PUBLIC PARTICIPATION DOCUMENTS For Lacks Enterprises, Inc. Cascade Township, Michigan

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1 STATE OF MICHIGAN Rick Snyder, Governor DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION CONSTITUTION HALL 525 WEST ALLEGAN STREET P.O. BOX LANSING, MICHIGAN PUBLIC PARTICIPATION DOCUMENTS For Lacks Enterprises, Inc. Cascade Township, Michigan PERMIT APPLICATION NUMBER May 1, 2012

2 Lacks Enterprises, Inc. Page 1 Purpose and Summary FACT SHEET MAY 1, 2012 The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), is proposing to act on Permit to Install (PTI) application No from Lacks Enterprises, Inc. The permit application is for a proposed installation and operation of a new facility that will consist of a decorative chrome plating line for plating plastic automotive parts and five natural gas fired boilers. The proposed project is subject to permitting requirements of the Department s Rules for Air Pollution Control and a review under the requirements of Section 112(g) of the Federal Clean Air Act (CAA). Prior to acting on this application, the AQD is holding a 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 held, will be considered by the decision maker prior to taking final action on the application. Background Information This location will be a new facility. Lacks Enterprises, Inc. currently operates several coating and plating operations of automotive parts in Michigan and is looking to expand their business. Proposed Facility and Present Air Quality Lacks Enterprises, Inc. has proposed to construct a new decorative chrome electroplating facility that is approximately 0.8 miles south of 52 nd Street on Kraft Avenue in Cascade Township. The facility will be located in Kent County which is currently designated as attainment for all criteria pollutants. The electroplating line will consist of 35 process tanks (not including reclaim tanks, rinse tanks and a wastewater treatment system) that will deposit copper, nickel and chromium on plastic automotive parts. In addition to the electroplating line, five small (1.8 million Btu per hour each) natural gas fired boilers will be installed at the facility. The proposed facility will be a minor source of emissions for all criteria pollutants. However, the facility will be a Title V major source due to the emissions of hazardous air pollutants (HAPs) above the major source thresholds for individual and combined HAPs. Pollutant Emissions The potential to emit for the proposed project is less than 250 tons per year (tpy) of any single regulated air pollutant and less than 100,000 tpy of greenhouse gases (GHGs). Therefore, the source is not subject to the PSD Regulations in Part 18 of the Michigan Air Pollution Control Rules or 40 CFR The following table provides the estimated emissions for each pollutant: Table 1: EMISSION SUMMARY Pollutant Estimated Emissions (tpy) Particulate Matter (PM) 0.3 PM10* 0.3 PM2.5** 0.3

3 Lacks Enterprises, Inc. Page 2 Pollutant Estimated Emissions (tpy) Sulfur Dioxide (SO 2 ) 0.02 Carbon Monoxide (CO) 3.3 Nitrogen Oxides (NO x ) 3.9 Volatile Organic Compounds (VOCs) 51.9 GHGs 4,696 Individual HAPs: methanol 39.4 formaldehyde 5.2 Total Chromium 0.02 Nickel 1.97 Hydrogen Chloride HAPs - Combined 46.6 * Particulate matter less than 10 microns in diameter ** Particulate matter less than 2.5 microns in diameter Key Permit Review Issues Staff evaluated the proposed project to identify all state rules and federal regulations which are, or may be, applicable. The tables in Appendix 1 summarize these rules and regulations. Federal NESHAP Regulations - National Emission Standards for Hazardous Air Pollutants (NESHAP) were established under 40 CFR Part 61 or Part 63. The proposed decorative chrome electroplating tanks are subject to the NESHAP for Chromium Emissions from Hard and Decorative Chrome Electroplating and Chromium Anodizing, 40 CFR Part 63 Subpart N. This NESHAP applies to any decorative chrome electroplating tank, regardless of whether the facility is an area source or major source of Hazardous Air Pollutants (HAPs). The proposed boilers are subject to the NESHAP for Industrial, Commercial and Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD. This NESHAP applies to any new boiler located at a major source of HAPs. Rule 224 T-BACT Analysis Each of the process tanks listed in the permit emits at least one type of toxic air contaminant. Of these tanks, all but the decorative chrome electroplating tank, conditioner tank and the electroless copper plating tank are subject to Rule 224 T-BACT requirements. T-BACT is an analysis of the Best Available Control Technology for the toxic air contaminants emitted from a process or group of processes. Based on the analysis conducted, the use of a packed bed scrubber system for the two acid strip tanks meets the requirements for T-BACT. The three chrome etch tanks will each have fume suppressant applied to the tanks and the tanks will share a composite mesh pad scrubber system for controlling the total chromium emissions; this meets T-BACT requirements. The emissions from the neutralizer tank, accelerator tank, catalyst tank, copper strike tank, six acid copper tanks, five semi-brite nickel plating tanks, two brite nickel plating tanks, six platinum/nickel plating tanks and the durni nickel plating tank were evaluated. Based on the minimal amount of emissions and compliance with Rule 225 without control, it was determined that the installation of air pollution control for each of these processes would not be economically feasible. This is consistent with previous determinations for similar sources.

4 Lacks Enterprises, Inc. Page 3 Rule 225 Toxics Impact Analysis The MDEQ Rules for Air Pollution Control require the ambient air concentration of toxic air contaminants (TACs) be compared against health-based screening levels. AQD staff reviewed Lacks Enterprises, Inc. s air quality modeling and evaluation of TAC impacts. The review found that all TACs show impacts less than the established health-based screening levels and will comply with the requirements of Rule 225. See Table 2 below for a listing of each individual TAC and the predicted ambient impact. CAS No. Table 2: Toxic Air Contaminant Impacts Potential Pollutant ITSL or Toxic Air Emission Impact IRSL/SRSL Contaminant Rate (lb/hr) (µg/m 3 ) (µg/m 3 ) Averaging Time % of ITSL/ IRSL/SRSL Chromium (total) Annual 61% Chromium (total) hr 68% ,3-dichloro-2-propanol 1.49 (DCP) Annual 33% DCP hr 74% Nickel Annual 98% Methanol hr 2% Formaldehyde Annual 13% Formaldehyde hr 28% Copper hr 2% Hydrogen Chloride Annual 1% Hydrogen Chloride hr 1% Sulfuric Acid Annual 4% Sulfuric Acid hr 2% Sodium Hydroxide hr 71% Nitric Acid hr 96% Rule 702 VOC Emissions This rule requires an evaluation of the following four items to determine what will result in the lowest maximum allowable emission rate of VOCs: a. Best Available Control Technology (BACT) or a limit listed by the department on its own initiative b. New Source Performance Standards (NSPS) c. VOC emission rate specified in another permit d. VOC emission rate specified in the Part 6 rules for existing sources An evaluation of these four items determined that the first item, emission limits for each VOC emitted from the process would dictate the lowest maximum allowable emission rate of VOC from the electroless copper plating tank. This determination is based on the fact that there is not an

5 Lacks Enterprises, Inc. Page 4 NSPS or Part 6 Rule for this source category and emission rates specified in other permits for similar sources were deemed incompatible due to the differences in the size of the tanks, concentrations and operating time. Test results for similar sources, a cost analysis of different types of control options and modeling results were all part of the basis for determining the emission limits for the two VOCs emitted from the electroless copper process. In addition to a Rule 702 BACT review, a review under the federal requirements of 112(g), case-by-case MACT determination was also conducted (see below) because the two VOC pollutants emitted from the electroless copper tank are also considered to be HAPs. Based on the analysis conducted, the use of a packed bed scrubber system for the conditioner tank and an emission limit of 1.5 lb/hr for DCP will meet the requirements for Rule 702(a) BACT. The VOC emissions from the five boilers are negligible at 0.22 tons per year, combined. The use of natural gas as fuel and good combustion practices meets the requirements of Rule 702 and no additional control or emission limitation is necessary for the boilers. 112(g) MACT - A case-by-case Maximum Achievable Control Technology (MACT) determination was completed for formaldehyde and methanol from the electroless copper plating tank. Introduction and Procedure Lacks Enterprises, Inc. is proposing to construct a new major source of HAPs. Section 112(g) of the Federal CAA requires that any constructed or reconstructed major source of HAPs be equipped with MACT to control HAP emissions if a source specific MACT standard for the source category has not been promulgated under Section 112(d) or Section 112(h). The process of determining what is maximum achievable control technology for a source is called a case-by-case MACT determination, and the implementation regulations are adopted by reference in Rule (2)(b). Operational Memorandum No. 15, Procedure for Processing Permit Applications Subject to Federal CAA Section 112(g) establishes guidelines for processing a permit application for a caseby-case MACT determination. First, a MACT emission limitation is defined as: MACT emission limitation for new sources means the emission limitation which is not less stringent than the emission limitation achieved in practice by the best controlled similar source, and which reflects the maximum degree of reduction in emissions that the permitting authority, taking into consideration the cost of achieving such emission reduction, and any non-air quality health and environmental impacts and energy requirements, determines is achievable by the constructed or reconstructed major source. This is the guiding principle in a case-by-case MACT determination. The development of approvable MACT emission limitations for Lacks Enterprises, Inc. is as follows: Pollutant Applicability MACT applies to the proposed source emitting HAPs that are greater than 10 tpy for an individual HAP or 25 TPY for the combined HAPs, and considering all HAP emissions at the source. For this project, the electroless copper plating tank emits two HAPs, formaldehyde and methanol at a combined rate of 44.2 tpy. Both of these HAPs are also volatile organic compounds.

6 Lacks Enterprises, Inc. Page 5 Emission Unit Applicability The emission unit subject to the case-by-case review for Lacks Enterprises, Inc. is the electroless copper plating tank. Potentially Sensitive Concerns Potentially sensitive concerns involving economic, public health and environmental issues were all identified as necessary when the two HAPs were evaluated. Any potentially sensitive concerns that affect the MACT emission limitation will be discussed below as appropriate. Initial Selection of MACT Control Technologies Identify alternative control strategies including transferable and innovative control technologies, process changes or alternative processes that inherently produce less pollution, and various configurations of the same technology which achieve different control efficiencies. Various sources of information were investigated to ensure that all possible control strategies were identified including but not limited to: relevant proposed regulations, EPA RBLC, literature, industrial surveys, etc. Selection of MACT Final Control Strategy MACT cannot be less stringent than the emission control which is achieved in practice by the best controlled similar source and must also be the most efficient alternative which is not demonstrated to be infeasible. Similar sources were reviewed for formaldehyde and methanol emissions in this case-by-case MACT determination. The definition of similar source is: Similar source means a stationary source or process that has comparable emissions and is structurally similar in design and capacity to a constructed or reconstructed major source such that the source could be controlled using the same control technology. Establishment of MACT Emission Limits The MACT emission limits should be established with a reasonable margin of safety (e.g., 95% confidence level of available test data); and should be based on an appropriate averaging time. Additional requirements such as stack testing, continuous emission monitoring, recordkeeping, and reporting requirements that serve to make the emission limitation enforceable as a practical matter should also be established. The MACT emission limitation and requirements are recommended by the applicant and approved by the permitting authority which is the AQD. Alternative Requirements Specific design, equipment, work practice or operational standards may be proposed in lieu of control technology and a MACT emission limitation may not be established if it is infeasible to establish and enforce an emission limitation. No alternative requirements were used in lieu of an enforceable MACT emission limitation in the case-by-case MACT determination for Lacks Enterprises, Inc. Case-by-Case MACT Determination for the Electroless Copper Plating Tank The following is a summary of the MACT determination, and the MACT emission limits that apply to the electroless copper plating tank. Methanol and Formaldehyde To determine if the emission limits proposed are not less stringent than the emission limitations achieved in practice by the best controlled similar source, a comparison to other electroless copper plating facilities was made. Three facilities were found outside of Michigan, (Kentucky, Missouri

7 Lacks Enterprises, Inc. Page 6 and Tennessee) and another facility was found in Michigan that all have permits for an electroless copper plating process. Additionally, Lacks Enterprises, Inc. currently operates three facilities with electroless copper plating tanks; their Barden Plater, Airlane North Plating Facility and the Airlane South Plating facility, all located in Grand Rapids, Michigan. Of these facilities that have permits, it appears that only Lacks Enterprises, Inc. has ever tested for both methanol and formaldehyde. Lapeer Plating and Plastics, located in Lapeer, Michigan currently operates an electroless copper plating tank that is vented to a packed bed scrubber system that is shared with other process tanks. Lapeer Plating and Plastics has tested their electroless copper plating process for formaldehyde and are currently limited to 1.02 milligrams per cubic meter. This emission limit appears to have been required to minimize odors as the underlying applicable requirement is R of the Michigan Air Pollution Control Rules. Seigel-Robert Automotive, located in Ripley, Tennessee, operates a decorative chrome electroplating line that contains an electroless copper plating tank which has a VOC limit of one (1) pound per hour. The tank is controlled by a formaldehyde scrubber and compliance is demonstrated by maintaining water flow through the scrubber at a rate of 20 gallons per minute. No testing has been completed for VOC, formaldehyde or methanol. McKechnie Vehicle Components, located in Nicholasville, Kentucky, operates two chromium electroplating lines both of which have an electroless copper plating tank as part of the line. Each line uses fume suppressant and has a scrubber system associated with the chrome electroplating tanks, but the electroless copper tanks are uncontrolled, and there are no limits in the Renewable Operating Permit (ROP). Seigel-Robert Automotive, located in Portageville, Missouri, operates a decorative chrome electroplating line that contains an electroless copper plating tank. The tank is controlled by a wet scrubber system. The Renewable Operating Permit (ROP) for the facility has emission limits of 9.0 tpy for both formaldehyde and methanol to comply with the facility wide HAPs opt-out emission limit. The formaldehyde and methanol emission limits are based on a 30% control efficiency but it is unclear how the efficiency was determined. The Missouri Department of Natural Resources indicated that the company has tested one time, but results could not be found for the electroless copper tank. Based on the review of these similar sources, review of the test data from Lacks Enterprises, Inc. s other existing facilities, a toxics review and the cost analysis performed by the applicant, it was determined that a packed bed scrubber system equivalent to what is used at their existing facilities and emission limits of 9.0 lb/hr for methanol and 1.1 lb/hr for formaldehyde meet the MACT requirements for a 112(g) review. It is unclear whether the scrubber system will meet any type of control efficiency as a packed bed scrubber system does not typically work well for controlling VOCs, especially when the air flow is high and the concentration is low, as is the case for the electroless copper process. However, the scrubber system has been demonstrated to minimize odor issues related to the electroless copper plating process. Key Aspects of Draft Permit Conditions Emission Control Requirements The draft permit includes the following: The draft permit requires the conditioner tank be operated with a packed bed scrubber system with mist eliminators to limit DCP emissions.

8 Lacks Enterprises, Inc. Page 7 The draft permit requires the three chromic acid etch tanks be operated with fume suppressant applied to each tank and a shared composite mesh pad scrubber system to limit total chromium emissions. The draft permit requires the electroless copper tank be operated with a packed bed scrubber system with mist eliminators to limit formaldehyde and methanol emissions. The draft permit requires the three decorative chrome electroplating tanks be operated with fume suppressant applied to each tank and a shared composite mesh pad scrubber system to limit total chromium emissions. The draft permit requires the chromic acid and nitric acid strip tanks be operated with a shared packed bed scrubber system with mist eliminators to limit nitric acid and sodium hydroxide emissions. Federal Regulations The proposed three decorative chrome electroplating tanks are subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chromium Emissions from Hard and Decorative Chrome Electroplating and Chromium Anodizing, 40 CFR Part 63 Subpart N. The permit specifies that compliance with the emission limit will constitute compliance with the NESHAP. The applicant has proposed to apply fume suppressant to the tanks and install a composite mesh pad scrubber system to control the chromium emissions from the three tanks. The applicant will be required to monitor the surface tension of each of the tanks and monitor the pressure drop of the scrubber system to demonstrate compliance. In addition, the applicant will be required to do a performance test to verify emissions are less than the total chrome emission limits specified in the permit. The five boilers are subject to the NESHAP for Industrial, Commercial and Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD. This NESHAP applies to any new boiler located at a major source of HAPs. The boilers are limited to a maximum size of five (5) MMBtu/hr, can only burn natural gas and the applicant will be required to perform a tune up every five years, as required by Subpart DDDDD. MACT Limits The draft permit includes MACT emission limits for formaldehyde and methanol for the electroless copper plating tank. The limits are based on a MACT control strategy utilizing a packed bed scrubber system. Proper operation of the control equipment and periodic emission testing will serve to make the emission limits enforceable as a practical matter. Testing & Monitoring Requirements The draft permit includes the following requirements: For the Conditioner Tank: Verify DCP emission rate through performance testing. Install a device to monitor and record the pressure drop across the packed bed scrubber system. Install a device to monitor and record the water flow for the packed bed scrubber system. For the Chrome Etch Tanks: Verify the total chrome emission rate through performance testing. Install a device to monitor and record the pressure drop across each stage of the composite mesh pad scrubber system.

9 Lacks Enterprises, Inc. Page 8 Install a device to monitor and record the water flow for each stage of the composite mesh pad scrubber system during each wash down cycle. For the Electroless Copper Plating Tank: Verify the methanol, formaldehyde and sodium hydroxide emission rates through performance testing. Install a device to monitor and record the pressure drop across the packed bed scrubber system. Install a device to monitor and record the water flow for the packed bed scrubber system. For the Decorative Chrome Electroplating Tanks: Verify the total chrome emission rate through performance testing. Install a device to monitor and record the pressure drop across each stage of the composite mesh pad scrubber system. Install a device to monitor and record the water flow for each stage of the composite mesh pad scrubber system during each wash down cycle. Monitor the surface tension of each tank as required by the NESHAP. For the two Strip Tanks: Verify the nitric acid and sodium hydroxide emission rates through performance testing. Install a device to monitor and record the pressure drop across the packed bed scrubber system. Install a device to monitor and record the water flow for the packed bed scrubber system. Conclusion Based on the analyses conducted to date, staff concludes that the proposed project would comply with all applicable state and federal air quality requirements. Staff also concludes that this project, as proposed, would not violate the federal National Ambient Air Quality Standards or the state and 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. Jeff Rathbun, AQD, at

10 Lacks Enterprises, Inc. Page 9 State Rule R R R R to R R to R R (2)(b) R R R R and R R to R R R R Appendix 1 STATE AIR REGULATIONS 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 to be installed without a permit (see Rules through below). Rule 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 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, 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 ambient air concentration of each toxic air contaminant emitted from the project must not exceed health-based screening levels. Initial Risk Screening Levels (IRSL) apply to cancer-causing effects of air contaminants and Initial Threshold Screening Levels (ITSL) apply to non-cancer effects of air contaminants. These screening levels, designed to protect public health and the environment, are developed by Air Quality Division toxicologists following methods in the rules and U.S. EPA risk assessment guidance. These rules list equipment to processes that have very low emissions and do not need to get an Air Use permit. However, these sources must meet all requirements identified in the specific rule and other rules that apply. Adopts by reference the provisions of 40 CFR to (2002) and 40 CFR to (2002), the federal hazardous air pollutant regulations governing constructed or reconstructed major sources. Limits how air emissions are allowed to look at the end of a stack. The color and intensity of the color of the emissions is called opacity. The particulate emission limits for certain sources are listed. These limits apply to both new and existing equipment. Material collected by air pollution control equipment, such as dust, must be disposed of in a manner, which does not cause more air emissions. Limit the sulfur dioxide emissions from power plants and other fuel burning equipment. 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 rules set VOC limits or work practice standards for existing equipment. The limits are based upon Reasonably Available Control Technology (RACT). RACT is required for all equipment listed in Rules through 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 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 Rules through Nitrogen oxide emission limits for larger boilers and stationary internal combustion engines are 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, a violation may be cited if excessive amounts of odor emissions were found to be preventing residents from enjoying outdoor activities.

11 Lacks Enterprises, Inc. Page 10 State Rule R R R R to R R to R Prevention of Significant Deterioration (PSD) Regulations Best Available Control Technology (BACT) R to R and R STATE AIR REGULATIONS Description of State Air Regulations Air pollution control equipment must be installed, maintained, and operated properly. When requested by the Department, a facility must develop and submit a malfunction 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 exceed the allowable emission rate in a rule and/or permit. Allow the Department to request that a facility test its emissions and to approve the protocol used for these tests. The PSD rules allow the installation and operation of large, new sources and the modification of existing large sources in areas that are meeting the National Ambient Air Quality Standards (NAAQS). The regulations define what is considered a large or significant source, or modification. In order to assure that the area will continue to meet the NAAQS, the permit applicant must demonstrate that it is installing the BACT. By law, BACT must consider the economic, environmental, and energy impacts of each installation on a case-by-case basis. As a result, BACT can be different for similar facilities. In its permit application, the applicant identifies all air pollution control options 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. Applies to new major stationary sources and major modifications as defined in R 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 Rate (LAER). LAER is the lowest emission rate required by a federal rule, state rule, or by a previously issued construction permit. The applicant must also provide emission offsets, 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. Citation Section 109 of the Clean Air Act National Ambient Air Quality Standards (NAAQS) FEDERAL AIR REGULATIONS 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 those with chronic respiratory ailments. The seven pollutants, called the criteria pollutants, are carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), and sulfur dioxide. Portions of Michigan are currently non-attainment for either ozone or PM2.5. Further, in Michigan, State Rules to are used to ensure the public health is protected from other compounds.

12 Lacks Enterprises, Inc. Page 11 Citation 40 CFR Prevention of Significant Deterioration (PSD) Regulations Best Available Control Technology (BACT) 40 CFR 60 New Source Performance Standards (NSPS) 40 CFR 63 National Emissions Standards for Hazardous Air Pollutants (NESHAP) Section 112 of the Clean Air Act Maximum Achievable Control Technology (MACT) Section 112g FEDERAL AIR REGULATIONS Description of Federal Air Regulations or Requirements The PSD regulations allow the installation and operation of large, new sources and the modification of existing large sources in areas that are meeting the NAAQS. The regulations define what is considered a large or significant source, or modification. In order to assure that the area will continue to meet the NAAQS, the permit applicant must demonstrate that it is installing BACT. By law, BACT must consider the economic, environmental, and energy impacts of each installation on a case-by-case basis. As a result, BACT can be different for similar facilities. In its permit application, the applicant identifies all air pollution control options 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 specific sources of pollutants. These New Source Performance Standards (NSPS) apply to new or modified equipment in a particular industrial category. These NSPS set emission limits or work practice standards for over 60 categories of sources. The United States Environmental Protection Agency has set national standards for specific sources of pollutants. The National Emissions Standards for Hazardous Air Pollutants (NESHAP) (a.k.a. Maximum Achievable Control Technology (MACT) standards) apply to new or modified equipment in a particular industrial category. These NESHAPs set emission limits or work practice standards for over 100 categories of sources. In the Clean Air Act, Congress listed 189 compounds as Hazardous Air Pollutants (HAPS). For facilities which emit, or could emit, HAPS above a certain level, one of the following two requirements must be met: 1) The United States Environmental Protection Agency has established standards for specific types of sources. These Maximum Achievable Control Technology (MACT) standards are based upon the best-demonstrated control technology or practices found in similar sources. 2) For sources where a MACT standard has not been established, the level of 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.