The following emission units and control devices associated with the friction materials process are currently permitted:

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1 Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia / Fax: 404/ Judson H. Turner, Director NARRATIVE TO: FROM: Manny Patel Jeng-Hon Su DATE: January 14, 2016 Facility Name: STEMCO Rome AIRS No.: Location: Rome, GA (Floyd County) Application #: Date of Application: December 7, 2015 Background Information STEMCO Rome (hereinafter facility ), formerly Rome Tool & Die, is an existing metal stamping facility located at 113 Hemlock Street SW, Rome, Georgia (Floyd County). The operations at the facility include stamping, forming, turning, milling, grinding, heat treating, welding, and assembly. Before the proposed SIP permit, the facility was operating on SIP Permit No B-01-0 dated January 25, Purpose of Application The facility submits Application No , dated December 7, 2015 for an ownership change and a modification to their brake friction blocks manufacturing process. After the ownership change, the name of the facility is changed from Rome Tool & Die to STEMCO Rome. The process change is described as follows. The following emission units and control devices associated with the friction materials process are currently permitted: Two natural gas fired curing ovens (ID Nos. OVE1 and OVE2) Two natural gas fired thermal oxidizers to control curing emissions (ID Nos. AB1 and AB2) Two automatic paint and print areas (ID Nos. APP1 and APP2) The above emission units and control devices will be replaced with the following: One mixing area (ID No. MIX1): Raw materials (i.e., phenolic resins, metallic fibers, glass fibers, and other fillers) are mixed in a vessel and then disposed in a hopper. Dust recovered by the dust collector is reused as raw material. Two friction materials production lines, each line consists with pre-form presses (ID Nos. PF1 and PF2) with associate dust collectors, heated presses with curing ovens (ID Nos. CR1 and CR2) controlled by a regenerative thermal oxidizer (ID No. RTO1), and finishing areas (ID Nos. FIN1 and FIN2) for grinding, drilling, and labeling with dust collectors. The mixtures from MIX1 are conveyed to PF1 and PF2 for molding. The molded products are dried/cured in CR1 and CR2. The cured products are shaped and grinded per specifications in FIN1 and FIN2. The removed

2 materials in FIN1 and FIN2 and all dust collected by the dust collectors are returned to MIX1 and used as raw materials. The finished and ground products are labeled before packaging. In addition to the above process changes, the facility also identifies changes in emissions from the welding process, and proposed to use RTO1 to control phenol emissions from CR1 and CR2 so that the facility will remain a minor source under Title V of 1990 CAAA. Updated Equipment List Emission Units Associated Control Devices Source Code Description Installation Date Source Code Description MX1 Mixing Area 2015* PF1 Pre-form Area * PF2 Pre-form Area * CR1 Curing Process * CR2 Curing Process * RTO1 Regenerative Thermal Oxidizer FIN1 Finishing Area * FIN2 Finishing Area * GEN1 Emergency Generator Burn Off Oven for Brakeshoe paint burnoff (1.6 MMBtu/hr, natural gas fired) E-Coat Line with Paint Cure Oven (E-coat Oven) (4.25 MMBtu/hr, natural gas fired) Pretreat Heater #1 for first detergent wash (2.5 MMBtu/hr, natural gas fired) Spray Washer (Die Spray Washer) (0.8 MMBtu/hr, natural gas fired) Heat Treat Oven * proposed within current application Emissions Summary Potential emissions from the modified friction materials process are re-evaluated while potential emissions from the existing welding process and the emergency generator (ID No. GEN1) are updated during the review of Application No Potential emissions from the existing sources (ID Nos through 9370) are not changed by this modification. All of the processes/areas (ID Nos. MX1 through FIN1), welding process, and GEN1 would emit particulate emissions. Although the curing ovens at CR1 and CR2 are changed to electric units, their exhaust before entering RTO1 still contains volatile organic compounds (VOC), hazardous air pollutants (HAPs, mainly phenol), and ammonia (NH 3 ). After RTO1, the exhaust contains smaller amounts of VOC, HAP, NH 3, as well as typical combustion products. The labeling process at the finishing areas (ID Nos. FIN1 and FIN2) also emits VOC and HAP emissions. The welding process emits some trace amount of hazardous heavy metals. GEN1 emits typical combustion products. Page 2

3 AP-42 emission factors, lab test data, and mass balance are used to estimate potential emissions from the above mentioned emission units. The background information and emission factors are included in the following. Background Information ID No. Design Capacity Pollution Control Control Efficiency MX tons per hour (tph) Dust Collector 99.5% on PM PF tph Dust Collector 99.5% on PM PF tph Dust Collector 99.5% on PM CR tph RTO1 98% on VOC and HAP CR tph (Burners = 2.4 MMBtu/hr) 50% on NH 3 * FIN tph Dust Collector 99.5% on PM FIN tph Dust Collector 99.5% on PM Labeling of FIN1/FIN2 35 gals resin/yr 41 gals thinner/yr Dust Collector 0% on VOC and HAP Welding 200,000 lbs electrode/yr Dust Collector 99.5% on PM GEN1 60 Hp * All of the nitrogen atoms in controlled NH 3 is assumed to form NO 2. Grinding/Drilling of FIN1 and FIN2 = 20% of products removed and became PM Operating Hour of GEN1 = 500 hrs/yr (defined in GA Air Quality Control Rule) AP-42 Emission Factors MX1 PM EF (AP-42 Table ) = 3 lbs/ton material PF1/PF2 PM EF (AP-42 Table ) = 3 lbs/ton material RTO1 (Natural Gas Combustion) GEN1 Pollutant Emission Factor Source Emission Factor Source NOx 100 lbs/mmcf AP-42 Table lb/hp-hr AP-42 Table CO 84 lbs/mmcf AP-42 Table lb/hp-hr AP-42 Table PM/PM 10 /PM lbs/mmcf AP-42 Table lb/hp-hr AP-42 Table SO lb/mmcf AP-42 Table lb/hp-hr AP-42 Table VOC 5.5 lbs/mmcf AP-42 Table lb/hp-hr AP-42 Table Total GHG lbs/mmbtu 40 CFR 98 Subpart C 164 lbs/mmbtu 40 CFR 98 Subpart C Hexane 1.8 lbs/mmcf AP-42 Table Phenol -- AP-42 Table Formaldehyde lb/mmcf AP-42 Table lb/mmbtu ( lb/hp-hr) AP-42 Table Xylene -- AP-42 Table lb/mmbtu ( lb/hp-hr) AP-42 Table Combined HAP 1.89 lbs/mmcf AP-42 Table & lb/mmbtu ( lb/hp-hr) AP-42 Table Welding HAP EF (AP-42 Tables & 2) = lb Chromium/lb electrode lb Mangnese/ lb electrode lb Nickel/ lb electrode Page 3

4 Lab Test Data Phenol from CR1/CR2 = lb/lb product Formaldehyde from CR1/CR2 = lb/lb product Other VOC from CR1/CR2 = lb/lb product NH 3 from CR1/CR2 = lb/lb prodcut Mass Balance Information Labeling of FIN1 and FIN2, Resin = lbs/gal density, 35% VOC, 7.5% Xylene Labeling of FIN1 and FIN2, Thinner = 6.72 lbs/gal density, 100% VOC With the above background information and emission data, the Division has calculated the following facility-wide potential-to-emit (PTE) with and without RTO1. Note the PTE from the unmodified sources (U.S.) is provided by the facility, and was verified during the review of Application No in Table 1: Facility-wide PTE (tpy) without RTO1 Pollutant U.S. MX1 PF1/PF2 CR1/CR2 FIN1/FIN2 Welding GEN1 Total NOx CO PM/PM 10 /PM SO VOC Total GHG 7, ,740 Single HAP (Phenol) Combined HAP Table 2: Facility-wide PTE (tpy) with RTO1 Pollutant U.S. MX1 PF1/PF2 CR1/CR2 FIN1/FIN2 Welding GEN1 Total NOx CO PM/PM 10 /PM SO VOC Total GHG 7, , ,970 Single HAP (Phenol) Combined HAP Page 4

5 Pollutant Before Facility-Wide Emissions (in tons per year) Potential Emissions* After Emissions Change Before Actual Emissions* After Emissions Change PM (34.7) (12.7) NOx SO CO VOC Max. Individual HAP < >21.0 < N/D** Total HAP < >21.3 < N/D** Total GHG (if applicable) 7,051 7, ,348 8,970 5,622 * Potential Emissions = PTE without RTO1, Actual Emissions = PTE with RTO1 ** N/D = Not Determined Regulatory Applicability 40 CFR 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Per 40 CFR (a)(2)(i), the emergency generator engine (ID No. GEN1) was constructed and manufactured before the associate applicable date; it is not subject to 40 CFR 60 Subpart JJJJ. 40 CFR 63 Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines As discussed previously, the facility is an area source for HAP emissions; per 40 CFR and , the emergency generator engine (ID No. GEN1) is subject to 40 CFR 63 Subpart ZZZZ. Since GEN1 was constructed before June 12, 2006, per 40 CFR (a)(1)(iii), it is an existing reciprocating internal combustion engine (RICE). According to 40 CFR (a)(1), it should be in compliance now. Note that GEN1 is exempt from permitting due to Georgia Rules for Air Quality Control (6)(b)11(i). Since it is not subject to any numeric emission standard, including those of 40 CFR 63 Subpart ZZZZ, it is not included in the SIP permit. The applicable 40 CFR 63 Subpart ZZZZ provisions for GEN1 are 40 CFR (a), Item 4 of Table 2d, 40 CFR (a) and (b), (e)(3), (f) and (i), (f), (a), and (e) and (f). Most importantly, the facility must follow the management practice standards included in Item 4 of Table 2d, which requires that the facility repeatedly change oil and filter and do inspections. 40 CFR 63 Subpart QQQQQ National Emission Standards for Hazardous Air Pollutants for Friction Materials Manufacturing Facilities According to 40 CFR , 40 CFR 63 Subpart QQQQQ is applicable to friction materials manufacturing facility that is a major source of HAP emissions. As discussed previously, the facility is an area source for HAP emissions. Therefore, the facility is not subject to this rule. Page 5

6 Georgia State Rules The facility is subject to Georgia Rule (b) Visible Emissions, Georgia Rule (d) Fuel Burning Equipment, Georgia Rule (e) Particulate Emissions from Manufacturing Processes, and Georgia Rule (g) Sulfur Dioxide. The facility will satisfy the requirements of Georgia Rule (g) by only combusting natural gas all fuel burning sources except the emergency generator (ID No. GEN1) and by only combusting distillate fuel oil in GEN1. Compliance with the other rules are also expected. According to the narrative that explained SIP Permit No B-01-0, the facility has no degreasers onsite, so Georgia Rule (ff) Solvent Metal Cleaning is not applicable. Permit Conditions New Condition 2.1 requires that the facility operates the regenerative thermal oxidizer (ID No. RTO1) at all times when any of the curing processes (ID Nos. CR1 and CR2) are in operation. The facility states in Application No that RTO1 has a minimum phenol (and also VOC) destruction efficiency of 98%. Without RTO1, phenol emissions from CR1 and CR2 can be as high as 22.0 tpy, which would have made the facility a major HAP source. Therefore, the requirements specified in Condition 2.1 are for avoiding being a Title V major source for single HAP emission. Condition 2.2 specifies natural gas be the only fuel type for all fuel burning sources at the facility except any emergency generator. Condition 2.3 includes the Georgia Rule (b) visible emission limits for every process at the facility. Condition 2.4 includes the Georgia Rule (d) PM and visible emission limits for any fuel burning equipment. Condition 2.5 includes the Georgia Rule (e) PM emission limit for every process at the facility. Per the narrative that explains SIP Permit No B-01-0, Condition 2.6 limits the particulate matter emissions from the baghouses to 0.02 gr/dscf in order to satisfy Georgia Rule (b). New Condition 4.2 requires that the facility maintain the combustion zone temperature of RTO1 above the average combustion zone temperature measured and recorded during the most recent performance test approved by the Division, per Condition 6.2. Condition 4.3 requires the facility to operate the control equipment. The requirement specified in existing Condition 4.4 of SIP Permit No B-01-0is no longer included in this Permit because there is no afterburners after the process change. Condition 4.4 requires the facility to ensure that the differential pressures across the baghouses are within the established ranges. Condition 4.5 requires additional bags as replacements. New Condition 5.1 requires that the facility continuously monitor and record the combustion zone temperature of RTO1. Data must be recorded once every 15 minutes and reduced to three hour rolling averages. Condition 5.2 requires the facility to install a pressure monitor for the baghouses. Condition 5.3 requires the facility to conduct a daily visible emission (VE) check on each baghouse. Page 6

7 New Condition 6.2 includes the initial and repeated RTO1 control efficiency performance testing requirements. The facility is required to demonstrate the 98-percent phenol destruction efficiency. The facility is also required to establish the average combustion zone temperature during the tests. New Condition 7.1 requires that the facility establish, document, and implement an inspection and maintenance plan for RTO1. Note that the modification described in SIP Application No is for modifying the design of the friction material processes, which is already permitted. The Division is not sure if the facility would have completed the modification when the proposed permit is issued. So the facility must comply with the requirements specified in Conditions 6.2 and 7.1 within 120 days after the issuance of this Permit, or within 120 days after the initial startup of CR1 and CR2, whichever comes later. Condition 7.2 requires the facility to maintain records of the manufacturer s acceptable pressure drop ranges for each baghouse. In the event if the facility operates the curing processes (ID Nos. CR1 and CR2) without operating the regenerative thermal oxidizer (ID No. RTO1), the facility must be able to demonstrate how it will maintain a minor source for single and combined HAP emissions under Title V of 1990 CAAA. Therefore, the facility is required by new Conditions 7.3 and 7.4 to track its HAP emission rates. Since the facility is now a synthetic minor (SM) source and is subject to a flat SM source permit fee, new Condition 8.2 includes the permit fee requirement. Finally, Condition 8.3 revokes the current SIP permit. Toxic Impact Assessment As discussed previously, the emission changes in single and combined HAP emissions are not determined. According to the narrative that explained SIP Permit No B-01-0, the facility-wide PTE for single and combined HAP is each below 1 tpy before the proposed modification. According to Table 1, the facility-wide PTE for single and combined HAP will still be below 1 tpy after the proposed modification. The Division therefore determines that the HAP emission change is negligible, and a detailed toxic impact analysis is not needed for Application No Summary & Recommendations I recommend that Permit No S-02-0 be issued to the facility. A public advisory was issued on December 23, 2015 and expired on January 22, No comment was received. The Mountain District (Cartersville) Office remains responsible for inspections and complaints/investigations. Page 7