Department of Environmental Quality

Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number B7248 STAFF REPORT MI-ROP-B7248-2014a

Chrysler Group LLC - Sterling Heights Assembly Plant

SRN: B7248

Located at

38111 Van Dyke, Sterling Heights, Michigan 48312

Permit Number: MI-ROP-B7248-2014a

Staff Report Date: May 19, 2014 Amended Date January 15, 2015

This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).

Page: 1 TABLE OF CONTENTS

Page: 2 Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number B7248 MI-ROP-B7248-2014 MAY 19, 2014 STAFF REPORT

Purpose

Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.

This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.

General Information

Stationary Source Mailing Address: Chrysler Group LLC - Sterling Heights Assembly Plant 38111 Van Dyke Sterling Heights, Michigan 48312 Source Registration Number (SRN): B7248 North American Industry Classification System 336111 (NAICS) Code: Number of Stationary Source Sections: 1 Is Application for a Renewal or Initial Issuance? Renewal Application Number: 201300047 Responsible Official: Tyree Minner Plant Manager 586-978-6422 AQD Contact: Robert Byrnes, Senior Environmental Engineer 517-284-6632 Date Permit Application Received: March 11, 2013 Date Application Was Administratively Complete: March 26, 2013 Is Application Shield In Effect? Yes Date Public Comment Begins: May 19, 2014 Deadline for Public Comment: June 18, 2014

Source Description

The Chrysler Group LLC – Sterling Heights Assembly plant currently operates automobile painting and assembly operations. These operations consist of various emission units. Descriptions of each emission unit are included in the attached Renewable Operating Permit. The following table lists stationary source emission information as reported in Michigan Air Emissions Reporting System for 2012.

Page: 3 TOTAL STATIONARY SOURCE EMISSIONS

Pollutant Tons per Year Carbon Monoxide (CO) 52.7 Lead (Pb) 0.00

Nitrogen Oxides (NOx) 62.55 Particulate Matter (PM) 7.9

Sulfur Dioxide (SO2) 0.38 Volatile Organic Compounds (VOCs) 456.8 Total Hazardous Air Pollutants (HAPs) Not Calculated **As listed pursuant to Section 112(b) of the federal Clean Air Act.

In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of CO2e is 115,108. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).

See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.

Regulatory Analysis

The following is a general description and history of the source. Any determinations of regulatory non- applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP.

The stationary source is located in Macomb County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.

The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the potential to emit volatile organic compounds exceeds 100 tons per year; the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is equal to or more than 10 tons per year and the potential to emit of all HAPs combined is more than 25 tons per year. Also, the potential to emit of Greenhouse Gases is 100,000 tons per year or more calculated as carbon dioxide equivalents (CO2e) and 100 tons per year or more on a mass basis.

The stationary source was subject to review under the Prevention of Significant Deterioration regulations of Part 18, because at the time of New Source Review permitting the potential to emit of volatile organic compounds was greater than 250 tons per year.

At this time, there are no GHG applicable requirements to include in the ROP. The mandatory Greenhouse Gas Reporting Rule under 40 CFR 98 is not an ROP applicable requirement and is not included in the ROP.

EU-ECOAT, EU-FLASHPRIMER, EU-TOPCOAT1, EU-TOPCOAT2 and EU-TOPCOAT3 at the stationary source are subject to the New Source Performance Standards for Automobile and Light Duty Truck Surface Coating operations promulgated in 40 CFR, Part 60, Subparts A and MM.

EU-ENG-DATACTR at the stationary source are subject to the New Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines promulgated in 40 CFR, Part 60, Subparts A and IIII.

Page: 4 EU-ENG-NEWPSHOP1, EU-ENG-NEWPSHOP2 and EU-ENG-NEWBSHOP at the stationary source are subject to the New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines promulgated in 40 CFR, Part 60, Subparts A and JJJJ.

EU-HWG 1, EU-HWG 2, EU-HWG 3 and EU-Boiler 1 at the stationary source are subject to the New Source Performance Standards for Small Industrial-Commercial-Steam promulgated in 40 CFR, Part 60, Subparts A and Dc.

EU-AST13 at the stationary source is subject to the Maximum Achievable Control Technology Standards for Organic Liquids Distribution operations promulgated in 40 CFR, Part 63, Subparts A and EEEE.

FG- Auto MACT at the stationary source are subject to the Maximum Achievable Control Technology Standards for Surface Coating of Automobiles and Light Duty Trucks promulgated in 40 CFR, Part 63, Subparts A and IIII.

EU-ENG-PH1, EU-ENG-PH2, EU-ENG-DATACTR, EU-ENG-PAINTSHOP and EU-ENG-NEWPSHOP2 at the stationary source is subject to the Maximum Achievable Control Technology Standards for Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR, Part 63, Subparts A and ZZZZ.

FG-Boiler MACT at the stationary source is subject to the Maximum Achievable Control Technology Standards for Industrial, Commercial, and Institutional Boilers and Process Heaters promulgated in 40 CFR, Part 63, Subparts A and DDDDD.

The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals."

EU-ECOAT, EU-TOPCOAT1, EU-TOPCOAT2 and EU-TOPCOAT3 at the stationary source is subject to the federal Compliance Assurance Monitoring (CAM) rule under 40 CFR, Part 64. These emission units have a control device and potential pre-control emissions of Volatile Organic Compounds greater than the major source threshold level. The monitoring for the control device(s) is continuous temperature monitoring, bypass monitoring, and inspections and maintenance of the control devices at a minimum of every 18 months.

Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions.

Source-wide Permit to Install (PTI)

Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.

The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-B7248-2008a are identified in Appendix 6 of the ROP.

PTI Number 82-06 227-10B

Page: 5 Streamlined/Subsumed Requirements

This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and 213(6).

Non-applicable Requirements

Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule 213(6)(a)(ii).

Processes in Application Not Identified in Draft ROP

The following table lists processes that were included in the ROP application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.

Exempt Description of Rule 212(4) Rule 201 Emission Unit ID Exempt Emission Unit Exemption Exemption EU-NATGAS Miscellaneous natural gas heaters R282(b)(i) R212(4)(b) exempt from PTI requirements

Draft ROP Terms/Conditions Not Agreed to by Applicant

This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree upon pursuant to Rule 214(2).

Compliance Status

The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP.

Action taken by the DEQ

The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit. In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the draft permit and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is Christopher Ethridge, Southeast Michigan District Supervisor. The final determination for ROP approval/disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.

Page: 6 Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number

B7248 SEPTEMBER 9, 2014 STAFF REPORT MI-ROP-B7248-2014 ADDENDUM

Purpose

A Staff Report dated May 19, 2014, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments.

General Information

Responsible Official: Tyree Minner, Plant Manager 586-978-6642 AQD Contact: Robert Byrnes, Senior Environmental Engineer 517-284-6632

Summary of Pertinent Comments

Chrysler Comment: EU-WWash&Gasfil was removed, but should be included as it is an emission unit contained in the permit.

AQD Response: EU-WWash&Gasfil was added to the emission unit summary table.

Chrysler Comment: EU-Final Repair description should be modified to better reflect the fact that the repairs occur in areas more accurately described as stalls rather than booths. The proposed change is denoted and marked as follows:

Topcoat low bake repair process consisting of spray booths stalls equipped with dry filters.

AQD Response: No changes made, the descriptions are not enforceable as a practical matter. However, the AQD does recognize this process as being required to exhaust unobstructed vertically to the ambient air from stacks.

Chrysler Comment: EU-LASHPRIMER should read EU-FLASHPRIMER (typo)

AQD Response: The typo was corrected.

Page: 7 Chrysler Comment: EU description changes were proposed in the Working Draft ROP and are requested again herein for the EU-Body Shop, as the description is not entirely accurate and could cause confusion. The body shop includes emissions that may be exhausted through stacks, particularly natural gas combustion sources which are generally routed to the ambient air. The proposed change is denoted and marked as follows:

Requested Change: New bBody shop including natural gas-combustion (i.e. air make-up units, heaters, etc.) for space or process heating, tooling and equipment to assemble and hem vehicle panels including resistance spot welding, adhesive/sealer application, grinding and other related operations. Emissions are released, uncontrolled, to the general in-plant environment.

AQD Response: The deletion of “New” was made. Deletion of “Emissions are released, uncontrolled, to the general plant environment” was not made because these requirements came from a Permit To Install (PTI). Chrysler may pursue a revised PTI to make the necessary corrections.

Chrysler Comment: EU-Final Repair – The final repair section of the facility, where final assembly occurs and minor topcoat repairs are made, does not have any stacks that emit to the ambient air. The stacks listed in the permit for this emission unit should be removed. You will recall that this fact was verified during your recent site visit of April 9, 2014, whereby it was noted that the original processes that were associated with the listed stacks no longer exist. The final repair stalls do not exhaust to stacks but have recirculating air handling units above the stalls. The stacks and associated characteristics are proposed for removal (see mark-up).

AQD Response: The AQD did acknowledge the deviation during our recent site visit. Changes of this nature require a PTI and cannot be made during a ROP renewal. These requirements were part of a past air toxics, National Ambient Air Quality Standard or Prevention of Significant Deterioration increment demonstration required to obtain a PTI.

Chrysler Comment: EU-Dinaclean – At the request of the MDEQ, Chrysler proposed, in the Working Draft version of the ROP, language that offered a quarterly time frame for the routine checks to ensure operation of the afterburner and cyclone. It should be noted that the current and historic ROPs and PTIs did not specify a definitive time frame for these routine checks.

In the May 19, 2014 version of the draft ROP, the MDEQ modified the language to require daily verification of the cyclone fan and afterburner temperature. Chrysler believes this change in frequency to daily is unnecessarily burdensome and has no regulatory basis. The fluidized bed unit is a non- production unit operated sporadically, and has no applicable emission or material limits. Monitoring and recordkeeping requirements are required to demonstrate compliance with emission limitations. Therefore, Chrysler requests the original proposed language be reconsidered, as it supports the requirement to ensure the afterburner and cyclone are operating properly. The proposed change is denoted and marked as follows:

Requested Change: Section VI.1. MONITORING/RECORDKEEPING 1. The permittee shall implement and maintain a routine quarterly check and keep records of the routine checks (when in operation) to ensure the proper operation of the afterburner and cyclone control systems for any quarter in which EU-Dinaclean operates. For any calendar quarter in which EU- Dinaclean does not operate, a quarterly check is not required. The routine checks verifying proper

Page: 8 operation of the afterburner and cyclone control systems will include at a minimum the following: 2 (R 336.1213(3), R 336.1910)

a. Date and length of time the unit was operated. b. Daily verification that the fan is on to the cyclone prior to operation. c. Daily verification the afterburner is up to temperature prior to operation. d. Quarterly records of all maintenance checks and repairs made to EU-Dinaclean, e. Records of the operating temperature of the afterburner.

AQD Response: The AQD is requiring daily records to ensure proper operation of the afterburner and cyclone due to past concerns regarding proper operation and the records that were kept. The regulatory basis for these changes to the monitoring and recordkeeping are done under the Rule 336.1213(3) and Rule 336.1910 to assure the afterburner and cyclone control systems are installed and operating properly.

Chrysler Comment: EU-Deadner – Chrysler requests that the language in the existing ROP relative to an alternative test method for establishing the VOC content of the deadener be carried through and reflected in the latest draft (see 2008a version, EU-Foamdeadener, V.1.). As discussed with the DEQ during the recent PTI activities, the alternative test method provides representative emissions of the toxics/VOCs of the deadener as applied. The proposed change is denoted and marked as follows:

Requested Change: Section V. TESTING/SAMPLING

1. The VOC emissions from EU-Deadner shall be based on testing using USEPA Test method Alt- 017/TO-17 or an alternative method approved by the AQD. content, water content and density of any deadener material as applied and as received, shall be determined using federal Reference Test Method 24 or an alternative approved by the AQD District Supervisor. Alternatively, the VOC content may be determined from manufacturer’s formulation data. If the tested and the formulation values should differ, the tested results shall be used to determine compliance. Upon request of the AQD District Supervisor, the VOC content, water content and density of any material shall be verified using federal Reference Test Method 24.2 (R 336.1702(a), R 336.2003, R 336.2004)

AQD Response: The AQD has reviewed the method as listed on EPA’s website and does not have sufficient information at this time to approve this method as an acceptable alternative. The response from EPA also states because of the wide range of facilities and pollutants of concern, the affected facility must demonstrate to the regulatory authority the appropriateness of this test. This request and supporting justification can be submitted to the AQD District Supervisor.

Chrysler Comment: EU-BodyShop – As the MDEQ is aware, the new body shop (“Body Shop”) was completed in August 2013, and the old body shop was subsequently decommissioned. As is typical for a body shop and as presented in the PTI application, the Body Shop contains units that discharge to the in-plant environment and to the ambient air. The body shop contains natural gas combustion units that, by design, discharge to the ambient air. Therefore, it would not be logical or reasonable for the permit to contain a condition that requires all sources in the body shop to discharge to the in-plant environment. Its inclusion, we believe, was an error at the time of PTI issuance, and respectfully request it be corrected. We ask the emission unit Body Shop description be modified as noted above, and the Stack/Vent Restrictions be removed, as follows:

Page: 9 Requested Change: Section VIII.1. STACK/VENT RESTRICTION(S) 1. The exhaust gases from EU-Body Shop shall not be discharged to the ambient air at any time. (R 336.1205, R 336.1224, R 336.1225, R 336.1702, R 336.2803, R 336.2804, 40 CFR 52.21(c) & (d))

For clarification purposes, we also request the removal of condition VII Reporting, #4, relating to the initial start-up of the Body Shop, as the condition makes reference to the Permit to Install and is no longer relevant (see mark-up).

AQD Response: The deletion of “The exhaust gases from EU Body Shop shall not be discharged to the ambient air at any time.” was not made because these requirements came from a Permit To Install (PTI). Chrysler may pursue a revised PTI to make the necessary corrections. Also, the AQD recognizes the correspondence dated August 29, 2013 stating the initial startup of the body shop was on or around August 1, 2013. Therefore special condition VII.4 has been removed.

Chrysler Comment: FG-Facility – For purposes of clarification, we request the removal of conditions VII Reporting, #6 and #7, regarding the shut-down of the “old” paint shop and initial start-up of the “new” paint shop, as these conditions are no longer relevant (see mark-up).

AQD Response: The AQD has received the notification required by special conditions VII.6 & 7. Therefore this condition has been removed.

Chrysler Comment: FG-Boilers – Chrysler has reviewed the applicability of New Source Performance Standards (NSPS) to EU-Boiler 1, EU-Boiler 2, and EU-Boiler 3 (“Existing boilers”) and determined that these emission units are not subject to the NSPS standards Subparts Db and Dc, as is incorrectly noted in the current draft ROP. A review of the March 29, 2011 MDEQ/AQD Full Compliance Evaluation Summary Report indicates that the Existing boilers are not subject to NSPS. This conclusion is based on an evaluation that was conducted at the time of issuance of the subject units’ 1995 PTI. In addition, the current ROP does not indicate that the Existing boilers are subject to NSPS. The Existing boilers have not been modified or reconstructed, and therefore would continue to not be subject to the NSPS.

Chrysler believes that the conditions making the Existing boilers subject to NSPS were first introduced in error in the 2011 PTI for the new paint shop. The conditions of this PTI have been incorporated into the draft ROP, and therefore include the incorrect NSPS reference. We request that the corresponding conditions be struck from the permit, as follows:

Requested Change: Section III. PROCESS/OPERATIONAL RESTRICTION(S) 4. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary Sources as specified in 40 CFR Part 60 Subparts A and Dc, as they apply to EU – Boiler No. 1 portion of FG - Boilers.2 (40 CFR Part 60 Subparts A & Dc)

6. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary Sources as specified in 40 CFR Part 60 Subparts A and Db, as they apply to EU – Boiler No. 2 and EU – Boiler no. 3 portions of FG - Boilers.2 (40 CFR Part 60 Subparts A & Db)

Page: 10 AQD Response: Special Conditions III.6 has been deleted. The evalform for PTI 329-95 issued on September 6, 1995 states that based upon EPA guidance for a similar conversion from coal to natural gas at GM, this was not considered a modification. The check boxes for NSPS were also listed as “N” for no. Therefore the change in 1995 for Boilers 2 & 3 was not considered a modification at that time.

Special Condition III.4 remains is it was from a previous PTI 261-84b which had conditions making Boiler 1 subject to NSPS Dc.

Chrysler Comment: Section VI. MONITORING/RECORDKEEPING 1. The permittee shall keep, in a satisfactory manner, monthly records of natural gas usage, in cubic feet, for the boilers and HWGs included in each boiler portion of FG – Boilers. All records shall be kept on file for a period of at least five years and made available to the Department upon request. (40 CFR 60.49b(d)(2), R 336.1201 (3), 40 CFR 60.48c(g)(2))

AQD Response: The Underlying Applicable Requirement (UAR) for 40 CFR 60.49b(d)(2) has been removed. However Boiler 1 and the HWGs are all required to have monthly usage records for each boiler per NSPS Dc. If flow meters for natural gas are not available for each boiler, the company may use hours of operation, or other process parameters to prorate the usage to each boiler on a monthly basis. Boilers 2 &3 are also included in the monthly recordkeeping requirement under Rule 213(3) to avoid any confusion as to how the total natural gas usage is prorated amongst all the boilers.

Chrysler Comment: FG-AutoMACT – Language was included to clarify: SHAP’s compliance obligations when controls are needed for compliance with MACT limitations; which conditions are not relevant when controls are not needed for compliance; and to ensure no available compliance options as identified in the rule are excluded by virtue of permit language. The language changes are included in the mark-up copy of the draft ROP.

AQD Response: No changes were made as this is our standard Auto MACT template.

Chrysler Comment: FG-BOILERMACT – Language was added to the description to note that the HWGs have continuous oxygen trim systems (see mark-up).

AQD Response: The AQD has added the language that the HWGs have continuous oxygen trim systems. The AQD has also changed special condition III.1 to correctly reflect that the new boilers/process heaters shall conduct the initial tune-up within 61 months of July 31, 2013 and a 5 year tune up (no more than 61 months after the previous tune-up) as specified in paragraphs (a)(10)(i) through (vi) and required by 40 CFR 63.7540(a)(12). Special Condition III.2 was changed to say “No later than January 31, 2016….) for the existing boiler units.

The AQD has also changed special condition III.3 to correctly reflect that “existing units” shall conduct a one-time energy assessment as required under Table 3 of subpart DDDDD.

Chrysler Comment: FG-MACT ZZZZ – New Emergency CI>500 HP

Page: 11 Section III. PROESS/OPERATIONAL RESTRICTION(S), #1 In accordance with 40 CFR 63.6625(e), the noted requirements are not applicable to new emergency engines, and is applicable only to existing units less than 500 HP. As EU-ENG-DATACTR is a new engine, we are proposing that it be removed from the permit (as noted in the mark-up).

Section VI. MONITORING/RECORDING In addition, while not required of the RICE MACT standard, we propose to add a recordkeeping condition to this flexible group that requires the tracking of hours of operation for the subject emergency engine. While similar recordkeeping requirements are noted in other flexible groups for EU-ENG-DATACTR, the condition is proposed for purposes of clarification and completeness:

Requested Change: Section VI. MONITORING/RECORDKEEPING 1. For each engine, the permittee shall keep records of hours of operation. The permittee shall document how many hours were spent during emergency operation and how many hours were spent during non-emergency operation. If the engines were used for demand response operation, the permittee shall keep records of the notification of the emergency situation and the time the engine was operated as part of demand response. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3))

AQD Response: The AQD agrees that the requirements in 40 CFR 63.6625(e) are not applicable to new sources and the language has been deleted. The AQD also appreciates the comment to require a record of the hours of operation under Rule 213(3) to be assured the hours restrictions for non-emergency use are met.

Chrysler Comment: FG-MACT ZZZZ – Existing Emergency CI>500 HP

Section III. PROESS/OPERATIONAL RESTRICTION(S), #1 In accordance with 40 CFR 63.6625(e), the noted requirements are applicable only to existing units less than 500 HP. As EU-ENG-PAINTSHOP is greater than 500 HP, we are proposing that it be removed from the permit (as noted in the mark-up).

Section VI. MONITORING/RECORDKEEPING In addition, while not required of the RICE MACT standard, we propose to add a recordkeeping condition to this flexible group that requires the tracking of hours of operation for the subject emergency engine. While similar recordkeeping requirements are noted in other flexible groups for EU-ENG-PAINTSHOP, the condition is proposed for purposes of clarification and completeness:

Requested Change: Section VI. MONITORING/RECORDKEEPING 1. For each engine, the permittee shall keep records of hours of operation. The permittee shall document how many hours were spent during emergency operation and how many hours were spent during non-emergency operation. If the engines were used for demand response operation, the permittee shall keep records of the notification of the emergency situation and the time the engine was operated as part of demand response. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3))

AQD Response: The AQD agrees that the requirements in 40 CFR 63.6625(e) are not applicable to new sources and the language has been deleted. The AQD also appreciates the comment to require a record of the hours of operation under Rule 213(3) to be assured the hours restrictions for non-emergency use are met.

Page: 12 Chrysler Comment: FG-NSPS IIII Emergency pre-2007 <10l/cyl

Section IV. DESIGN/EQUIPMENT PARAMETERS, #1 In accordance with the NSPS, 40 CFR 60.4209(a), non-resettable hour meters are required on the engines if they do not meet standards applicable to non-emergency engines. In accordance with the engine certifications provided by the manufacturer, the emissions from EU-DATACTR meet the emissions standards for emergency and non-emergency engines (the emission standards are identical). Therefore, language was added accordingly to reflect that option.

Requested Change: Section IV. DESIGN/EQUIPMENT PARAMETERS 1. The permittee shall equip and maintain EU-ENG-DATACTR with a non-resettable hour meter to track the operating hours if the engine does not meet the standards applicable to non-emergency engines. (40 CFR 60.4209(a))

Section VI. MONITORING/RECORDKEEPING, #3 Similarly, 40 CFR 60.4214(b) does not require recordkeeping for EU-DATACTR as it meets standards applicable to non-emergency engines and is not of the model years reflected in Table 5 of the standard (MY 2011-2012). Therefore, the regulatory basis for the recordkeeping requirement does not appear to be accurate, and MI rule 336.1213 is proposed instead (see mark-up).

Section VI. MONITORING/RECORDKEEPING, #5 We are proposing removal of condition #5, as there is not a regulatory basis for monitoring and tracking the fuel usage rate for the emergency engine. The manufacturer has provided emission certification data, and therefore the amount of fuel used and at what rate is not necessary or required for demonstrating compliance with the emission limitations (see mark-up).

AQD Response: The AQD has maintained the requirement to have an hour meter but used the UAR as R336.1213(3). The UAR in special condition VI.2 has been changed and special condition VI.5 has been deleted as requested.

Chrysler Comment: FG-NSPS JJJJ Emergency >100 but <500

The word “South” in the equipment names in Section I and III,3 are proposed for deletion (see mark-up).

Section III. PROCESS/OPERATIONAL RESTRICTION(S), #1 In accordance with the NSPS, the engines are restricted to 100 hours per year on a calendar basis, not on a 12-month rolling time basis. Modification of the permit condition was proposed accordingly (see mark-up).

Section III. PROCESS/OPERATIONAL RESTRICTION(S), #3(c) In accordance with the NSPS, not all engines will be subject to 40 CFR 1068 (which Chrysler engines are not) so the words “as applicable” are proposed for inclusion (see mark-up).

Section IV. DESIGN/EQUIPMENT PARAMETERS, #1 In accordance with the NSPS, 40 CFR 60.4237(b), non-resettable hour meters are required on the engines if they do not meet standards applicable to non-emergency engines. In accordance with the engine certifications provided by the manufacturer, the emissions from EU-ENG-NEW PSHOP1 and EU- ENG-NEW BSHOP meet the emissions standards for emergency and non-emergency engines (the emission standards are identical). Therefore, language was added accordingly to reflect that option.

Page: 13 Requested Change: Section IV. DESIGN/EQUIPMENT PARAMETERS 1. EU-ENG-NEW PSHOP1 and EU-ENG-NEW BSHOP shall be equipped with a non-resettable hour meter to track the operating hours if the engine does not meet the standards applicable to non- emergency engines. (40 CFR 60.4237(b))

AQD Response: The descriptive words “south” were deleted and the hours restrictions were changed to 100 hours per calendar year. The reference to 40 CFR 1068 was removed. Records of hours of operation are being required under Rule 213(3).

Chrysler Comment: FG-NSPS JJJJ Emergency >500 HP

Section III. PROCESS/OPERATIONAL RESTRICTION(S), #1 In accordance with the NSPS, the engine is restricted to 100 hours per year on a calendar basis, not on a 12-month rolling time basis. Modification of the permit condition was proposed accordingly (see mark- up).

Section III. PROCESS/OPERATIONAL RESTRICTION(S), #3(c) In accordance with the NSPS, not all engines will be subject to 40 CFR 1068 (which Chrysler engines are not) so the words “as applicable” are proposed for inclusion (see mark-up).

Section IV. DESIGN/EQUIPMENT PARAMETERS, #1 In accordance with the NSPS, 40 CFR 60.4237(b), non-resettable hour meters are required on the engines if they do not meet standards applicable to non-emergency engines. The engine was tested and confirmed compliance with the emission standards for emergency and non-emergency engines (the emission standards are identical). Therefore, language was added accordingly to reflect that option.

Requested Change: Section IV. DESIGN/EQUIPMENT PARAMETERS 1. EU-ENG-NEW PSHOP2 shall be equipped with a non-resettable hour meter to track the operating hours if the engine does not meet the standards applicable to non-emergency engines. (40 CFR 60.4237(b))

AQD Response: The hours restrictions were changed to 100 hours per calendar year. The descriptive words “south” were deleted and the hours restrictions were changed to 100 hours per calendar year. The reference to 40 CFR 1068 was removed. Records of hours of operation are being required under Rule 213(3).

AQD Comment/Response: The AQD has also made corrections to the staff report. EU-Boiler 2 and EU-Boiler 3 are not subject to NSPS Db and the reference in regulatory analysis has been removed. These emission units have been added to section E of the ROP in the “non-applicable requirements” table. These emission units were converted from coal to natural gas fire under PTI 329-95. The evaluation form for PTI 329-95 states the emission units were not modified as there was no increase in emissions from the conversion. The PTI also relied upon an April 6, 1993 EPA letter which states if there are no increases in production rates, utilization and hours of operation, emission reductions are achieved. The evaluation form also checked the NSPS box as false. As such these units were installed prior to the NSPS applicability date and since they have not been modified since, they are still not subject as a new source.

B7248 NOVEMBER 18, 2014 STAFF REPORT ADDENDUM MI-ROP-B7248-2014

Purpose

A Staff Report dated May 19, 2014, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 45-day EPA comment period as described in R336.1214(6). In addition, this addendum describes any changes to the proposed ROP resulting from these pertinent comments.

General Information

Responsible Official: Tyree Minner, Plant Manager 586-978-6642 AQD Contact: Robert Byrnes, Senior Environmental Engineer 517-284-6632

Summary of Pertinent Comments

No pertinent comments were received during the 45-day EPA comment period.

B7248 JANUARY 15, 2015 STAFF REPORT FOR RULE MI-ROP-B7248-2014a 216(2) MINOR MODIFICATION

Purpose

On November 18, 2014, the Department of Environmental Quality, Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-B7248-2014 to Chrysler Group LLC pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(2).

General Information

Responsible Official: Craig J. Colby, Plant Manager 586-978-6642 AQD Contact: Robert Byrnes, Senior Environmental Engineer 517-284-6632 Application Number: 201400165 Date Application For Minor Modification October 22, 2014 Was Submitted:

Regulatory Analysis

The AQD has determined that the change requested by the stationary source meets the qualifications for a Minor Modification pursuant to R 336.1216(2).

Description of Changes to the ROP

Modification of the conditions for EU-Final Repair to be operated as exempt under Rule 287(c) and to incorporate the modification of the conditions for EU-Body Shop covered by PTI 227-10C. This modification will also change the company name from Chrysler Group LLC to FCA US LLC.

Compliance Status

The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the emission unit(s) involved with the change as of the date of approval of the Minor Modification to the ROP.

Action Taken by the DEQ

The AQD proposes to approve a Minor Modification to ROP No. MI-ROP-B7248-2014, as requested by the stationary source. A final decision on the Minor Modification to the ROP will not be made until any affected states and the U.S. Environmental Protection Agency (USEPA) has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District Supervisor. The final determination for approval of the Minor Modification will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other requirements, and resolution of any objections by any affected states or the USEPA.

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