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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.