State Registration Number
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
N7707 STAFF REPORT MI-ROP-N7707-2013a
Shelby Foam Systems
SRN: N7707
Located at
6200 26 Mile Road, Shelby Township, Macomb County, Michigan 48316
Permit Number: MI-ROP-N7707-2013a
Staff Report Date:
Amended Date:
April 8, 2013
February 25, 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 8, 2013 STAFF REPORT
June 3, 2013 STAFF REPORT ADDENDUM
August 20, 2013 STAFF REPORT ADDENDUM
February 25, 2014 STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION
April 15, 2014 STAFF REPORT ADDENDUM FOR RULE 216(2) MINOR MODIFICATION
10
12
13
3
8
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State Registration Number
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
N7707
April 8, 2013 STAFF REPORT
MI-ROP-N7707-2013
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:
Source Registration Number (SRN):
Shelby Foam Systems
6200 26 Mile Road
Shelby Township, Michigan 48316
N7707
North American Industry Classification System
(NAICS) Code:
326150
Number of Stationary Source Sections: 1
Is Application for a Renewal or Initial Issuance? Initial Issuance
Application Number: 201200063
Responsible Official:
AQD Contact:
Rene Chauvin, General Manager
586-816-1402
Remilando Pinga, Senior Environmental Engineer
586-753-3744
April 30, 2012 Date Permit Application Received:
Date Application Was Administratively Complete: June 6, 2012
Is Application Shield In Effect? Yes
Date Public Comment Begins:
Deadline for Public Comment:
April 8, 2013
May 8, 2013
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Source Description
Shelby Foam Systems is an automotive foam seat cushions manufacturing facility acquired from
Faurecia Automotive Seating, Inc., on December 21, 2009, and became a division of Magna Seating of
America, Inc. The facility is located in Shelby Township, Macomb County, Michigan. The property is located on the south side of 26 Mile Road east of Mound Road, west of Van Dyke Avenue and about a mile west of Van Dyke Freeway (M-53). There are residential neighborhoods less than a quarter of a mile northwest from Mound Road and 26 Mile Road, northeast, and southeast from the facility location.
The immediate property boundaries of the facility are industrial/commercial establishments.
The facility currently manufactures bench and bucket foam seat cushions for the production of automotive seats. The seat cushion is produced by injecting/mixing polyol, polymeric diphenylmethane diisocyanate (MDI), and some additives into a lid and bowl type molding press and allow for chemical reaction to occur for about 3 to 4 minutes to form the product. The facility operates 2 main production lines (emission units), EU-RTLine (bench line) and EU-CFLine (bucket line), which utilize mold release solvent and/or wax that contain volatile organic compounds (VOCs) and Hazardous Air Pollutants
(HAPs). The facility recently obtained Permit to Install (PTI) No. 303-06D as modification from the previous PTI No. 303-06B for the emission units/processes at the facility.
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)
Tons per Year
NA
Lead (Pb)
Nitrogen Oxides (NO x
)
Particulate Matter (PM)
Sulfur Dioxide (SO
2
)
Volatile Organic Compounds (VOCs)
Individual Hazardous Air Pollutants (HAPs) **
MDI
Total Hazardous Air Pollutants (HAPs)
NA
NA
NA
NA
108.2
0.001315
0.001315
**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.
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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 Macomb County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants, except for annual/24-hour PM
2.5
(fine particles).
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the potential to emit for Volatile Organic Compounds (VOC) criteria pollutant 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 (tpy) and/or the potential to emit of all HAPs combined are more than 25 tons per year. However, the facility took federally enforceable restrictions in its Permit to Install No. 303-
06D to limit any single HAP to less than 10 tpy and/or the combined HAPs to less than 25 tpy to enable the facility to become a synthetic minor for HAPs.
The potential to emit of Greenhouse Gases (GHG) is less than 100,000 tons per year calculated as carbon dioxide equivalents (CO2e) and on a mass basis thus making the facility a minor source for GHG emissions.
No emission units at the stationary source are currently subject to the Prevention of Significant
Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act
451, because at the time of New Source Review permitting the potential to emit of volatile organic compounds was less than 250 tons per year.
EU-RTLine, EU-CFLine, and EU-Anti-Squeak at the stationary source are subject to the Maximum
Achievable Control Technology Standards (MACT) for National Emissions Standards for Hazardous Air
Pollutants (NESHAPS) for Flexible Polyurethane Foam Production and Fabrication Area Sources as promulgated in 40 CFR Part 63 Subparts A and OOOOOO. The facility submitted the initial/compliance notification requirements per Subpart OOOOOO dated 8/11/2008. The company certified that even prior to July 16, 2007, methylene chloride was not used at the facility.
EU-Generator at the stationary source is subject to MACT for National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) as promulgated in 40 CFR Part 63 Subparts A and ZZZZ. EU-Generator is subject to the applicable requirement provisions in Subpart ZZZZ as an existing compression ignition (CI) emergency RICE > 500
HP engine located at an area source of HAP emissions.
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."
No emission units are subject to the federal Compliance Assurance Monitoring rule under 40 CFR, Part
64, because all emission units at the stationary source either do not have a control device or those with a control device do not have potential pre-control emissions over the major source thresholds.
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.
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
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-TANKS
EU-FrtOfficeAMU
EU-BreakRoomAMU
EU-QualtyLabAMU
EU-Weatherrite
EU-WarehouseAMU
Description of
Exempt Emission Unit
6 – 7,000 gal. above ground storage tanks for Polyol and Polymeric MDI
1 – natural gas fired heater (0.115
MMBTU/hr. rated heat input)
1 – natural gas fired heater (0.007
MMBTU/hr. rated heat input)
1 – natural gas fired heater (0.030
MMBTU/hr. rated heat input)
2 – natural gas fired heater (1.890
MMBTU/hr. rated heat input)
1 – natural gas fired heater (2.400
MMBTU/hr. rated heat input)
Rule 212(4)
Exemption
212(4)(c)
212(4)(b)
212(4)(b)
212(4)(b)
212(4)(b)
212(4)(b)
Rule 201
Exemption
284(i)
282(b)(i)
282(b)(i)
282(b)(i)
282(b)(i)
282(b)(i)
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.
Page: 6

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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State Registration Number
N7707
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
MI-ROP-N7707-2013
June 3, 2013 STAFF REPORT ADDENDUM
Purpose
A Staff Report dated April 8, 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:
Rene Chauvin, General Manager
586-816-1402
Remilando Pinga, Senior Environmental Engineer
586-753-3744
Summary of Pertinent Comments
The United States Environmental Protection Agency (USEPA), Region 5 Air Division sent comments via e-mail on 5/1/2013. AQD Southeast Michigan District office received the official copy through the mail on 5/3/2013. The letter was signed by Genevieve Damico, Chief of Air Permits Section, but the e-mail copy came from Constantine Blathras.
Here are the summary of comments and the AQD responses to the comments:

Comment 1 : The draft RO Permit for Shelby Foam Systems contain detailed permit applicable requirements on 40 CFR Part 63, Subpart ZZZZ but only has a high level citation as applicable requirement on 40 CFR Part 63, Subpart OOOOOO.
Response 1 : The detailed requirements in Subpart OOOOOO do not apply to Shelby Foam
Systems because the facility does not use Methylene Chloride as component in the cleaner material and the mold release agent. AQD staff has discussed in the above “Regulatory
Analys is” section of the ROP Staff Report that the facility submitted the initial/compliance notification requirements per Subpart OOOOOO dated 8/11/2008, certifying that, even prior to
July 16, 2007, methylene chloride was not used at the facility. A high level citation is appropriate since the facility has complied with the regulation by not using Methylene Chloride.

Comment 2 : USEPA referred to page 31 of the draft ROP for Shelby Foam Systems under the
“FG-Facility” flexible group pertaining to the individual and aggregate Hazardous Air Pollutants
(HAP) limits of 9.5 and 24.5 tons per year respective limits. USEPA commented:
”The associated monitoring and record keeping requirements do not specify the HAP emission calculation methodology used to assure compliance with the yearly HAP limits.
The permit conditions require records of HAP content in materials used and reclaimed, but does not provide the method for determining HAP content emitted from the
Page: 8

associated processes. The monitoring and recordkeeping necessary to assure compliance with the limits should also take into account all emissions at the facility, including those emissions from finished product off-gases being stored within the facility.
MDEQ should include adequate monitoring and recordkeeping in the permit which would provide the specific method for calculating the HAP emissions so the permit terms would be enforceable as a practical matter.”
Response 2 : AQD staff believes that the current monitoring and recordkeeping requirements in
FG-Facility as it relates to the individual and aggregate HAPs are sufficient and set up precisely to allow for flexibility in enforceability as a practical matter. a) On the concern that the monitoring and recordkeeping requirements did not account for all emissions at the facility, AQD staff has deleted FG-Facility from the draft ROP and transferred all the applicable requirements in FGFacility into the “SOURCE-WIDE
CONDITIONS” table to ensure that the individual HAP and aggregate HAPs limits are applicable to all emission sources. b) On the comment of not specifying the HAP emission calculation methodology, AQD staff elected to require a more flexible calculation methodology by requiring the company, under “VI. MONITORING/RECORDKEEPING, condition 1”, to complete all calculations in a format acceptable to AQD District Supervisor. Due to the source-wide applicability of this flexible group, the company may replace the compounds being used in the different processes as it strives to improve on efficiency and product quality. Also, the AQD or the company has the option to recommend an improved HAPs calculation methodology over time as technology, technical expertise, and/or measuring devices improve. c) On the comment that the permit does not provide the method for determining HAP content emitted from the associated processes, AQD staff elected to require this particular company to use manufacturer’s formulation data as the method to determine
HAP content, but included an option for the AQD District Supervisor to request for EPA
Method 311 testing to verify the formulation data (condition 1 of “V.
TESTING/SAMPLING”). These data can then be used as emission factor to calculate the actual emissions. The t able on “TOTAL STATIONARY SOURCE EMISSIONS” for
FY2012 reported actual emissions, showed that the facility emitted 0.0013 lb. of MDI (only
HAP emission at facility) which is very insignificant. This will eliminate burdening the company on incurring exorbitant testing costs for an insignificant HAP emission, but also having the applicable requirement for AQD to require the company to test for any reported future HAPs emissions on materials used in significant quantities for any processes at the facility.
Changes to the April 8, 2013 Draft ROP
The following changes were made to the draft ROP per the comments provided by USEPA region 5:
1. The entire FG-Facility flexible group was deleted and the applicable requirements were moved to “SOURCE-WIDE CONDITIONS” table.
2. The Underlying Applicable Requirement (UAR) = R 336.1201(3) in SOURCE-WIDE
CONDITIONS (I)(1 & 2) was replaced by R 336.1213(2).
3. The UAR = R 336.1201(3) in SOURCE-WIDE CONDITIONS (V & VII) was replaced by
R 336.1213(3).
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State Registration Number
N7707
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
MI-ROP-N7707-2013
August 20, 2013 STAFF REPORT ADDENDUM
Purpose
A Staff Report dated April 8, 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 45-day EPA comment period as described in R 336.1214(6). In addition, this addendum describes any changes to the proposed ROP resulting from these pertinent comments.
General Information
Responsible Official:
AQD Contact:
Rene Chauvin, General Manager
586-816-1402
Remilando Pinga, Senior Environmental Engineer
586-753-3744
Summary of Pertinent Comments
The United States Environmental Protection Agency (USEPA), Region 5 Air Division, Ms. Beth
Valenziano and Mr. Constantine Blathras, provided verbal comments to AQD Southeast Michigan
District Supervisor, Christopher Ethridge, June 6, 2013, on the proposed ROP during the 45-day EPA review time period. Ms. Valenziano sent additional comments via e-mail on July 17, 2013 in response to a revised draft of the proposed ROP e-mailed to Ms. Valenziano and Mr. Blathras by Mr. Ethridge dated
July 2, 2013. Another revised draft of the proposed ROP was e-mailed to Ms. Valenziano on July 26,
2013 by Mr. Ethridge followed by a response e-mail from Ms. Valenziano on August 7, 2013. A teleconference occurred on August 14, 2013 attended by Ms. Valenziano and Mr. Blathras, USEPA, and
AQD staff Mr. Ethridge, Ms. Foy, and Mr. Pinga, to discuss and resolve remaining issues pertaining to the most recent draft of the proposed ROP at that time.
Here are the summary of comments and the AQD responses to the comments:

Comment 1 : USEPA discussed with Mr. Ethridge via teleconference on June 6, 2013 about mass balance calculations taking into account all emitted emissions applicable requirement for
HAPs and revisiting the MACT applicable requirements (AR) on 40 CFR Part 63, Subpart
OOOOOO.
Response 1 : AQD staff included in the revised draft (June 1, 2013) of the proposed ROP detailed applicable requirements pertaining to 40 CFR Part 63, Subpart OOOOOO and detailed formula for calculating the MDI/PMDI HAP emissions in Appendix 7.

Comment 2 : USEPA Beth Valenziano sent e-mail (July 17, 2013) to AQD Chris Ethridge commenting the MACT (40 CFR 63, Subpart OOOOOO) applicable requirements looked good but contained some redundant conditions. She also mentioned that Mr. Blathras is still looking at the Appendix 7 formula.
Page: 10

Response 2 : AQD staff revised the draft proposed ROP (July 26, 2013) deleting the permit condition below and e-mailed to Ms. Valenziano:
“For an existing or new molded/fabrication flexible polyurethane foam affected source, Permittee shall achieve compliance with the applicable provisions of 40 CFR Part 63 Subpart OOOOOO by
July 16, 2007 or upon startup of the affected source. §63.11415((b), (c), & (d))”

Comment 3 : USEPA Region 5 staff, Ms. Valenziano and Mr. Blathras, and AQD staff,
Mr. Ethridge, Ms. Foy, and Mr. Pinga, conducted teleconference on August 14, 2013 to discuss and resolve remaining issues pertaining to the July 26, 2013 draft of the proposed ROP. USEPA
Ms. Valenziano suggested mass balance taking into account all HAP emissions in lieu of the
Appendix 7 calculations. She commented that AQD staff was missing temperature and pressure monitoring and recordkeeping requirements at the Source-Wide Conditions applicable requirement table if AQD staff insisted on keeping the Appendix 7 calculations.

Response 3 : AQD staff agreed to use the mass balance applicable requirement as per
Ms. Valenziano’s alternate suggestion and removed the Appendix 7 calculations. As for the redundant SOURCE-WIDE CONDITIONS (IX)(7), AQD staff decided to keep the applicable requirement since the company’s responsible official has already agreed to the AR.
Changes to the June 3, 2013 Proposed ROP
The following changes were made to the proposed ROP per the comments provided by USEPA Region
5:
1. Added applicable requirement SOURCE-WIDE CONDITIONS (VI)(1) pertaining to calculating and keeping records all of individual and aggregate HAPs using mass balance or an alternate method as approved by the AQD District Supervisor. The UAR is R 336.1213(3).
2. Added specific Underlying Applicable Requirements (UARs) as SOURCE-WIDE CONDITIONS
(IX)(3, 4,..8) pertaining to 40 CFR Part 63, Subpart OOOOOO MACT standards.
3. The UAR SOURCE-WIDE CONDITION (IX)(3) was moved to SOURCE-WIDE CONDITION
(IX)(9).
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State Registration Number
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
N7707
February 25, 2014 STAFF REPORT FOR RULE
216(2) MINOR MODIFICATION
MI-ROP-N7707-2013a
Purpose
On August 23, 2013, the Department of Environmental Quality, Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-N7707-2013 to Shelby Foam Systems pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(2).
General Information
Responsible Official:
AQD Contact:
Application Number:
Date Application For Minor Modification
Was Submitted:
Rene Chauvin, General Manager
Kirsten S. Clemens, P.E., Environmental Engineer
269-567-3548
201400021
February 4, 2014
Regulatory Analysis
The AQD has determined that the change requested by the stationary source meets the qualifications for a Minor Modification pursuant to R 336.1216(2).
Description of Changes to the ROP
The emergency generator (749 brake horsepower diesel fired Catepillar compressor ignition emergency generator (559 KW)) was removed from the facility as of December 23, 2013. The emergency generator
(749 brake horsepower diesel fired Catepillar compressor ignition emergency generator (559 KW)) was removed from the facility as of December 23, 2013.
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the emission unit(s) involved with the change as of the date of approval of the Minor Modification to the ROP.
Action Taken by the DEQ
The AQD proposes to approve a Minor Modification to ROP No. MI-ROP-N7707-2013a, as requested by the stationary source. A final decision on the Minor Modification to the ROP will not be made until any affected states and the U.S. Environmental Protection Agency (USEPA) has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District
Supervisor. The final determination for approval of the Minor Modification 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 requirements, and resolution of any objections by any affected states or the
USEPA.
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State Registration Number
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT ROP Number
N7707
April 15, 2014 STAFF REPORT ADDENDUM FOR
RULE 216(2) MINOR MODIFICATION
MI-ROP-N7707-2013a
Purpose
A Staff Report dated February 25, 2014, was developed in order to set forth the applicable requirements and factual basis for the proposed Minor Modification to the Renewable Operating Permit’s (ROP) terms and conditions as required by R 336.1216(2)(c). The purpose of this Staff Report Addendum is to summarize any significant comments received on the proposed ROP modification during the U.S.
Environmental Protection Agency’s (USEPA) 45-day comment period as described in R 336.1216(2)(c).
In addition, this addendum describes any changes to the proposed ROP Minor Modification resulting from these pertinent comments.
General Information
Responsible Official:
AQD Contact:
Rene Chauvin, General Manager
Kirsten S. Clemens, P.E., Environmental Engineer
269-567-3548
Summary of Pertinent Comments
No pertinent comments were received during the USEPA’s 45-day comment period.
Changes to the February 25, 2014 Proposed ROP Minor Modification
No changes were made to the proposed ROP Minor Modification.
Page: 13