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									                                  STATE OF MICHIGAN
                              Jennifer M. Granholm, Governor



MICHIGAN DEPARTMENT OF NATURAL RESOURCES AND ENVIRONMENT
                              Rebecca A. Humphries, Director




                           AIR QUALITY DIVISION
            CONSTITUTION HALL, 525 W ALLEGAN STREET, PO BOX 30260, LANSING MI 48909
                                 INTERNET: http://www.michigan.gov




PUBLIC PARTICIPATION DOCUMENTS
                         For
                GENERAL MOTORS
              ORION ASSEMBLY PLANT
                 4555 Giddings Road
                   Orion, Michigan




         PERMIT APPLICATION NUMBER

                                       224-09

                          January 20, 2010
General Motors – Orion Assembly Plant                                                      Page 1
Permit No. 224-09                                                                 January 20, 2010

                                         FACT SHEET
                                         January 20, 2010

Purpose and Summary

The Michigan Department of Natural Resources and Environment (MDNRE), Air Quality
Division (AQD), is proposing to act on Permit to Install (PTI) application No. 224-09 from
General Motors – Orion Assembly Plant. The Orion facility is located at 4555 Giddings Road,
Orion, Michigan. The permit application is for the proposed installation and operation of a new
automobile paint shop and modifications to existing assembly operations. The new paint shop
will replace an existing one at the facility that General Motors recently took out of service.
General Motors has requested that the permit be issued in a flexible permitting format. The
proposed project is subject to permitting requirements of the Department’s Rules for Air
Pollution Control. Prior to acting on this application, the AQD is holding a 30-day public
comment period and a public hearing, if requested in writing, to allow all interested parties the
opportunity to comment on the proposed PTI. All relevant information received during the
comment period and hearing, if requested in writing, will be considered by the decision maker
prior to taking final action on the application.

Background Information

The proposed new paint shop and modified assembly operations will include pre-treatment
operations; an electrodepostion dip tank and oven; a sealer deck and oven; a sound deadener
application process; a three wet paint process; a glass installation process; a fluid fill process;
and a final repair process. The pre-treatment operations are a series of washers which are
used to remove oils and grease from the unpainted vehicles followed by a series of tanks in
which micro-crystals are attached to the vehicle body. The micro-crystals are used to enhance
the adhesion of paint and to inhibit corrosion. In the electrodepostion tank, an initial prime
coating is applied to the vehicle bodies. Sealers and fillers are used to seal joints in the sheet
metal and to protect the vehicle interior compartment from water, dirt, and noise. Sound
deadener is used to reduce road noise. The three wet paint process consists of a basecoat 1
booth, a heated flash, a basecoat 2 booth, a heated flash, a clearcoat spraybooth, and a curing
oven. Basecoat 1 serves as a second primer on the vehicle body. Basecoat 2 is the color
coating applied to each vehicle. Clearcoat is the gloss coating sprayed over the color coat to
give the vehicle its shine. Both the windshield and the rear window are installed within the glass
installation process. During the fluid fill process all necessary fluids including power steering
fluid, antifreeze, transmission fluid, engine oil, windshield washer fluid, refrigerant, and fuel are
added to the vehicle. Spot repair to damaged vehicle bodies is done in the final repair process.

Orion is located in Oakland County, which is currently in compliance with all National Ambient
Air Quality Standards (NAAQS) for each criteria pollutant, except for particulate matter less than
2.5 microns in size (PM2.5).

Michigan’s flexible permitting initiative grew out of the “Joint EPA/State Agreement to Pursue
Regulatory Innovation” (Agreement) signed in 1998 by the U.S. Environmental Protection
Agency (EPA) and the Environmental Council of States. The purpose of this Agreement was to
encourage states to experiment with innovative regulatory approaches to environmental
management. It required that all innovations provide equal or better environmental performance
than currently being achieved. The Agreement did not change any existing laws but
General Motors – Orion Assembly Plant                                                    Page 2
Permit No. 224-09                                                               January 20, 2010

encouraged state environmental agencies and EPA to work together to identify regulatory
flexibility within the current environmental statutes.

In the spirit of this Agreement, the AQD set about to evaluate current permitting practices and
environmental statutes to identify potential ways to satisfy industry’s need for increased
operational flexibility while simultaneously ensuring environmental protection.           Existing
environmental regulations and the permitting reviews they require have been criticized as being
overly restrictive. For example, the number and type of limitations on production equipment and
work practices have been characterized as unnecessarily intrusive and an obstacle to
manufacturing flexibility. One key criticism has been that, in order to make small process
modifications, facilities have been forced to give up previously permitted, but unused, production
capacity in order to avoid having to re-permit existing production capacity.

The solutions that AQD developed are incorporated into its flexible permit format. The key to
AQD’s approach is that the environmental performance of a facility that complies with the whole
spectrum of process-specific requirements represents the net effect of those requirements.
Therefore, AQD decided to base flexible permits on the net effect of all the process-specific
requirements rather than by retaining each individual requirement. The logical measures of
environmental performance is a pounds of pollutant emitted per job limit together with a facility-
wide yearly mass limit. For existing facilities, both should be established based upon the past
actual performance (within a 10 year baseline) of the facility. For new facilities, such as Orion,
both are established by the applicable best available control technology (BACT) analysis.

Under this approach to permitting, a facility is permitted to operate a specific function, such as
automotive assembly and painting operations. Modifications to the existing process equipment
are within the scope of the flexible permit as long as the facility continues to comply with the
environmental performance standards (both the facility wide mass tons per year volatile organic
compound [VOC] limit and the pounds of VOCs per vehicle produced limit) and continues the
same specific function (i.e., remains an automotive assembly and painting facility).

The AQD has determined that modifications involving the installation of new emission units can
be divided into two categories, those that require an increase in the flexible permit emission
limits and those that do not. Activities that require an increase in the permitted emission limits
must first go through a pre-construction permit review process, either major new source review
(NSR) or Michigan’s minor source permitting. The installation of new emission units that do not
require increasing the flexible permit emission limits are allowed if:

A.   The new emission unit will not result in a meaningful change in the nature or quantity of
     toxic air contaminants emitted from the stationary source;

B.   The new emission unit will not be a newly constructed or reconstructed major source of
     hazardous air pollutants as defined in and subject to 40 C.F.R. §63.2 and §63.5(b)(3),
     National Emission Standard for Hazardous Air Pollutants; and,

C.   The installation of the new emission unit will not cause the violation of any other applicable
     requirement.

A demonstration that any new installation meets these criteria is required to be kept on site for
the life of the new emission unit and made available to the MDNRE upon request. Furthermore,
a notification of the installation of the new emission unit must be made to the MDNRE prior to
beginning the installation. The notification must follow the procedures specified in Michigan Air
General Motors – Orion Assembly Plant                                                      Page 3
Permit No. 224-09                                                                 January 20, 2010

Pollution Control Rule R 336.1215(3)(c)(i) through (v).           Once the notification is sent,
construction of the new emission unit may commence.

The notification procedure allows the facility to proceed with the modification after identifying
and determining compliance with all applicable requirements. This notification procedure is
similar to procedures allowed under Michigan Air Pollution Control Rules R336.1215 and
R336.2823(15). The notification procedure also provides the AQD the opportunity to review the
applicable requirements determination made by the facility. In this system the facility accepts all
risks associated with construction or installation for which additional requirements are later
determined to apply.

Key Permit Review Issues

•   Flexible Permit Initiative – The flexible permit allows certain changes at the Orion facility to
    be made without first requiring a permit review. This is accomplished by creating a flexible
    group for the automotive assembly and painting operations and by defining the regulatory
    terms, “physical change” and “method of operation.” A physical change is defined as a
    change that causes the flexible group to become something other than automobile painting
    and assembly operations. The method of operation is defined as meeting the performance-
    based pounds per job (lbs/job) and tons per year (tpy) emission limits. Consequently, any
    changes that do not cause the facility to become something other than an automobile
    painting and assembly operation or that do not cause an increase in the lbs/job or tpy
    emission limits, are not physical changes or changes in the method of operation, and
    therefore, are not modifications. As such, limited changes are expressly allowed by the
    flexible permit because they do not trigger state or federal NSR permitting requirements.

•   Minor Modification Determination Attainment Pollutants – The current Orion facility is an
    existing prevention of significant deterioration (PSD) major stationary source. Any
    modification at the facility where the emissions of any regulated pollutant will increase by
    more than the significance level for that pollutant results in the change being subject to PSD
    for that pollutant. Orion is located in Oakland County which is currently in attainment for all
    regulated pollutants, except for particulate matter less than 2.5 microns in size (PM2.5). By
    keeping the requested increases of each regulated pollutant to less than their respective
    significance levels above past actuals, the proposed new Orion facility was able to avoid
    being subject to PSD. See Appendix A: Proposed Emissions Changes, for a listing of the
    proposed changes of each regulated pollutant.

•   Minor Modification Determination Non-Attainment Pollutants – The Orion facility is
    located in Oakland County which is currently in nonattainment for PM2.5. The current Orion
    facility is an existing PSD major stationary source. An increase in PM2.5 emissions above
    the significance level will result in the change being subject to major nonattainment NSR for
    PM2.5. The significance level for PM2.5 is 10.0 tons per year. The proposed emission
    increase of particulate matter less than 10 microns in size (PM10) from the Orion facility is
    6.84 tons per year. Even assuming that all of the PM10 emissions are PM2.5 results in a
    PM2.5 increase from the facility of less than significance. As such, the proposed PM2.5
    increase is not subject to major NSR.

•   Rule 702 BACT Analysis – The proposed 748.5 tons per year of VOC emissions from the
    new automobile paint shop and modified assembly operations are subject to BACT under
    Michigan Air Pollution Control Rule R 336.1702. As a part of the BACT analysis GM
General Motors – Orion Assembly Plant                                                    Page 4
Permit No. 224-09                                                               January 20, 2010

    provided a comparison of their proposed pounds of VOCs per job values with those of all
    other flexible permits previously issued by MDNRE. GM’s proposed value of 4.6 pounds of
    VOCs per job is lower than the previous lowest value of 4.8 pounds of VOCs per job. GM
    also evaluated the economic viability of placing add-on VOC controls on waterborne
    basecoat booths to destroy a portion of the VOCs which will be emitted. The applicant’s
    evaluation demonstrated that add-on VOC control on these booths was not cost effective.
    AQD concurred with this determination. AQD also concurred with GM’s determination that
    4.6 pounds of VOCs per job represents BACT for the proposed Orion facility.

•   Criteria Pollutants Modeling Analysis – The projected PM and nitrogen oxides (NOx)
    emissions from the proposed facility were evaluated against both the national ambient air
    quality standards (NAAQS) and the PSD increments. The NAAQS are intended to protect
    public health. The standards define the maximum concentration of air emissions in the
    breathing zone that would protect the health of most sensitive individuals, including those
    with heart, respiratory, neurological, and asthma problems. The PSD increments are
    intended to allow industrial growth in an area, while ensuring that the area will continue to
    meet the NAAQS. For PM10 both the NAAQS and the PSD increments are evaluated on a
    short term (24-hour) basis and a long term (annual) basis. For NOx both the NAAQS and
    the PSD increments are evaluated on a long term (annual) basis only. There is no short
    term (24-hour) NAAQS or PSD increments for NOx. The evaluation is done using computer
    modeling. The modeling done for Orion demonstrated that the maximum long term PM10
    impact was insignificant for both the NAAQS and PSD increments. The modeling also
    demonstrated compliance with both the short term NAAQS and PSD increments for PM10
    and both the long term NAAQS and PSD increments for NOx. See Appendix B: Criteria
    Pollutant Impact Summary for modeling results.

•   Rule 225 Toxics Analysis - The Department’s Rules for Air Pollution Control require that
    the airborne concentration of toxic air contaminants (TACs) be compared against health-
    based screening levels. AQD staff reviewed GM’s air quality modeling and evaluation of
    toxic air contaminant impacts. AQD’s review found that all toxic air contaminants show
    impacts less than their established health-based screening levels. See Appendix C: Toxics
    Analysis for a listing of each individual toxic air contaminant and its predicted ambient
    impact.

•   Federal Regulations – The proposed new paint shop is subject to the New Source
    Performance Standard (NSPS) for Automobile and Light Duty Truck Manufacturers,
    40 CFR 60 Subpart MM. The requirements of the NSPS are inherent in the 4.6 lbs/job and
    748.5 tpy emission limits. The permit specifies that compliance with these limits will
    constitute compliance with the NSPS. A demonstration that the facility meets the NSPS
    requirements is included as Appendix D to this Fact Sheet.

Key Aspects of Draft Permit Conditions

•   VOC Emission Limits – The proposed permit for the Orion facility has been written in a
    flexible permit format. This format establishes a single VOC emission limit for all automotive
    assembly and painting operations in the form of 4.6 pounds per job and 748.5 tons per year.
    Grouping emissions together on a unit of production (i.e., per job) basis allows compliance
    to be more easily determined by both the facility and the AQD. The proposed flexible permit
    pre-approves certain changes at the facility (i.e. those that do not require increasing either
    the pound per job or the ton per year emission limits).
General Motors – Orion Assembly Plant                                                     Page 5
Permit No. 224-09                                                                January 20, 2010


•   Control Requirements – The draft permit requires that the permittee not operate the
    electrodeposition tank and oven, the sealer oven, the basecoat 1 heated flash-off area, the
    basecoat 2 heated flash-off area, the clearcoat spray booth, and the three wet curing oven
    unless the regenerative thermal oxidizer is installed and operating properly.

•   Natural Gas Usage Limits – The draft permit limits the total natural gas combustion from
    the painting and assembly portions of the facility to a maximum of 800 million cubic feet per
    year.

•   Testing – The draft permit requires testing to verify the overall transfer efficiency of one
    representative basecoat 1 booth, one representative basecoat 2 booth, one representative
    clearcoat booth; capture efficiency across the three wet painting process and across the
    sealer curing oven; and destruction efficiency of the regenerative thermal oxidizer. The draft
    permit also requires testing to verify PM10 emission rates from the basecoat 1 and basecoat
    2 spray booths and a single representative final repair spray booth.

•   Federal Regulations – The Orion facility is subject to the “National Emission Standards for
    Hazardous Air Pollutants: Surface Coating of Automobiles and Light-Duty Trucks” (Auto
    MACT), and the “National Emission Standards for Hazardous Air Pollutants: Organic Liquids
    Distribution (non-gasoline)” (OLD MACT). These requirements are included in the permit.

Conclusion

Based on the analyses conducted to date, staff concludes that the proposed project would
comply with all applicable federal air quality requirements and with all AQD regulations. Staff
also concludes that this project, as proposed, would not violate the federal National Ambient Air
Quality Standards and the federal PSD increments.

Based on these conclusions, staff has developed draft permit terms and conditions which would
ensure that the proposed facility design and operation are enforceable and that sufficient
monitoring, recordkeeping, and reporting would be performed by the applicant to determine
compliance with these terms and conditions. If the permit application is deemed approvable,
the delegated decision maker may determine a need for additional or revised conditions to
address issues raised during the public participation process.

If you would like additional information about this proposal, please contact Mr. Mark C. Mitchell,
AQD, at 517-373-7077.
General Motors – Orion Assembly Plant                                                                  Page 6
Permit No. 224-09                                                                             January 20, 2010

                                        STATE AIR REGULATIONS
   State Rule                                Description of State Air Regulations
                 Requires an Air Use Permit for new or modified equipment that emits, or could emit, an air
                 pollutant or contaminant. However, there are other rules that allow smaller emission sources
  R 336.1201
                 to be installed without a permit (see R 336.1279 through R 336.1290 below). R 336.1201 also
                 states that the Department can add conditions to a permit to assure the air laws are met.
                 Outlines the permit conditions that are required by the federal Prevention of Significant
                 Deterioration (PSD) Regulations and/or Section 112 of the Clean Air Act. Also, the same
  R 336.1205     types of conditions are added to their permit when a plant is limiting their air emissions to
                 legally avoid these federal requirements. (See the Federal Regulations table for more details
                 on PSD.)
                 New or modified equipment that emits toxic air contaminants must use the Best Available
                 Control Technology for Toxics (T-BACT). The T-BACT review determines what control
                 technology must be applied to the equipment. A T-BACT review considers energy needs,
  R 336.1224
                 environmental and economic impacts, and other costs. T-BACT may include a change in the
                 raw materials used, the design of the process, or add-on air pollution control equipment. This
                 rule also includes a list of instances where other regulations apply and T-BACT is not required.
                 The concentration of each toxic air contaminant present in the outdoor air must be less than
                 specified levels. These levels, called the initial risk screening level (IRSL) for cancer causing
 R 336.1225 to   air contaminants and the initial threshold screening level (ITSL) for non-cancer causing air
  R 336.1232     contaminants, are health-based standards. Air Quality Division toxicologists develop these
                 standards following the methods in the rules. The standards are designed to protect all
                 humans, including the most sensitive populations such as the young, elderly, and ill.
                 These rules list equipment to processes that have very low emissions and do not need to get
 R 336.1279 to
                 an Air Use permit. However, these sources must meet all requirements identified in the
  R 336.1290
                 specific rule and other rules that apply.
                 Limits how air emissions are allowed to look at the end of a stack. The color and intensity of
  R 336.1301
                 the color of the emissions is called opacity.
                 The particulate emission limits for certain sources are listed. These limits apply to both new
  R 336.1331
                 and existing equipment.
                 Material collected by air pollution control equipment, such as dust, must be disposed of in a
  R 336.1370
                 manner, which does not cause more air emissions.
R 336.1401 and
               Limit the sulfur dioxide emissions from power plants and other fuel burning equipment.
  R 336.1402
                 Volatile organic compounds (VOCs) are a group of chemicals found in such things as paint
                 solvents, degreasing materials, and gasoline. VOCs contribute to the formation of smog. The
 R 336.1601 to
                 rules set VOC limits or work practice standards for existing equipment. The limits are based
  R 336.1651
                 upon Reasonably Available Control Technology (RACT). RACT is required for all equipment
                 listed in R 336.1601 through R 336.1651.
                 New equipment that emits VOCs is required to install the Best Available Control Technology
                 (BACT). The technology is reviewed on a case-by-case basis. The VOC limits and/or work
  R 336.1702     practice standards set for a particular piece of new equipment cannot be less restrictive than
                 the Reasonably Available Control Technology limits for existing equipment outlined in
                 R 336.1601 through R 336.1651.
                 Nitrogen oxide emission limits for larger boilers and stationary internal combustion engines are
  R 336.1801
                 listed.
                 Prohibits the emission of an air contaminant in quantities that cause injurious effects to human
                 health and welfare, or prevent the comfortable enjoyment of life and property. As an example,
  R 336.1901
                 a violation may be cited if excessive amounts of odor emissions were found to be preventing
                 residents from enjoying outdoor activities.
  R 336.1910     Air pollution control equipment must be installed, maintained, and operated properly.
General Motors – Orion Assembly Plant                                                                        Page 7
Permit No. 224-09                                                                                   January 20, 2010
                                             STATE AIR REGULATIONS
   State Rule                                     Description of State Air Regulations
                     When requested by the Department, a facility must develop and submit a malfunction
   R 336.1911        abatement plan (MAP). This plan is to prevent, detect, and correct malfunctions and
                     equipment failures.
                     A facility is required to notify the Department if a condition arises which causes emissions that
   R 336.1912
                     exceed the allowable emission rate in a rule and/or permit.
 R 336.2001 to       Allow the Department to request that a facility test its emissions and to approve the protocol
  R 336.2060         used for these tests.
                     The PSD rules allow the installation and operation of large, new sources and the modification
 R 336.2801 to
                     of existing large sources in areas that are meeting the National Ambient Air Quality Standards
  R 336.2804
                     (NAAQS). The regulations define what is considered a large or significant source, or
 Prevention of
                     modification.
  Significant
                     In order to assure that the area will continue to meet the NAAQS, the permit applicant must
 Deterioration
                     demonstrate that it is installing the BACT. By law, BACT must consider the economic,
    (PSD)
                     environmental, and energy impacts of each installation on a case-by-case basis. As a result,
  Regulations
                     BACT can be different for similar facilities.
                     In its permit application, the applicant identifies all air pollution control options available, the
 Best Available
                     feasibility of these options, the effectiveness of each option, and why the option proposed
    Control
                     represents BACT. As part of its evaluation, the Air Quality Division verifies the applicant’s
  Technology
                     determination and reviews BACT determinations made for similar facilities in Michigan and
    (BACT)
                     throughout the nation.
               Applies to new “major stationary sources” and “major modifications” as defined in R 336.2901.
               These rules contain the permitting requirements for sources located in nonattainment areas
               that have the potential to emit large amounts of air pollutants. To help the area meet the
               NAAQS, the applicant must install equipment that achieves the Lowest Achievable Emission
 R 336.2901 to Rate (LAER). LAER is the lowest emission rate required by a federal rule, state rule, or by a
R 336.2903 and previously issued construction permit. The applicant must also provide emission offsets,
  R 336.2908   which means the applicant must remove more pollutants from the air than the proposed
               equipment will emit. This can be done by reducing emissions at other existing facilities.
               As part of its evaluation, the AQD verifies that no other similar equipment throughout the
               nation is required to meet a lower emission rate and verifies that proposed emission offsets
               are permanent and enforceable.

                                           FEDERAL AIR REGULATIONS
          Citation                           Description of Federal Air Regulations or Requirements
                           The United States Environmental Protection Agency has set maximum permissible
                           levels for seven pollutants. These NAAQS are designed to protect the public health
                           of everyone, including the most susceptible individuals, children, the elderly, and
 Section 109 of the Clean those with chronic respiratory ailments. The seven pollutants, called the criteria
Air Act – National Ambient pollutants, are carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter
  Air Quality Standards    less than or equal to 10 microns (PM10), particulate matter less than or equal to 2.5
         (NAAQS)           microns (PM2.5), and sulfur dioxide. Portions of Michigan are currently non-
                           attainment for either ozone or PM2.5. Further, in Michigan, State Rules 336.1225
                           to 336.1232 are used to ensure the public health is protected from other
                           compounds.
                             The PSD regulations allow the installation and operation of large, new sources and
40 CFR 52.21 – Prevention the modification of existing large sources in areas that are meeting the NAAQS.
of Significant Deterioration The regulations define what is considered a large or significant source, or
     (PSD) Regulations       modification.
                             In order to assure that the area will continue to meet the NAAQS, the permit
   Best Available Control    applicant must demonstrate that it is installing BACT. By law, BACT must consider
        Technology           the economic, environmental, and energy impacts of each installation on a case-by-
           (BACT)            case basis. As a result, BACT can be different for similar facilities.
                             In its permit application, the applicant identifies all air pollution control options
General Motors – Orion Assembly Plant                                                                      Page 8
Permit No. 224-09                                                                                 January 20, 2010
                                          FEDERAL AIR REGULATIONS
          Citation                         Description of Federal Air Regulations or Requirements
                               available, the feasibility of these options, the effectiveness of each option, and why
                               the option proposed represents BACT. As part of its evaluation, the Air Quality
                               Division verifies the applicant’s determination and reviews BACT determinations
                               made for similar facilities in Michigan and throughout the nation.
                               The United States Environmental Protection Agency has set national standards for
 40 CFR 60 – New Source        specific sources of pollutants. These New Source Performance Standards (NSPS)
 Performance Standards         apply to new or modified equipment in a particular industrial category. These
         (NSPS)                NSPS set emission limits or work practice standards for over 60 categories of
                               sources.
                               In the Clean Air Act, Congress listed 189 compounds as Hazardous Air Pollutants
 Section 112 of the Clean
                               (HAPS). For facilities which emit, or could emit, HAPS above a certain level, one of
         Air Act
                               the following two requirements must be met:
                                 1) The United States Environmental Protection Agency has established
   Maximum Achievable
                                     standards for specific types of sources. These Maximum Achievable Control
   Control Technology
                                     Technology (MACT) standards are based upon the best-demonstrated control
        (MACT)
                                     technology or practices found in similar sources.
                                 2) For sources where a MACT standard has not been established, the level of
       Section 112g
                                     control technology required is determined on a case-by-case basis.

Notes:
An “Air Use Permit,” sometimes called a “Permit to Install,” provides permission to emit air contaminants up to
certain specified levels. These levels are set by state and federal law, and are set to protect health and welfare.
By staying within the levels set by the permit, a facility is operating lawfully, and public health and air quality are
protected.

The Air Quality Division does not have the authority to regulate noise, local zoning, property values, off-
site truck traffic, or lighting.

These tables list the most frequently applied state and federal regulations. Not all regulations listed may be
applicable in each case. Please refer to the draft permit conditions provided to determine which regulations apply.
General Motors – Orion Assembly Plant                                                      Page 9
Permit No. 224-09                                                                 January 20, 2010

                                         Appendix A
                                Proposed Emissions Changes
                             General Motors Orion Assembly Plant
                         Existing  Existing              Difference
             Existing                       Proposed
                         Facility  Facility               Between
              Facility                      Emissions                  Significance
                          Actual  Two Year              Existing and                  Significant
Pollutant   Actual 2007                       New                          Value
                           2008    Average               Proposed                      Increase
            Emissions                        Facility                     (Tons)
                        Emissions Emissions               Facility
              (Tons)                         (Tons)
                          (Tons)    (Tons)                 (Tons)

  VOCs        565.52     1050.2     807.86     748.5      - 59.36          40.0           No


   CO          15.4       19.6          17.5   33.6         16.1           100            No


  NOx          8.47      11.27          9.87   40.0        30.13           40             No


  SO2          0.11       0.14      0.125      0.24        0.115           40             No


  PM10         9.98       16.9      13.44      20.28        6.84           15             No


 PM-2.5        9.98       16.9      13.44      20.28        6.84           10             No
General Motors – Orion Assembly Plant                                                                          Page 10
Permit No. 224-09                                                                                      January 20, 2010

                                                 Appendix B
                                    Criteria Pollutant Impact Summary
                                   General Motors Orion Assembly Plant




    PSD Impact Summary

                       Facility’s                                    Combined                     Increment
                                      Insignificant    80% PSD                       100% PSD                       Under
         Averaging    Increment                                      Increment                    Consumed
                                       Increment       Increment                     Increment                    Allowable
           Time      Consumption                                    Consumption                   by Facility
                                         (µg/m3)         (µg/m3)                       (µg/m3)                   Increments
                        (µg/m3)                                        (µg/m3)                       (%)


PM10     24-hour            4.8               5              24           17.3            30        16.0              YES


                                                                                                                      YES
 NOx      Annual            2.2               1              20           5.6             25           8.8



         NAAQS Impact Summary

                                                                                  Combined
                   Total                          Combined     Background
                                  Averaging                                          and       NAAQS          Meets
                  Emission                         Impact     Concentrations
                                    Time                                         Background    (µg/m3)       NAAQS
                 Rate (lb/hr)                      (µg/m3)       (µg/m3)
                                                                                   (µg/m3)


       PM10          6.91         24-hour          17.3            33              50.3          150          YES


                                                                                                              YES
        NOx          9.11         Annual            5.6            26.7            32.3          100
  General Motors – Orion Assembly Plant                                                                  Page 11
  Permit No. 224-09                                                                              January 20, 2010
                                                 Appendix C
                                       Toxic Air Contaminant Analysis
                                     General Motors Orion Assembly Plant


                                            Maximum       Screening     Screening
                                            Emission        Level         Level     Maximum         % of      Meets
                                               Rate     Concentration   Averaging    Impact      Screening   Rule 225
                                                                  3                          3
Toxic Air Contaminant             CAS #      (lbs/hr)      (ug/m )        Time       (ug/m )       Level      Limit
Formaldehyde                      50-00-0      0.20          0.08        annual         0.01      12.82%       Yes
Propylene Glycol                  57-55-6      45.13        6000         annual         3.55       0.06%       Yes
Ethyl alcohol                     64-17-5       8.68        19000          8 hr        66.99       0.35%       Yes
Methanol                          67-56-1      10.86        3250           1 hr        82.22       2.53%       Yes
Isopropyl Alcohol                 67-63-0      61.39         220          24 hr       130.65      59.39%       Yes
Acetone                           67-64-1     34.27         5900           8 hr         7.54       0.13%       Yes
Propyl Alcohol                    71-23-8      46.89         730         annual         3.83       0.52%       Yes
n-Butyl Alcohol                   71-36-3     361.16         350          24 hr       284.23      81.21%       Yes
Amyl Alcohol                      71-41-0      21.65         120         annual         2.10       1.75%       Yes
Benzene                           71-43-2      0.09           30          24 hr         4.46      14.86%       Yes
Benzene                           71-43-2      0.09        1 SRSL        annual        0.35       35.36%       Yes
Isobutyl Alcohol                  78-83-1      45.30        1500           8 hr        87.06       5.80%       Yes
Methyl Ethyl Ketone               78-93-3       1.31        5000          24 hr         0.63       0.01%       Yes
Naphthalene                       91-20-3      1.45            3          24 hr         1.20      39.87%       Yes
Naphthalene                       91-20-3      1.45       0.8 SRSL       annual         0.14      17.04%       Yes
1,2,4-Trimethyl Benzene           95-63-6      51.54         220          24 hr        39.31      17.87%       Yes
Cumene                            98-82-8       0.06         400          24 hr         0.04       0.01%       Yes
Cumene                            98-82-8      0.06      0.006 SRSL      annual       0.004       72.61%       Yes
Ethylbenzene                     100-41-4      19.22        1000          24 hr        21.87       2.19%       Yes
Ethylbenzene                     100-41-4      19.22           3         annual         1.99      66.28%       Yes
Benzyl Alcohol                   100-51-6      56.84        5000          24 hr        39.48       0.79%       Yes
Phenylene ester                  101-68-8      0.01           0.6         24 hr         0.03       4.95%       Yes
diethylene glycol phenol ether   104-68-7       0.08           7         annual         0.04       0.55%       Yes
2-Ethylhexanol                   104-76-7      19.35          70         annual         1.52       2.18%       Yes
n-Propyl Propionate              106-36-5      45.27          84         annual         3.39       4.04%       Yes
Ethylene Glycol                  107-21-1      0.003        1000           1 hr         0.12       0.01%       Yes
Propylene Glycol Monomethyl
Ether                            107-98-2    314.17        2000           24 hr      167.23        8.36%       Yes
Dimethylaminoethanol             108-01-0     13.54          16           24 hr        9.38       58.61%       Yes
Methyl Isobutyl Ketone           108-10-1     27.65        3000           24 hr       14.31        0.48%       Yes
Isopropyl Acetate                108-21-4    13.13         4200            8 hr       13.51        0.32%       Yes
1-Methoxy-2Propyl Acetate        108-65-6     25.38        3000           24 hr       36.98        1.23%       Yes
2,6-Dimethylheptanone            108-83-8     1.63         1500            8 hr        6.94        0.46%       Yes
Toluene                          108-88-3     13.92         5000          24 hr       35.46        0.71%       Yes
Methyl (N-Amyl) Ketone           110-43-0     1.20         2330            8 hr        1.58        0.07%       Yes
Cyclohexane                      110-82-7     0.03         6000           24 hr        1.49        0.02%       Yes
2-Butoxy Ethanol                 111-76-2     40.85        13000          24 hr       29.92        0.23%       Yes
2-Butoxylethyl Acetate           112-07-2     78.78        17600          24 hr       56.96        0.32%       Yes
Ethylene Glycol Monohexyl
Ether                            112-25-4     14.18          8           annual       1.12        13.96%       Yes
Diethylene Glycol Monobutyl
Ether                            112-34-5     18.05          20           24 hr       12.50       62.52%       Yes
Diacetone Alcohol                123-42-2     1.37          2375           8 hr        5.84        0.25%       Yes
N-Butyl Acetate                  123-86-4    167.00         7100           8 hr      417.63        5.88%       Yes
Diethylene Glycol Butyl Ether
Acetate                          124-17-4     1.58           25           24 hr       3.87        15.48%       Yes
  General Motors – Orion Assembly Plant                                                                  Page 12
  Permit No. 224-09                                                                              January 20, 2010
                                             Maximum      Screening      Screening
                                             Emission        Level         Level     Maximum        % of      Meets
                                                Rate     Concentration   Averaging    Impact     Screening   Rule 225
                                                                  3                          3
Toxic Air Contaminant             CAS #       (lbs/hr)      (ug/m )        Time       (ug/m )      Level      Limit
2-Methylbutyl Alcohol            137-32-6       4.56           13         annual        0.47       3.60%       Yes
2-Aminoethanol                  141-43-5        6.07           80           8 hr       11.73      14.67%       Yes
Ethyl Acetate                   141-78-6        0.64         3200          24 hr        1.58       0.05%       Yes
N-Heptane                        142-82-5       5.50         3500           8 hr       12.38       0.35%       Yes
Pentyl Propionate                624-54-4      14.32           21         annual        1.50       7.16%       Yes
Ethyl 3-Ethoxypropanoate        763-69-9       24.45          134          24 hr       27.58      20.58%       Yes
N-Methyl-2-Pyrrolidone          872-50-4       12.28          700          24 hr       10.90       1.56%       Yes
Xylene                          1330-20-7      75.29          100          24 hr       82.76      82.76%       Yes
Propylene Glycol Monopropyl
Ether                          1569-01-3        1.40           86          24 hr       7.15        8.31%       Yes
Propylele lycol Methyl Ether   1589-47-5        1.40          660          24 hr       0.67        0.10%       Yes
1-Butoxy-2-Propanol            5131-66-8      110.67          77          annual       8.35       10.84%       Yes
Cycloalkene                    5989-27-5       0.39          6250          24 hr       1.58        0.03%       Yes
Gasoline                       8006-61-9       2.61        20 SRSL        annual      10.61       53.04%       Yes
V.M. & P. Naphtha              8032-32-4       2.54          3500           8 hr       9.07        0.26%       Yes
Stoddard Solvent               8052-41-3       39.52         3500           8 hr      282.22       8.06%       Yes
1-Propanol-2-Butoxy            15821-83-7       5.16           77         annual       0.41        0.53%       Yes
Trimethyl Benzene              25551-13-7       5.48          220          24 hr       4.37        1.99%       Yes
Dipropylene Glycol
Monomethyl Ether               34590-94-8      56.10          720          24 hr       45.93       6.38%       Yes
Petroleum Distillates          64741-65-7      49.13         3500          8 hr        99.57       2.84%       Yes
Petroleum Distillates          64741-66-8      4.52           138         annual        0.41       0.30%       Yes
Petroleum Distillates          64741-68-0      27.41           70         annual        2.29       3.27%       Yes
Petroleum Distillates          64742-48-9      12.26         3500          8 hr        22.79       0.65%       Yes
Solvent naphtha                64742-52-5       2.63           50           8 hr       36.90      73.81%       Yes
Naphtha                        64742-82-1       5.48           14         annual        0.46       3.27%       Yes
Naphtha                        64742-88-7       6.79         3500           8 hr       14.19       0.41%       Yes
Aromatic Hydrocarbon           64742-94-5      10.90           70          24 hr       12.77      18.24%       Yes
Aromatic Naphtha               64742-95-6      87.20           61         annual        6.42      10.52%       Yes
2-Methoxy-1-Propyl Acetate     70657-70-4       0.60          500          24 hr        0.39       0.08%       Yes
Oxo-Hexyl Acetate              88230-35-7       6.53           81         annual        1.03       1.28%       Yes
Dibasic Ester                  95481-62-2       3.87          0.6         annual        0.30      50.78%       Yes
Dipropylene glycol dimethyl
ether                          111109-77-4     0.80           59           24 hr       3.25        5.51%       Yes
General Motors – Orion Assembly Plant                                                               Page 13
Permit No. 224-09                                                                           January 20, 2010
                                           Appendix D
                      40 CFR 60 Subpart MM New Source Performance Standard
                                    Compliance Demonstration
                               General Motors Orion Assembly Plant


 The following table demonstrates how the proposed facility will comply with the NSPS emission limits.


                                                                 Liquid                Topcoat
                                                Ecoat          Basecoat 1       Basecoat 2  Clearcoat
                                           COATING DATA

Maximum Aver. VOC Content (lb/gal)               0.74              1.20            1.40           4.10

Minimum Aver. Solids Content (vol%)              91.0              24.0            20.0           45.0

Calculated VOC Content (lb/gal solids)           0.78              5.00            7.00           9.11

Topcoat Usage Split (Fraction)1                   ---               ---            65.0           35.0

                                           NSPS LIMITS

NSPS Limit (lb/GACS)                             1.42              11.68                  12.3

                             TRANSFER EFFICIENCY WITHOUT CONTROLS

% Transfer Efficiency (TE) Required2            54.93              42.80                  62.91

Current NSPS Transfer Efficiency (%)             100               75.0                   82.0
1
    These values represent the topcoat usage split between Basecoat and Clearcoat normalized to one
    gallon.
2
    These values represent the minimum TE needed in order to meet the NSPS limit without the use of
    add-on controls. The VOC Content (lb/gal solids) is divided by the NSPS limit of 12.3 lb/GACS to
    determine the minimum TE value required to meet the NSPS standard.

								
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