAAQS, or are nearby and contribute to a violation, are considered
"nonattainment." In 2006, the EPA maintained the annual standard at 15 µg/m3 and revised the NAAQS
PM 2.5 24 hour by reducing it to 35 µg/m3. The EPA designated seven counties in the Detroit-Ann Arbor
Metropolitan Statistical Area (Southeast Michigan) as nonattainment for the annual and 24 hour PM 2.5
NAAQS: Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw and Wayne counties. Air quality
monitoring data collected in the 2007 - 2010 period showed all seven counties in Southeast Michigan in
attainment for the PM 2.5 annual and daily NAAQS.
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 exceeds 100 tons per year.
 the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is
more than 10 tons per year and/or the potential to emit of all HAPs combined is more than 25
tons per year.
PSD: The stationary source is considered a “synthetic minor” source in regards to the Prevention of
Significant Deterioration regulations of Title 40 of the Code of Federal Regulations (CFR), Part 52.21,
because the stationary source accepted legally enforceable permit conditions limiting the potential to
emit of volatile organic compounds to less than 250 tons per year (MI-ROP-A5496 limit: 198 tons of VOC
per year). The source is not one of the 28 categories listed in 40 CFR, Part 52.21.
NESHAP / MACT: The webcoating lines (4), known as FG-WEBCOATING, at the stationary source are
subject to the Maximum Achievable Control Technology Standards for Paper and other Web Coating
NESHAP / MACT JJJJ promulgated in Title 40 of the Code of Federal Regulations (CFR), Part 63,
Subparts A and JJJJ (40 CFR, Part 63, Subpart JJJJ—National Emission Standards for Hazardous Air
Pollutants for Paper and Other Webcoating, Page 72330, Federal Register / Vol. 67, No. 233 /
Wednesday, December 4, 2002 / Rules and Regulations / Final Rule). In addition, EU-EMERG-GEN
(0.125 MM BTU per hour natural gas fired emergency generator, spark ignition (SI) reciprocating internal
combustion engine (RICE)) is subject to 40 CFR 63, Subpart ZZZZ-National Emission Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.
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."
CAM: The emission limitations or standards for Volatile Organic Compounds (VOC) from the four
webcoating lines (FG-WEBCOATING) at the stationary source are not exempt from the federal
Compliance Assurance Monitoring (CAM) regulation under Title 40 of the Code of Federal Regulations
(CFR), Part 64. However, presumptively acceptable monitoring conditions from Title 40 of the Federal
Regulations (CFR), Part 63, Subparts A and JJJJ are included in this ROP. This paragraph is revised
from April 21, 2014 draft staff report.
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.
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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-A5496-2014 are identified in Appendix 6 of the ROP.
PTI Number
491-99 dated January 5, 2001 (Consolidated permits (851-84B, 463-78 & 37-77C) into facility-wide
limits for VOC).
154-07 dated May 18, 2007 (Revised RTO language of PTI No. 491-99 and removed minimum 95
percent destruction efficiency requirement. PTI revision: PTI No. 491-99  PTI No. 154-07)
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
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
There were no processes listed in the ROP application as exempt devices under Rule 212(4). Exempt
devices are not subject to any process-specific emission limits or standards in any applicable
requirement.
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 Christopher Ethridge,
Southeast Michigan 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
A5496
July 16, 2014 STAFF REPORT ADDENDUM
MI-ROP-A5496-201X
Purpose
A Staff Report dated April 21, 2014, 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:
Mr. Robin Van Tilburg
Vice President, Operations
Phone: 248-363-8321, Ext. 349
Cell: 248-766-0727
E-mail: rvantilburg@pcicoatings.com
Mr. Iranna Konanahalli
Senior Environmental Engineer
586-753-3741 or konanahallii@michigan.gov
Summary of Pertinent Comments
Only US EPA comments were received during the 30-day public comment period. The comments are as
follows:
1. Staff Report, page 4. The stationary source emissions table only includes information pertaining to
Volatile Organic Compounds (VOC) and total Hazardous Air Pollutants (HAP). Please provide
additional information in the Staff Report regarding whether there are any other pollutants emitted,
taking into account activities at the source, including but not limited to the three Regenerative
Thermal Oxidizers (RTOs) and the four curing ovens.
2. Staff Report, page 5. The Staff Report states that the emission limitations for VOC from the four
webcoating lines are exempt from the Part 64 Compliance Assurance Monitoring (CAM)
requirements because "hazardous air pollutants which are part of VOC are addressed by Federal
Regulations (CFR), Part 63, Subparts A and JJJJ." For units subject to both exempt and nonexempt
emission limitations or standards, Part 64 still applies to the unit. On page 4 of the source's renewal
application, the applicant also states that the source is subject to CAM. Please add the CAM
permitting requirements specified in 40 CFR 64.6 through 64.9 to the permit as applicable, and revise
the Staff Report accordingly.
3. Staff report, page 6. The Staff Report lists EU-EMERG-GEN as an exempt emission unit that is not
subject to any applicable requirements. On pages 3-4 of the source's renewal application, the
applicant states that the source is subject to the Reciprocating Internal Combustion Engine (RICE)
Maximum Achievable Control Technology (MACT), 40 CFR Part 63, Subpart ZZZZ. The applicant
also proposes permit conditions pertaining to the RICE MACT. Please add the RICE MACT
requirements to the permit as applicable, and revise the Staff Report accordingly.
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4. FG-WEBCOATING, SC I. Please include specific citations to the associated monitoring/testing
methods in SC VI. for each emission limit, instead of a general reference to the entire section.
5. FG-WEBCOATING, SC I.2., SC I.3., and VI.4. Section VI.4. only includes a general statement
regarding emission calculations for determining compliance with the VOC potential to emit limit and
the HAP limit, and does not specify how emissions are to be calculated. Please include specific
emission calculation requirements sufficient to assure compliance with the VOC and HAP emission
limits, in accordance with the underlying applicable requirements (including 40 CFR 63.3360,
63.3370, R336.1205, 40 CFR 70.6(a)(3)(i)(B), and/or 70.6(c)(1), as applicable.
6. FG-WEBCOATING, SC I. The applicable emission standard in 40 CFR 63.3320 should be specified
in the emission limit table. Further, footnote £ does not clearly address which 40 CFR Part 63.3370
compliance demonstration methods the source is using; i.e., is it as-purchased compliance coating
materials, as-applied, multiple capture system and control devices, and/or combination of compliance
coatings and control devices? In order to clearly delineate the source's compliance demonstration
options and to ensure that all requirements are included in the permit, please include all applicable
40 CFR 63.3370 compliance demonstration methods directly in the permit, as well as all associated
monitoring, recordkeeping, and reporting requirements for each of the methods.
7. FG-WEBCOATING, SC 1.3. The underlying applicable requirements column cites a consent order. Is
there a consent order currently in effect for this source? Please provide additional information in the
Staff Report.
8. FG-WEBCOATING, SC III. and VI. These sections of the permit include some but not all of the
operating limits and associated control equipment requirements for 40 CFR Part 63, Subpart JJJJ.
For example, the permit includes some temperature monitoring requirements for the RTOs, but does
not include the minimum MACT combustion temperature (and averaging time), or the requirements
for establishing the minimum temperature. In addition, some of the requirements are paraphrased.
Please revise the permit to specifically address the requirements in 40 CFR 63.3321, Table 1,
63.3350, and 63.3360 as applicable.
9. FG-WEBCOATING, SC V. This section of the permit includes testing/sampling methods for
determining VOC content of the coatings, but it does not address HAP content requirements. Please
include conditions for determining HAP content as necessary to assure compliance with the HAP
emission limits, in accordance with 40 CFR 63.3360, 40 CFR 70.6(a)(3)(i)(B), and/or 70.6(c)(1), as
applicable.
10. FG-WEBCOATING, SC VII. Please address the MACT semiannual compliance report requirements,
as specified in 40 CFR 63.3400(c), in this section of the permit.
Changes to the April 21, 2014 Draft ROP
The changes were made to the April 21, 2014, draft ROP and Staff Report as follows:
Staff Report
Emissions information is updated as follows
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Tons per Year
1
0
2
0.1
0.01
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Pollutant
Tons per Year
Volatile Organic Compounds (VOCs)
6
Carbon Dioxide (CO2e)
2,000
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
1
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
The above emissions are based upon the data submitted by the company via e-mail
CAM language is changed as follows
CAM: The emission limitations or standards for Volatile Organic Compounds (VOC) from the four
webcoating lines (FG-WEBCOATING) at the stationary source are exempt from the federal Compliance
Assurance Monitoring (CAM) regulation under Title 40 of the Code of Federal Regulations (CFR), Part
64, because hazardous air pollutants which are part of VOC are addressed by Federal Regulations
(CFR), Part 63, Subparts A and JJJJ. Therefore, FG-WEBCOATING consisting of four coating lines is
exempt from CAM requirements for VOC. FG-WEBCOATING is exempt from CAM because it is subject
to federal regulations (NESHAP / MACT 4J) promulgated after November 15, 1990
CAM: The emission limitations or standards for Volatile Organic Compounds (VOC) from the four
webcoating lines (FG-WEBCOATING) at the stationary source are not exempt from the federal
Compliance Assurance Monitoring (CAM) regulation under Title 40 of the Code of Federal Regulations
(CFR), Part 64. However, presumptively acceptable monitoring conditions from Title 40 of the Federal
Regulations (CFR), Part 63, Subparts A and JJJJ are included in this ROP.
RICE MACT
“In addition, EU-EMERG-GEN (0.125 MM BTU per hour natural gas fired emergency generator, spark
ignition (SI) reciprocating internal combustion engine (RICE)) is subject to 40 CFR 63, Subpart ZZZZNational Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines” is added to the April 21, 2014, staff report.
Renewable Operation Permit (ROP)
Specific citation added by revising SC VI to SC VI.4.a, SC VI.4.a, SC VI.4.b corresponding to FGWEBCOATING, I.1; FG-WEBCOATING, I.2; FG-WEBCOATING, I.3.
The calculation procedures are described in Appendix 7.
FG-WEBCOATING, Footnote £ is revised to clarify compliance demonstration, minimum MACT
operating temperature, US EPA Method 204 Permanent Total Enclosure providing 100% capture of VOC
and HAP emissions, VOC & HAP emissions calculations, etc.
A reference to Consent Order AQD No. 22, 2008 is removed (FG-WEBCOATING, I) because G. Vinson
Hellwig, AQD Chief, terminated CO on November 29, 2012.
FG-WEBCOATING, III & VI are expanded to clarify minimum MACT operating temperatures, VOC &
HAP emissions calculations, applicable CAM requirements, etc.
New flexible group FG-WEBCOATING-MACT4J-RTO-CAM is added to include and clarify that MACT 4J
is presumptively acceptable CAM.
New flexible group FG-RICEMACT, corresponding to EU-EMERG-GEN (0.125 MM BTU per hour natural
gas fired emergency generator, spark ignition (SI) reciprocating internal combustion engine (RICE)) is
added.
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