Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6027 / STAFF REPORT / MI-ROP-B6027-2012a
Inteva Products, LLC – Adrian Operations
SRN: B6027
Located at
1450 Beecher Street, Adrian, Michigan 49221
Permit Number: MI-ROP-B6027-2012a
Staff Report Date: May 21, 2012
Amended Date: May 7, 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).
TABLE OF CONTENTS
MAY 21, 2012 STAFF REPORT 3
JUNE 22, 2012 STAFF REPORT ADDENDUM 9
MAY 7, 2015 STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION 10
JUNE 23, 2015 STAFF REPORT ADDENDUM FOR RULE216(2) MINOR MODIFICATION 12
Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6027 /
MAY 21, 2012 STAFF REPORT
/ MI-ROP-B6027-2012Purpose
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: / Inteva Products, LLC – Adrian Operations1450 Beecher Street
Adrian, Michigan 49221
Source Registration Number (SRN): / B6027
North American Industry Classification System (NAICS) Code: / 336360
Number of Stationary Source Sections: / 1
Is Application for a Renewal or Initial Issuance? / Renewal
Application Number: / 201100116
Responsible Official: / Clive Smith, Plant Manager
517 265-4211
AQD Contact: / Sersena M. White, Senior Environmental Engineer
517 780-7844
Date Permit Application Received: / October 11, 2011
Date Application Was Administratively Complete: / October 24, 2011
Is Application Shield In Effect? / Yes
Date Public Comment Begins: / May 21, 2012
Deadline for Public Comment: / June 20, 2012
Source Description
Inteva Products, LLC - Adrian Operations facility is located at 1450 East Beecher Road within the Adrian city limits and Madison Township, Lenawee County, Michigan. In 1977, production began with four injection-molding machines and the plant remained under the ownership of General Motors from 1974 to the end of 1998, at which time ownership was transferred to Delphi Corporation. The facility was transferred to Inteva in March 2008.
The property is fenced along all borders, which are bounded by Treat Highway to the west, Beecher Street to the north, a correctional facility to the east, and a mix of woods and grassy fields to the south.
There is some isolated housing located WNW of the plant with the land adjoining to the south being vacant. The facility has railroad access on the south side via a rail spur that joins into the main railroad tracks to the west.
Inteva Products, LLC – Adrian Operations primarily produces Instrument Panels for General Motors pickup trucks (approximately 95% of output). The main production operations at the facility are plastic injection molding and instrument panel assembly. The facility operates two automated paint lines (CK3 and Paint line #5) that include full aqueous parts washer lines, robotic paint booths and dryer ovens. A third paint booth (CK2) is used more for small scale painting or maintenance painting. Plastic pellets are delivered via rail car and tractor trailer and transferred to the facility’s storage tanks via two trestle piping runs into the plant. The pellets are sent through a drying process before utilization in the facility’s injection molding machines. There are several emission units that are exempt from the requirement to obtain an air use permit, they will be identified in the table Processes in Application Not Identified in the Draft ROP. The following emission units were removed on March 1, 2012: EU_EastBth_012, EU_EastBth_014 and EU_EastBth_015 and they were formerly under the flexible group FG-RULE287(c) and FG-MACTPPPP.
The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System (MAERS) in the 2011 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant / Tons per Year /Carbon Monoxide (CO) / 2.14
Lead (Pb) / 0
Nitrogen Oxides (NOx) / 6.41
Particulate Matter (PM) / 0.19
Sulfur Dioxide (SO2) / 0.032
Volatile Organic Compounds (VOCs) / 38.60
Individual Hazardous Air Pollutants (HAPs) ** From 2011 Usage
Toluene / 1.58
Xylene / 0.62
Triethylamine / 0.34
Formaldehyde / 0.000045
Isocyanates / 0.033
Cumene / 0.053
MIBK / 0.73
Total Hazardous Air Pollutants (HAPs) / 3.36
**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 non-applicability 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 Lenawee 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 Title 40 of the Code of Federal Regulations (CFR), Part 70, because
the potential to emit for volatile organic compounds exceeds 100 tons per year, and 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/or the potential to emit of all HAPs combined is more than 25 tons per year.
Although emission units identified in the table Processes in Application Not Identified in the Draft ROP, according to Rule 212(4), were installed after August 15, 1967, this equipment was exempt from New Source Review (NSR) permitting requirements at the time it was installed. However, future modifications of this equipment may be subject to NSR.
ExemptEmission Unit ID / Description of
Exempt Emission Unit / Rule 212(4)
Exemption / Rule 201
Exemption /
EU-PLASTBLENDSYS / Plastic/fiberglass material handling and blending process consist of material unloading from the railcars, two silos, silo to blender material transfer, and the material blending system controlled by a fabric filter that exhaust inside the plant. / Rule 212(3) / Rule 286(b)
EU-Laser-South / Laser scoring of plastic instrument panel / Rule 212(3)(f) / Rule 285(l)(vi)(B)
EU-Laser-North / Laser scoring of plastic instrument panel / Rule 212(3)(f) / Rule 285(l)(vi)(B)
EU-Laser-East / Laser scoring of plastic instrument panel projected installation January 2012 / Rule 212(3)(f) / Rule 285(l)(iv)(B)
EU-Laser-West / Laser scoring of plastic instrument panel projected installation January 2012 / Rule 212(3)(f) / Rule 285(l)(iv)(B)
EU-Laser Drill / Laser hole drilling of plastic instrument panel projected installation January 2012 / Rule 212(3)(f) / Rule 285(l)(iv)(B)
EU-Flame-East / Flame treatment of plastic instrument panel projected installation January 2012 / Rule 212(3)(f) / Rule 285(l)(iv)(B)
EU-Flame-West / Flame treatment of plastic instrument panel projected installation January 2012 / Rule 212(3)(f) / Rule 285(l)(iv)(B)
EU-R&D / Research and Development into new formulations, new part configurations or material / Rule 212(3)(d) / Rule 283
EU-HndHldAerosol / Miscellaneous maintenance painting / Rule 212(3)(f
and h) / Rule 285(hh)
Rule 287(b)
EU-PlasWeld / Plastic Welding operations / Rule 212(3)(f) / Rule 285(i)
EU-RIM / Reaction Injection Molding – foam in place / Rule 212(3)(g) / Rule 286(e)
EU-InjMold / Injection molding and associated equipment – injection, compression, and transfer molding equipment and associated plastic resin handling, storage, and drying equipment / Rule 212(3)(g) / Rule 286(b)
FG-MACTPPPP at the stationary source is subject to the Maximum Achievable Control Technology Standards for coating of plastic parts and products promulgated in 40 CFR, Part 63, Subparts A and PPPP.
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-CKIP#3 Booths 1 and 2 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 desorption gas inlet temperature in the concentrator and monitoring of the temperature in the combustion chamber of the thermal oxidizer in order to ensure efficient capture and destruction of the emissions. The facility also has a malfunction abatement plan for the control equipment identified as Management of Abatement Equipment CK#3, Environmental Management Procedure EMS ADR P31 which is not included in the ROP.
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 wereincorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-B6027-2007 are identified in Appendix 6 of the ROP.
PTI Number /177-04A / 5-77 / 23-84 / 243-77
221-80C / 179-89B / 560-97 / 159-85
198-80 / 794-80A / 643-94 / 914-78
794-80 / 135-07B / 135-07C
Streamlined/Subsumed Requirements
AQD proposes to keep the following
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.
ExemptEmission Unit ID / Description of
Exempt Emission Unit / Rule 212(4)
Exemption / Rule 201
Exemption /
EU-EMPIREBLAST / Tool Room Empire Blast Booth with dust collection system. Non-production / Rule 212(4)(d) / Rule 285(l)(vi)(A)
EU-MISC-HEATERS / Miscellaneous Direct Fired Gas Space Heaters < 10 MMBTU/hr / Rule 212(4) / Rule 285(b)(i)
EU-GASTNK / 1,000 Gallon Gasoline Tank for Fleet Vehicles / Rule 212(4) / Rule 284(g)(i)
EU-BOILER#35-1 / Cleaver Brooks natural gas fired boiler A-35-1, 14.645 mmBTU/hr / Rule 212(4) / Rule 282(b)(i)
EU-BOILER#15-2 / Cleaver Brooks natural gas fired boiler A-15-2, 6.2775 mmBTU/hr / Rule 212(4) / Rule 282(b)(i)
EU-PACBOILER#1 / Superior natural gas fired boiler #1, 14.6 mmBTU/hr / Rule 212(4) / Rule 282(b)(i)
EU-PACBOILER#2 / Superior natural gas fired boiler #2, 14.6 mmBTU/hr / Rule 212(4) / Rule 285(b)(i)
EU-PACBOILER#3 / Superior natural gas fired boiler #3, 14.6 mmBTU/hr / Rule 212(4) / Rule 285(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.
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 Scott Miller, Jackson 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.
Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B2806 /
JUNE 22, 2012 STAFF REPORT ADDENDUM
/ MI-ROP-B6027-2012Purpose
A Staff Report dated May 21, 2012, 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 R336.1214(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: / Clive Smith, Plant Manager517 265-4211
AQD Contact: / Sersena M. White, Senior Environmental Engineer
517 780-7844
Summary of Pertinent Comments