ATIEVA USA INC. CASA GRANDE

Transcription

1 ATIEVA USA INC. CASA GRANDE 1. INTRODUCTION LISTING OF (FEDERALLY ENFORCEABLE) APPLICABLE REQUIREMENTS COMPLIANCE CERTIFICATION... 5 A. COMPLIANCE PLAN... 5 B. COMPLIANCE SCHEDULE AUTHORITY TO CONSTRUCT... 5 A. GENERALLY... 5 B. MINOR NEW SOURCE REVIEW REQUIREMENTS EMISSION LIMITATIONS AND CONTROLS... 8 A. APPLICABLE LIMITATIONS... 8 B. ALLOWABLE EMISSIONS... 8 C. MINOR SOURCE STATUS - VOC'S AND HAP'S Major Source Thresholds Annual Emission Cap and Product Use Limitations Consumables Expansion Consumable Expansion Notification... 9 D. SPRAY PAINT AND OTHER SURFACE COATING OPERATIONS... 9 E. CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS - RTO OPERATING REQUIREMENTS Minimum Destruction Efficiency Temperature Monitoring System Minimum Operating Temperature F. CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS - ADR OPERATING REQUIREMENTS Minimum Destruction Efficiency ADR parameters G. CONTROL OF PARTICULATE MATTER EMISSIONS Mass Emissions Limitation a. Particulate Emissions Fuel Burning Equipment b. Particulate Emissions Fossil Fuel Fired Industrial Equipment and Stationary Rotating Machinery H. NITROGEN OXIDES EMISSION Boilers and Water Heaters RTOs and other Unclassified Sources I. SULFUR DIOXIDE EMISSIONS Boilers and Water Heaters RTOs and other Unclassified Sources J. OPACITY LIMITS SIP Limitation Visibility Limiting Standard K. PARTICULATE MATTER REASONABLE PRECAUTIONS L. SURFACE STABILIZATION M. NSPS (SUBPART MM) STANDARDS AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS For each Electrodeposition prime coat operation: For each nonelectrodeposition prime coat operation: N. NSPS (SUBPART IIII) STANDARDS STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION ENGINES O. FUEL USE LIMITATIONS Primary Fuels

2 P. GENERAL MAINTENANCE OBLIGATION COMPLIANCE DEMONSTRATION A. VOC AND HAP EMISSIONS MONITORING AND RECORDKEEPING Product Labeling Consumable Log Monthly Usage Summary B. REGULAR EMISSIONS MONITORING AND RECORDKEEPING Non-instrumental emissions monitoring - oxides of nitrogen and carbon monoxide SOx monitoring Opacity monitoring C. OPERATIONAL MONITORING Spray Booths Operation Monitoring ADR and RTO Operation Monitoring ADR and RTO Planned Shutdowns D. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS MONITORING PROVISIONS E. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS REPORTING AND RECORDKEEPING PROVISIONS F. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS PERFORMANCE TEST AND COMPLIANCE PROVISION G. NSPS (SUBPART IIII) INTERNAL COMBUSTION ENGINE (ICE) OPERATIONAL COMPLIANCE DEMONSTRATION H. PERFORMANCE TESTING Generally Applicable Test Program Requirements a. Test Requirement b. Test Protocol c. Timing of initial and subsequent tests d. Test Report RTO Testing - Destruction Efficiency Verification ADR Testing Capture Efficiency Testing I. RECORDKEEPING J. SEMI-ANNUAL COMPLIANCE REPORTING K. ANNUAL REGULAR COMPLIANCE/COMPLIANCE PROGRESS CERTIFICATION OTHER REPORTING OBLIGATIONS A. DEVIATIONS FROM PERMIT REQUIREMENTS B. NOTIFICATION OF CONSTRUCTION, START-UP AND INITIAL COMPLIANCE Notification of Construction & Start-up NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations Notification Requirements C. ANNUAL EMISSIONS INVENTORY FEE PAYMENT GENERAL CONDITIONS A. TERM B. BASIC OBLIGATION C. DUTY TO SUPPLEMENT APPLICATION D. RIGHT TO ENTER E. TRANSFER OF OWNERSHIP F. POSTING OF PERMIT G. PERMIT REVOCATION FOR CAUSE

3 H. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS I. PERMIT EXPIRATION AND RENEWAL J. SEVERABILITY K. PERMIT SHIELD L. PERMIT REVISIONS M. PERMIT RE-OPENING N. RECORD RETENTION O. SCOPE OF LICENSE CONFERRED P. EXCESS EMISSION REPORTS; EMERGENCY PROVISION EQUIPMENT A. PERMITTED EQUIPMENT B. INSIGNIFICANT ACTIVITIES EMISSION INVENTORY TABLE APPENDIX A: SEMI-ANNUAL REPORT

4 1. Introduction This permit pertains to a new automobile manufacturing facility operated by Atieva USA INC, a Delaware corporation, and commonly referred to as Lucid Motors. The source falls under SIC Code 3711: Automobile and Light Duty Truck Assembly and NAICS code : Automobile Manufacturing. The facility is located at the southwest corner of Peters Road and Thorton Road in Casa Grande, Arizona, upon parcels also identified by Pinal County Assessor Parcels # F, J, B, C, E, A, B, A, B. The source is situated in an area classified as non-attainment for PM10 and attainment for all other pollutants. Lucid Motors is an automobile manufacturing facility consisting of production areas and support facilities, including utilities and an on-site test track. The production areas include separate buildings for the body shop, paint shop, and assembly shop. The main emission sources include spray paint booths, drying ovens, water boilers, air supply units, emergency generator-engines, and a firewater pump engine. The facility is a minor stationary source of regulated air pollutants. Applicable Federal standards include New Source Performance Standards (NSPS), Subpart MM for Automobile and Light Duty Truck Surface Coating Operations, and Subpart IIII for Stationary Compression Ignition Internal Combustion Engines. Typical spray paint operations may give rise to emissions of organic material in the form of volatile organic compounds (VOCs). VOCs may also constitute either hazardous air pollutants (HAPs) or photochemically reactive solvents (PRS). The use of VOCs, HAPs and PRSs are all subject to different use-based regulatory thresholds. Exceeding those thresholds triggers a variety of differing regulatory obligations. In the absence of the limitations established in this permit, this source would have an uncontrolled potential to emit that could trigger the need for a permit subject to Title V of the Clean Air Act (1990) ("CAA"). However, at the source's request, this permit includes proposed "federally enforceable provision(s)" ("FEP"), designated pursuant to Code The source includes spraying equipment. A complete list of equipment from which emissions are allowed by this permit is given in section 7 of this permit. As an informational disclosure, emissions listed in the last section of this permit entitled "EMISSION INVENTORY TABLE" constitute good-faith estimates of emissions subject to regulation, as set forth in the application for permit. 2. Listing of (Federally Enforceable) Applicable Requirements A. The listed specific provisions of the Pinal-Gila Counties Air Quality Control District (PGAQCD) Regulations, as adopted by the Pinal County Board of Supervisors on the dates listed, and approved by the Administrator as elements of the Arizona State Implementation Plan (SIP) by the Federal Register (FR) notice listed: Visible Emissions; General (6/16/80) 47 FR (4/12/82) Emission Standards - Particulate Emissions - Fugitive Dust (3/31/75) 43 FR (11/15/78) B Fuel-Burning Equipment Nitrogen Oxide Emissions (3/31/75) 43 FR (11/15/78)] Fuel-Burning Equipment Particulate Emissions (3/31/75) 43 FR (11/15/78) 4

5 B. Those specific provisions of the Pinal County Air Quality Control District Code of Regulations (Code), as adopted by the Pinal County Board of Supervisors on dates listed, and approved by the Administrator as elements of the Arizona State Implementation Plan (SIP) by the Federal Register (FR) notice listed: Visibility Limiting Standard (5/18/05) 71 FR (3/27/06) Fugitive Dust Standards (6/29/93) 72 FR (08/01/07) Fossil Fuel Fired Steam Generator Sulfur Dioxide Emission Limitation (2/22/95) 65 FR (9/29/00) C. The New Source Performance Standards (NSPS), 40 CFR Part 60 Subpart MM, for Automobile and Light Duty Truck Surface Coating Operations, 40 CFR , 392, 393, 394, 395, 396, 397. D. The New Source Performance Standards (NSPS), 40 CFR Part 60 Subpart IIII, for Stationary Compression Ignition Internal Combustion Engines, 40 CFR , (b), (b), , (a),(c),(f). E. General Provisions, 40 CFR 60, Subpart A, 40 CFR provisions as defined in 40 CFR Subpart MM and as listed in Table 8 of 40 CFR 60, Subpart IIII. 3. Compliance Certification A. Compliance Plan (Code C, A.7) Insofar as the Permittee is currently in compliance, the compliance plan consists of continued adherence to the requirements of this permit. B. Compliance Schedule (Code B.1, A.7.c) 4. Authority to Construct Insofar as the Permittee is currently in compliance, no compliance schedule to attain compliance is required. A. Generally [Federally enforceable pursuant to PCAQCD Code , ( 10/12/95) approved as a SIP element at 65 FR (12/20/00)] 1. As an exercise of authority under PCAQCD's SIP-approved minor new source review program, this permit authorizes the construction of the equipment enumerated in the "Equipment Schedule" below. Emissions from this facility, specifically the emissions from the equipment described in the Equipment Schedule, and the operating configuration more fully described in the application for permit, fall subject to the enforceable limitations set forth either below or elsewhere in this permit. Therefore, based on the regulations in effect upon the date of issuance of this permit and a finding that allowable emissions from the equipment described in the Equipment Schedule will 5

6 neither cause nor contribute to a violation of any ambient air quality standard even without additional limitations, and a further finding that in view of this permit this does not constitute a "major emitting source" within the meaning of Code , this permit constitutes authority to construct and operate such equipment. 2. Definitions and acronyms a. For the purposes of this permit the combustion zone shall be defined as the area in which the primary VOC destruction occurs, in the plenum between the media beds, in accordance with manufacturer specifications. b. Adsorption-desorption-recovery (ADR) c. Regenerative Thermal Oxidizer (RTO) B. Minor New Source Review Requirements [Federally enforceable pursuant to PCAQCD Code , (10/12/95) approved as a SIP element at 65 FR (12/20/00)] Recognizing that the predominant potential emissions from this facility will result from painting operations and recognizing that elements of this permit impose emission limitations on VOCs this permit imposes the following "minor NSR" emission limitations on this facility. 1. VOC Facility-Wide Synthetic Minor Cap [Federally enforceable provision, pursuant to Code (8/15/94) approved as a SIP element at 61 FR (12/20/00)] (Code A) Permittee shall limit the facility-wide VOC emissions to a rolling 12-month total of 80 tons. 2. Except for allowed and quantified RTO bypass events as defined below, emissions from the following processes and equipment shall be captured upon startup as described below and controlled by a RTO system, with a minimum VOC destruction efficiency of 98%. The Permittee shall operate the following equipment in accordance with manufacture s specifications to ensure 100% capture of VOCs. - Equipment B01 ED Oven 1 - Equipment B02 Sealer Oven - Equipment B03 Primer Oven - Equipment B05 Top Coat Oven 3. Except for allowed and quantified RTO bypass events as defined below, emissions from the following processes and equipment shall be captured upon startup as described below and controlled by an ADR/RTO system, with a minimum VOC destruction efficiency of 92%. The Permittee shall operate the following equipment in accordance with manufacture s specifications to ensure 100% capture of VOCs. - Equipment B04 Heated Flash Oven 1 4. Except for allowed and quantified RTO bypass events as defined below, emissions from the following processes and equipment shall be captured upon startup as described below 6

7 and controlled by an ADR/RTO system, with a minimum VOC destruction efficiency of 92%. - Process A08 Primer Booth (75% VOC capture efficiency to the ADR and 19% capture efficiency to the oven); - Process A10 Clear Coat Booth (83% VOC capture efficiency to the ADR and 12% capture efficiency to the oven) 5. Permittee shall be allowed to bypass the exhaust of all ovens routed to the RTO or ADR/RTO and the exhaust of the spray booths which are connected to the ADR up to 8 hours per year due to RTO malfunction. The VOC emissions emitted to the ambient air during each bypass event shall be quantified via a mass balance methodology and the Permittee shall maintain a record of the associated calculations. The bypass emissions shall be included in the rolling 12-month VOC totals and shall count towards the annual VOC cap. 6. Particulate emissions from the following processes and equipment shall be captured upon startup as described below and controlled by an E-Cube / Dry filter system connected to an ADR system, with a minimum average particulate matter collection efficiency of 99%. The Permittee shall operate the following paint booths in accordance with manufacture s specifications to ensure 100% capture of particulate matter in the air stream. Some particulate matter will be lost on surfaces and is not included in this capture efficiency. - Process A08 Primer Booth; - Process A10 Clear Coat Booth 7. Particulate emissions from the following processes and equipment shall be captured upon startup as described below and controlled by an E-Cube / Dry filter system, with a minimum average particulate matter collection efficiency of 95%. The Permittee shall operate the following paint booths in accordance with manufacture s specifications to ensure 100% capture of particulate matter in the air stream. Some particulate matter will be loss on surfaces and is not included in this capture efficiency. - Process A09 Base Coat Booth 8. Particulate emissions from the following processes and equipment shall be captured upon startup as described below and controlled by a Dry filter system, with a minimum average particulate matter collection efficiency of 95%.The Permittee shall operate the following paint booths in accordance with manufacture s specifications to ensure 100% capture of particulate matter in the air stream. Some particulate matter will be loss on surfaces and is not included in this capture efficiency. - Process A14 Wax Line 9. Particulate emissions from the following processes and equipment shall be captured upon startup as described below and controlled by a Dry filter system, with a minimum particulate matter efficiency of 90%. - Process A11 Spot-Repair Booths 1,2 and 3 (100% PM capture efficiency); - Process A12 Spot-Repair Booths 1,2 and 3 (100% PM capture efficiency); 7

8 10. Permittee shall install a non-resettable hour meter prior to the startup of the emergency internal combustion engines and shall not operate the each emergency engine more than 500 hours per year. 11. Permittee shall install temperature sensors capable of monitoring the RTO combustion zone temperature and the ADR desorption temperature. 12. The Permittee shall install pressure sensors on all spray booth supply and exhaust fans. 13. The Permittee shall install volume regulators in the exhaust of the automatic application zone of the following processes. i. Process A08 Primer Booth ii. Process A09 Base Coat Booth iii. Process A10 Clear Coat Booth 5. Emission Limitations and Controls A. Applicable Limitations [Federally enforceable pursuant to PCAQCD Code (11/3/93) approved as SIP Elements at 65 FR (12/20/00)] Where different standards or limitations apply under this permit, the most stringent combination shall prevail and be enforceable. B. Allowable Emissions [Federally enforceable pursuant to PCAQCD Code (10/12/95) approved as SIP Elements at 65 FR (12/20/00)] 1. The owner/operator ("Permittee") is authorized to discharge or cause to discharge into the atmosphere those emissions of air contaminants as set forth in this permit. Unless exempted under Code , Permittee shall not use any material, process, or equipment not identified in this permit which will cause emissions of any regulated air pollutant in excess of the 5.5 pound-per-day de minimis amount, unless authorized by a permit revision under as allowed under this permit, or by a separate permit issued by the District or other competent authority. 2. Insignificant Activities (Code a, ) Apart from the authority of this permit, Permittee is authorized to discharge or cause to discharge into the atmosphere emissions from insignificant activities, as defined in Code a. Section 10 of this permit includes a non-limiting schedule of specific activities that the District concurs qualify for "insignificant" status. C. Minor Source Status - VOC's and HAP's [Federally Enforceable Provision pursuant to code (8/15/94) approved as SIP Elements at 61 FR (4/9/96)] 1. Major Source Thresholds a. VOC Emissions 8

9 Permittee shall limit the emissions of VOC's to less than 100 tons during any 12 month period. b. HAP Emissions - Single Pollutant Emission Limitation Permittee shall limit the emission of any single HAP to less than 10 tons during any 12 month period. c. HAP Emissions - Combined Emission Limitation Permittee shall limit the emissions of any combination of HAP's to less than 25 tons during any 12 month period. 2. Annual Emission Cap and Product Use Limitations In order to stay below major source categories, permittee shall limit VOC emissions to 80% (80 tons per year) of the 100 ton per year threshold for VOCs by tracking and limiting the use of all approved paints and solvents. Permittee shall demonstrate compliance with this threshold as indicated in the Compliance Demonstration section of this permit. In order to stay below major source categories, permittee shall limit HAP emissions to 80% (8 tons per year for individual HAPs and 20 tons per year for total HAPs) of the 10/25 ton per year threshold for HAPs by tracking and limiting the use of all approved paints and solvents. Permittee shall demonstrate compliance with this threshold as indicated in the Compliance Demonstration section of this permit. 3. Consumables Expansion Due to the nature of the business, permittee may expand the foregoing list of consumables to add other products which conform to the limitations below, and as long as it can be shown that VOC and HAP emissions will not exceed 80% of the major source thresholds. 4. Consumable Expansion Notification Permittee shall submit, either by or mail, notification of any new product being added to the list of consumables prior to the use of the product. Material Safety Data Sheets or Environmental Data Sheets shall be provided when made available from the manufacturer. D. Spray paint and other Surface Coating Operations (Code ) 1. Photochemically Reactive Solvents Disposal Limitation No person shall, during any one day, dispose of a total of more than one and one-half gallons of any photochemically reactive solvent, as defined above or of any material containing more than one and one-half gallons of any such photochemically reactive solvent by any means which will permit the evaporation of such solvent into the atmosphere. 2. To limit emissions of particulate matter ("PM 10"), no person shall conduct any spray paint operations without using an enclosed area (3 sided structure with walls a minimum of 8 feet high) designed to contain not less than 96% by weight of the over spray. 9

10 3. To conform to the foregoing over spray capture and control requirement, Permittee shall: a. Conduct painting operations in a spray paint booth or building, equipped with at least 90% reduction efficiency filters on all exhaust points. b. Each spray booth shall be equipped with a pressure drop measurement device and the Permittee shall maintain a pressure drop of at least 0.05 inches of water across each filter. E. Control of Volatile Organic Compound Emissions - RTO Operating Requirements [Federally Enforceable Provision pursuant to code (8/15/94) approved as SIP Elements at 61 FR (4/9/96)] 1. Minimum Destruction Efficiency At a minimum, the RTO shall maintain a VOC destruction efficiency of not less than 98%. 2. Temperature Monitoring System The Permittee shall install and operate on each RTO unit a temperature monitoring system that continuously monitors the temperature in the oxidizer combustion zone, and that temperature monitoring system shall be accurate to within 0.75% of observed temperature. The continuous temperature monitoring system shall also be equipped with a system to log those temperatures, electronically or otherwise, at least once every 15 minutes. Each temperature monitoring system shall be equipped with an alarm, adequate to alert the permittee if instantaneous observed temperatures in the combustion zone fall below the minimum operating temperature. 3. Minimum Operating Temperature Permittee shall maintain an average minimum temperature of 1450 F in the combustion zone of each RTO unit, based upon a rolling 1-hour average of monitored temperatures, or another adequate temperature as demonstrated by a performance test. Observed excursions below that average minimum temperature shall trigger a requirement for a corrective action plan, as defined in the compliance section below. The 1450 F operational limit shall apply to the RTO units until individual operating ranges are established by testing as required by this permit. F. Control of Volatile Organic Compound Emissions - ADR Operating Requirements [Federally Enforceable Provision pursuant to code (8/15/94) approved as SIP Elements at 61 FR (4/9/96)] 1. Minimum Destruction Efficiency At a minimum, each ADR shall maintain a VOC control efficiency of not less than 92%. 2. ADR parameters Pressure drop across ADR cannot be greater than 12 mbar (1200 Pa). Desorption air temperature shall be maintained at a minimum of 370 F (187 C). G. Control of Particulate Matter Emissions 10

11 1. Mass Emissions Limitation a. Particulate Emissions Fuel Burning Equipment [PGCAQCD Reg (3/31/75) approved as a SIP element at 43 FR (11/15/78)] For equipment with a heat input capacity of less than 4,000 million Btu per hour, particulate emissions shall not exceed: Y = 1.02X , where Y = maximum emissions in lbs./hr. for each million BTU per hour heat input, and X = maximum heat input capacity in million BTU per hour. b. Particulate Emissions Fossil Fuel Fired Industrial Equipment and Stationary Rotating Machinery (Code and ) The maximum allowable emissions shall be determined by the following equation: E = E = Q = 1.02Q where: the maximum allowable particulate emissions rate in pounds-mass per hour and the total heat input of all operating fuel-burning units of stationary rotating machinery on the premises in million Btu/hr. H. Nitrogen Oxides Emission 1. Boilers and Water Heaters [Federally Enforceable Provision pursuant PGCAQCD Reg B (3/31/75) approved as a SIP element at 43 FR (11/15/78)] (Code ) The steam boilers and water heaters shall not emit more than 0.20 pounds of nitrogen oxides, maximum two-hour average, calculated as nitrogen dioxide, per million Btu heat input when gaseous fuel is fired, and shall only burn gaseous fuel. 2. RTOs and other Unclassified Sources (Code A.3.) I. Sulfur Dioxide Emissions The Permittee shall not emit more than 500 parts per million of nitrogen oxides expressed as NO 2 from the RTOs and any unclassified source. 1. Boilers and Water Heaters [Federally Enforceable Provision pursuant Code (2/22/95) approved as a SIP element at 65 FR (9/29/00)] The steam boilers and water heaters shall only burn gaseous fuel. 2. RTOs and other Unclassified Sources (Code A.2) 11

12 J. Opacity Limits The permittee shall not emit more than 600 parts per million of sulfur dioxide from the RTOs and any unclassified source. 1. SIP Limitation [Federally enforceable pursuant to PGAQCD Reg (8/7/80) approved as a SIP element at 47 FR (4/12/82)] The opacity of any plume or effluent shall not be greater than 40 percent as determined by Reference Method 9 in the Arizona Testing Manual (ADEQ, 1992). Nothing in this limitation shall be interpreted to prevent the discharge or emission of uncontaminated aqueous steam, or uncombined water vapor, to the open air. 2. Visibility Limiting Standard [Federally enforceable pursuant to Code (5/18/05) approved as a SIP element at 71 FR (3/27/06)] The opacity of any plume or effluent from any point source not subject to a New Source Performance Standard adopted under Chapter 6 of the Code, and not subject to an opacity standard in Chapter 5 of the Code, shall not be greater than 20% as determined in Method 9 in 40 CFR Part 60, Appendix A. Emissions from spray painting are subject to this standard. K. Particulate Matter Reasonable Precautions [Federally enforceable pursuant to Code (6/29/93) approved as a SIP element at 72 FR (8/1/07) and PGAQD Reg (7/1/75) approved as a SIP element at 43 FR 53034(11/15/78)] 1. Permittee shall not cause, suffer, allow, or permit a building or its appurtenances, subdivision site, driveway, parking area, vacant lot or sales lot, or an urban or suburban open area to be constructed, used, altered, repaired, demolished, cleared, or leveled, or the earth to be moved or excavated, or fill dirt to be deposited, without taking reasonable precautions to effectively prevent fugitive dust from becoming airborne. 2. Permittee shall not cause, suffer, allow, or permit a vacant lot, or an urban or suburban open area, to be driven over or used by motor vehicles, such as but not limited to allterrain vehicles, trucks, cars, cycles, bikes, or buggies, without taking reasonable precautions to effectively prevent fugitive dust from becoming airborne. 3. Permittee shall not disturb or remove soil or natural cover from any area without taking reasonable precautions to effectively prevent fugitive dust from becoming airborne. 4. Permittee shall not crush, screen, handle or convey materials or cause, suffer, allow or permit material to be stacked, piled or otherwise stored without taking reasonable precautions to effectively prevent fugitive dust from becoming airborne. 5. Stacking and reclaiming machinery utilized at storage piles shall be operated at all times with a minimum fall of material and in such a manner, or with the use of spray bars and wetting agents, as to prevent excessive amounts of particulate matter from becoming airborne. Other reasonable precautions shall be taken, as necessary, to effectively prevent fugitive dust from becoming airborne. 12

13 6. Permittee shall not cause, suffer, allow or permit transportation of materials likely to give rise to fugitive dust without taking reasonable precautions to prevent fugitive dust from becoming airborne. Earth and other material that is tracked out or transported by trucking and earth moving equipment on paved streets shall be removed by the party or person responsible for such deposits. L. Surface Stabilization [Code , adopted 10/28/15, effective 1/1/16] 1. Permittee shall not cause or allow visible fugitive dust emissions from open areas / vacant lots (areas not currently utilized for an activity) to exceed 20% opacity based on EPA Method 9 or the continuous plume or intermittent plume methods listed in PCAQCD Code Permittee shall erect barriers or no trespassing signs upon evidence of trespass on open areas / vacant lots. 3. Permittee shall stabilize any open area / vacant lot greater than 1.0 acre that has 0.5 acre or more of disturbed surface and sign up for the Pinal County Dust Control forecast within 30 days of discovery. The open area / vacant lot shall be stabilized the day leading up to and the day that is forecast to be high risk for dust emissions. 4. Permittee shall not remove vegetation from open areas / vacant lots without applying dust suppressants before and during the weed abatement. Trackout onto paved surfaces must be prevented or eliminated and dust suppressants must be applied following weed abatement to stabilize the entire surface. 5. Stabilization of open areas / vacant lots is determined by the drop ball, threshold friction velocity, flat vegetation or standing vegetation methods listed in PCAQCD Code Permittee shall not cause or allow visible fugitive dust emissions from unpaved lots (areas being utilized for an activity) greater than 5000 square feet to exceed 20% opacity based on EPA Method 9 or the continuous plume or intermittent plume methods listed in PCAQCD Code Permittee shall not allow silt loading equal to or greater than 0.33 oz/ft 2 or allow the silt content to exceed 8% on unpaved lots greater than 5000 square feet. 8. Permittee shall stabilize unpaved lots greater than 5000 square feet by paving, applying a dust suppressant or graveling. 9. Permittee shall clean up trackout on a paved public roadway that exceeds 50 feet within 24 hours of discovery and limit opacity to 20% or less while using a rotary brush or broom. 10. Permittee shall make a record of the control measures applied. M. NSPS (Subpart MM) Standards Automobile and Light Duty Truck Surface Coating Operations [Federally enforceable pursuant to 40 CFR ] These standards apply to the following affected facilities in an automobile or light-duty truck assembly plant: each prime coat operation and each topcoat operation 13

14 On and after the date on which the initial NSPS Subpart MM performance test required by 40 CFR 60.8 and as described in 6.H of this permit is completed, no owner or operator subject to the provisions of NSPS Subpart MM shall discharge or cause the discharge into the atmosphere from any affected facility VOC emissions in excess of: 1. For each Electrodeposition prime coat operation: a kilogram of VOC per liter of applied coating solids when the solids turnover ratio is 0.16 or greater. b ( R T) kg of VOC per liter of applied coating solids when the solids turnover ratio is greater than or equal to and less than c. When the solids turnover ratio is less than 0.040, there is no emission limit. 2. For each nonelectrodeposition prime coat operation: a kilogram of VOC per liter of applied coating solids. b kilograms of VOC per liter of applied coating solids from each guide coat operation. c kilograms of VOC per liter of applied coating solids from each topcoat operation (including each basecoat and clearcoat operation). N. NSPS (Subpart IIII) Standards Stationary Compression Ignition Internal Combustion Engines [Federally enforceable pursuant to 40 CFR (a), (b)(c), , (a)(c)] Owners and operators of 2007 model year and later stationary compression ignition engines must purchase an engine that meets the emission standards listed in 40 CFR and 40 CFR for emergency generators or Table 4 of 40 CFR Part 60, Subpart IIII for fire pump engines for the same model year and maximum engine power and operate and maintain the engine according to the manufacturer s instructions for the entire life of the engine. O. Fuel Use Limitations 1. Primary Fuels (Code ) a. The Permittee shall only burn natural gas in the ADR, RTO, boilers and heaters. b. The Permittee shall only burn low sulfur diesel which contains less than 0.9 percent sulfur by weight in the fire pump and emergency generators. (Code F) c. Federal Fuel limitations [Federally enforceable pursuant to 40 CFR b] For 2007 and later engines Permittee shall use a diesel fuel that meets the requirements in 40 CFR (c) for nonroad diesel fuel: i. 15 ppm maximum sulfur for diesel fuel; ii. Cetane index or aromatic content, as follows: A minimum cetane index of 40, or; 14

15 A maximum aromatic content of 35 volume percent. d. The Permittee shall not use used oil, used oil fuel, hazardous waste, and hazardous waste fuel (as defined in federal, state, or county codes and rules) without first obtaining a separate permit or an appropriate permit revision. [Federally enforceable pursuant to PCAQCD Code (9/5/01) approved as a SIP element at 66 FR (12/5/01) P. General Maintenance Obligation [Federally Enforceable Provision pursuant to code E (9/5/01) approved as a SIP element at 66 FR (12/5/01)](Code A.3) At all times, including periods of start-up, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate the permitted facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. 6. Compliance Demonstration A. VOC and HAP Emissions Monitoring and Recordkeeping [Federally Enforceable Provision pursuant to code (8/15/94) approved as a SIP element at 61 FR (4/9/96)] To demonstrate continuing compliance with the emissions limitations established under this permit, Permittee shall: 1. Product Labeling To enable compliance verification with respect to the foregoing product formulation and use limitations, all containers containing one or more gallons of material containing more than 5% by volume of VOC shall be in closed containers and legibly labeled to identify the contents. 2. Consumable Log a. Permittee shall maintain a log listing of all consumables utilized in the subject operation, including a separate listing for each paint, coating, solvent, or adhesive that identifies for each respective consumable product: i. the product or products manufacturer ii. iii. iv. the manufacturer's product identification number the relevant material data safety sheet (MSDS) or environmental data sheet (EDS) number and issue date; the vendor; b. A copy of the MSDS or EDS sheet for each consumable product. 3. Monthly Usage Summary a. Within fourteen (14) working days of the end of each calendar month, Permittee shall generate a material usage report summarizing the quantity, in gallons, of all 15

16 coating products, thinners, solvents, and adhesives utilized during the preceding calendar month. b. Within fourteen (14) working days of the end of each calendar month, Permittee shall generate a rolling 12 month total report providing actual VOC and HAP emissions in tons per year based on the material usage report. This report shall also include any bypass emissions that have occurred during the month and the associated calculations. c. For any month in which the rolling 12 month total report exceeds 40 tons per year of VOC the Permittee shall develop a 12-month rolling VOC emission budget report. This emission budget report shall be based on the past 10 months of historical VOC emissions data and the amount of emissions (or emissions budget) that could be allowable in the upcoming 2 months (including the current month) without exceeding the 80 tons per year VOC emission cap. For any month in which the rolling 12 month total report exceeds 4 tons per year of individual HAP or 10 tons of total HAPs the Permittee shall develop a 12- month rolling HAP emission budget report. This emission budget report shall be based on the past 10 months of historical HAP emissions data and the amount of emissions (or emissions budget) that could be allowable in the upcoming 2 months (including the current month) without exceeding the 8 tons per year individual HAP emission cap and the 20 ton per year total HAP emissions cap. d. For any month in which the rolling 12 month total VOC report exceeds 70 tons per year of VOCs the Permittee shall generate the material usage report, the rolling 12-month total report and 12-month rolling emission budget report on a weekly basis until the rolling 12-month total falls below 70 tons per year. For any month in which the rolling 12 month individual HAP report exceeds 7 tons or the total HAP report exceeds 18 tons per year of HAPs the Permittee shall generate the material usage report, the rolling 12-month total report and 12-month rolling emission budget report on a weekly basis until the rolling 12- month totals fall below 7 tons per year for individual HAPs and 18 tons per year for total HAPs. B. Regular Emissions Monitoring and Recordkeeping [Federally Enforceable Provision pursuant to code A (2/22/95)) approved as a SIP element at 65 FR (12/20/00)] 1. Non-instrumental emissions monitoring - oxides of nitrogen and carbon monoxide As a surrogate measurement for monitoring emissions of oxides of nitrogen and carbon monoxide, Permittee shall maintain records reflecting total fuel consumption in the thermal oxidizers, ovens, engines, boilers and other fuel burning equipment. On an annual basis, no later than March 31 st to adequately support the annual emission inventory, permittee shall calculate NOx and CO emissions based on the fuel records. For these calculations, Permittee shall use emission factors from the specific equipment manufacturer, if available, or otherwise, AP-42 or other factors as approved by the Director. 2. SOx monitoring 16

17 As an alternative to monitoring fuel sulfur, Permittee shall maintain an annual certification from the fuel supplier that the natural gas and the diesel fuel utilized does not contain more than 0.9% by weight. 3. Opacity monitoring C. Operational Monitoring On at least a semi-annual basis, Permittee shall conduct a visual opacity screen on each process and fuel-burning exhaust stack. If visible emission in excess of 5% opacity are observed, Permittee shall have a full Method 9 opacity test performed by a certified opacity observer, and shall provide a copy of the resulting report to the District within 10 days. Submission of such a report may constitute cause to reopen this permit to add additional testing and/or control requirements. 1. Spray Booths Operation Monitoring a. At least once daily, the Permittee shall visually inspect the spray booth filters to determine if they need to be repaired or replaced. Records of these inspections, repairs and replacements shall be maintained. b. At least once daily, the Permittee shall physically check the downdraft in the spray booth zone to determine that monitoring systems for the spray booth are working properly. Records of these inspections shall be maintained. 2. ADR and RTO Operation Monitoring a. On a daily basis, Permittee shall physically inspect all ADR and RTO units to verify the structural integrity of each unit and that the units are in operation. The Permittee shall make a record of such inspection. b. Except for during planned shutdowns, as defined below, should the rolling average combustion chamber temperature in the RTO unit fall below 1450 F(1- hr average) or the ADR desorption temperature fall below 370 o F (1-hr average), Permittee shall take such actions to curtail emissions, and shall investigate and report the cause and curative action taken within 10 days in accordance with the deviation reporting requirements of this permit. c. On an annual basis, all RTOs shall be visually inspected for proper seating of the valves, and for accumulation of resin buildup in the valves. Permittee shall keep records of such inspections. d. On an annual basis, all ADR shall be visually inspected for proper function of the rotor, drive and bearings. Permittee shall keep records of such inspections. 3. ADR and RTO Planned Shutdowns Planned Shutdowns of the ADR and RTO shall not be considered a deviation from the required operating parameters specified in this permit, and shall not require deviation reporting as required under 7.A of this permit provided that the following conditions are met: a. All process emissions normally controlled by the ADR and/or RTO undergoing shutdown are stopped for the duration of the ADR and/or RTO shutdown 17

18 b. Records shall be kept indicating the date and the time the ADR and/or RTO were shutdown, date and time the ADR and/or RTO was restored, and how process emissions were controlled during the shutdown. c. See Section 4.B.5 of this permit for allowable by-pass events. D. NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations Monitoring Provisions [Federally enforceable pursuant to 40 CFR ] Permittee shall install, calibrate, maintain, and operate temperature measurement devices as prescribed below: i. Where thermal incineration is used, a temperature measurement device shall be installed in the firebox (or combustion chamber). ii. iii. Each temperature measurement device shall be installed, calibrated, and maintained according to accepted practice and the manufacturer's specifications. The device shall have an accuracy of the greater of ±5 percent of the temperature being measured expressed in degrees Celsius or ±2.5 C. Each temperature measurement device shall be equipped with a recording device so that a permanent record is produced. E. NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations Reporting and Recordkeeping Provisions [Federally enforceable pursuant to 40 CFR ] 1. Following the initial NSPS Subpart MM performance test, the owner or operator of an affected facility shall identify, record, and submit a written report to Pinal County Air Quality and the Administrator every calendar quarter of each instance in which the volume-weighted average of the total mass of VOC's emitted to the atmosphere per volume of applied coating solids (N) is greater than the limit specified under 40 CFR and 5.M of this permit. If no such instances have occurred during a particular quarter, a report stating this shall be submitted to Pinal County Air Quality and the Administrator semiannually. Where compliance is achieved through the use of a capture system and control device, the volume-weighted average after the control device should be reported. 2. Where compliance with 40 CFR and 5.M of this permit is achieved through the use of incineration, the owner or operator shall continuously record the incinerator combustion temperature during coating operations for thermal incineration. The owner or operator shall submit a written report semi-annually (included with the semi-annual report required by 6.J of this permit) and as defined below. a. For thermal incinerators, every three-hour period shall be reported during which the average temperature measured is more than 28 C less than the average temperature during the most recent control device performance test at which the destruction efficiency was determined as specified under 40 CFR and 6.H of this permit. b. For thermal incinerators, if no such periods occur, the owner or operator shall submit a negative report. 18

19 c. The owner or operator shall notify Pinal County Air Quality and the Administrator 30 days in advance of any test by EPA Method 25. F. NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations Performance Test and Compliance Provision [Federally enforceable; 40 CFR ] Each monthly calculation is a performance test for the purposes of this subpart. 1. The owner or operator of an affected facility shall conduct an initial NSPS Subpart MM performance test as described in 6.H of this permit within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup of such facility and thereafter for each calendar month for each affected facility (prime coat operation, and topcoat operation) according to the procedures in this section. 2. The owner or operator shall use the following procedures for determining the monthly volume weighted average mass of VOC emitted per volume of applied coating solids. 3. The owner or operator shall use the following procedures for each affected facility which uses a capture system and a control device that destroys VOC (e.g., incinerator) to comply with the applicable emission limit specified under 40 CFR and 5.M of this permit. a. Calculate the volume weighted average mass of VOC per volume of applied coating solids (G) during each calendar month for each affected facility as follows. The owner or operator shall determine the composition of the coatings by formulation data supplied by the manufacturer of the coating or from data determined by an analysis of each coating, as received, by EPA Method 24. The Administrator may require the owner or operator who uses formulation data supplied by the manufacturer of the coating to determine data used in the calculation of the VOC content of coatings by EPA Method 24 or an equivalent or alternative method. The owner or operator shall determine from company records on a monthly basis the volume of coating consumed, as received, and the mass of solvent used for thinning purposes. b. Calculate the volume weighted average mass of VOC per volume of applied solids emitted after the control device, by the following equation: N = G[1-FE] i. Determine the fraction of total VOC which is emitted by an affected facility that enters the control device by using the following equation where n is the total number of stacks entering the control device and p is the total number of stacks not connected to the control device: If the owner can justify to the Administrator's satisfaction that another method will give comparable results, the Administrator will approve its use on a case-by-case basis. In subsequent months, the owner or operator shall use the most recently determined capture fraction for the performance test. 19

20 ii. Determine the destruction efficiency of the control device using values of the volumetric flow rate of the gas streams and the VOC content (as carbon) of each of the gas streams in and out of the device by the following equation where n is the total number of stacks entering the control device and m is the total number of stacks leaving the control device: In subsequent months, the owner or operator shall use the most recently determined VOC destruction efficiency for the performance test. iii. If an emission control device controls the emissions from more than one affected facility, the owner or operator shall measure the VOC concentration (Cbi) in the effluent gas entering the control device (in parts per million by volume) and the volumetric flow rate (Qbi) of the effluent gas (in dry standard cubic meters per hour) entering the device through each stack. The destruction or removal efficiency determined using these data shall be applied to each affected facility served by the control device. c. If the volume weighted average mass of VOC per volume of applied solids emitted after the control device (N) calculated on a calendar month basis is less than or equal to the applicable emission limit specified in and 5.M of this permit, the affected facility is in compliance. G. NSPS (Subpart IIII) Internal Combustion Engine (ICE) Operational Compliance Demonstration [Federally enforceable pursuant to 40 CFR f] 1. Permittee may operate the emergency engine for the purpose of maintenance checks and readiness testing, provided the tests are recommended by Federal, State, or local government, the manufacturer, the vendor or the insurance company associated with the engine. Permittee shall not operate the ICE for the purposes of maintenance checks and readiness testing for more than 100 hours per year unless the Permittee maintains records identifying the Federal, State or local standards that require maintenance and testing of emergency internal combustion engines beyond 100 hours per year. Copies of such records shall be provided to the District upon request. a. Non-emergency operation is limited to 50 hours per calendar year. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance, readiness checks, and demand response operation. b. The 50 hours per calendar year for non-emergency operation cannot be used to supply power to another entity without a separate permit issued by the District. H. Performance Testing [Federally Enforceable Provision pursuant to code (2/22/95) and (11/3/93) approved as a SIP element at 65 FR (12/20/00)] 1. Generally Applicable Test Program Requirements 20

21 Unless specified otherwise in defining a particular testing requirement, all required tests shall conform to the following requirements. a. Test Requirement Test shall be required as defined elsewhere in this permit. Tests shall be performed at the maximum practical production rate. b. Test Protocol Required tests shall use standard EPA test methods (40 CFR Part 60). At least 60 days before the test, Permittee shall submit test protocol to PCAQCD for review and approval; Permittee shall provide notice of the performance test at least 30 days prior to running the test. c. Timing of initial and subsequent tests Initial tests shall be conducted within 180 days of the start-up of new or modified equipment. Subsequent tests, if applicable, shall be conducted as defined below d. Test Report A copy of the test report shall be submitted to the District for approval within forty-five days after the test. e. Permittee shall use the results of the most recent performance test to quantify actual emissions. 2. RTO Testing - Destruction Efficiency Verification a. Permittee shall conduct a performance test to verify the VOC destruction efficiency of any RTO within 60 days after achieving maximum production rate at which the RTO unit will be operated, but no later than 180 days after commissioning using the following EPA-approved methods. -EPA Methods 18 and EPA Method 25, 25A, or 25B i. The VOC destruction efficiency performance test shall be repeated annually at each RTO, no later than 12 months after the previous test. b. Permittee shall conduct a performance test to verify the HAP destruction efficiency of the initial RTO within 60 days after achieving maximum production rate at which the initial RTO unit will be operated, but no later than 180 days after commissioning using the following EPA-approved methods. -EPA Method 320 i. The HAP destruction efficiency performance test shall be repeated once every five years, no later than 60 months from the previous test, at each RTO. ii. The Permittee shall propose in the HAP test protocol which species of HAP will be quantified and at a minimum shall include any HAP with an uncontrolled PTE of 0.10 tons per year or more. 21