mercedes-benz u.s. international, inc.management (adem) during which each plant was issued a...

Mercedes-Benz U.S. International, Inc.

Plantwide Applicability Limit Permit Renewal Application

Vance, Alabama – Tuscaloosa County

February 2018

Submitted by Mercedes-Benz U.S. International, Inc.

Vance, Alabama – Facility No. 413-0034

TABLE OF CONTENTS

i MBUSI PAL Renewal Application February 2018

1. INTRODUCTION................................................................................................................ 1-1

1.1 FACILITY DESCRIPTION ......................................................................................... 1-1

1.2 PAL RENEWAL APPLICATION REQUIREMENTS ............................................... 1-2

2. EMISSIONS UNITS ............................................................................................................ 2-1

2.1 VOC PTE ...................................................................................................................... 2-1

2.2 DESIGNATION OF EMISSIONS UNITS .................................................................. 2-2

2.3 LIST OF APPLICABLE FEDERAL AND STATE REGULATORY

REQUIREMENTS........................................................................................................ 2-3

2.4 LIST OF APPLICABLE EMISSIONS LIMITATIONS ............................................ 2-10

2.5 LIST OF APPLICABLE WORK PRACTICES PLANS ........................................... 2-13

3. BASELINE ACTUAL VOC EMISSIONS CALCULATION ......................................... 3-1

4. PROPOSED PAL LEVEL .................................................................................................. 4-1

5. MONITORING, RECORDKEEPING AND NOTIFICATION REQUIREMENTS ... 5-1

LIST OF TABLES

ii MBUSI PAL Renewal Application February 2018

Table 2-1 MBUSI Facility-wide VOC PTE................................................................................. 2-2

Table 2-2 PTE and Designation of Emissions Units at MBUSI .................................................. 2-3

Table 2-3 Federal Requirements Applicable to MBUSI.............................................................. 2-4

Table 2-4 State Requirements Applicable to MBUSI.................................................................. 2-6

Table 4-1 Comparison of MBUSI VOC PTE and Permit Limits ................................................ 4-2

LIST OF APPENDICES

iii MBUSI PAL Renewal Application February 2018

Appendix A - VOC PTE Calculations

Appendix B - Baseline Actual VOC Emissions


Plantwide Applicability Limit Renewal Application

1-1 MBUSI PAL Renewal Application February 2018

1. INTRODUCTION

Mercedes-Benz U.S. International, Inc. (MBUSI) manufactures motor vehicles in a state-of-the-

art motor vehicle assembly facility (Facility) located in Vance, Alabama in Tuscaloosa County.

MBUSI is requesting a renewal of its current Plantwide Applicability Limit (PAL) for volatile

organic compound (VOC) emissions for this Facility.

1.1 FACILITY DESCRIPTION

The Facility was once comprised of two main production plants – Plant 1 (built between 1995 and

1997) and Plant 2 (built between 2002 and 2004). Both plants were taken through Prevention of

Significant Deterioration (PSD) permitting with the Alabama Department of Environmental

Management (ADEM) during which each plant was issued a plantwide limit for VOC – 488.0 tons

per year (tpy) for Plant 1 and 640.0 tpy for Plant 2. On August 11, 2008, ADEM issued a PAL

permit for VOC. The PAL level of 859.55 tpy of VOC was established for both Plant 1 and Plant

2 combined. In 2009, MBUSI ceased operation of the Plant 1 paintshop. In October 2011, MBUSI

received an ADEM air permit approving modifications to the Facility including an expansion of

the remaining paintshop to reestablish some of the lost capacity when the Plant 1 paintshop was

shutdown, as well as other modifications needed to accommodate production of the Mercedes-

Benz C-class vehicle.

The current Title V Operating Permit (TVOP) still retains the VOC limit of 640.0 tpy, which

applies to what was once referred to as “Plant 2,” and which was set prior to the PAL permit

issuance in August 2008. MBUSI believes the 640.0 tpy limit should have been removed when

the PAL was set since the PAL was set Facility-wide, inclusive of all VOC sources regardless of

whether the sources were at Plant 1 or Plant 2. In this application, MBUSI is requesting that the

PAL for VOC be retained at its current level, based on an assessment of the potential to emit (PTE)

of the current operations. MBUSI is also requesting that this subordinate limit of 640.0 tpy be

removed at the time of the PAL renewal.




1.2 PAL RENEWAL APPLICATION REQUIREMENTS

MBUSI is requesting a renewal of the PAL for VOC emissions for its Facility. ADEM Rule 335-

3-14-.04(23)(j)(3) lists the information that is required to be included in a PAL renewal

application. This includes:

1. A list of all emissions units at the source designated as small, significant, or major

based on their PTE. In addition, the owner or operator of the source shall indicate

which, if any, Federal or State applicable requirements, emissions limitations, or work

practices apply to each unit.

2. Calculations of the baseline actual emissions (with supporting documentation).

Baseline actual emissions are to include emissions associated not only with operation

of the units, but also emissions associated with startup and shutdown.

3. The sum of the PTE of all emissions units under the PAL (with supporting

documentation).

4. A proposed PAL level.

5. The calculation procedures that the major stationary source owner or operator proposes

to use to convert the monitoring system data to monthly emissions and annual

emissions based on a 12-month rolling total for each month as required by

subparagraph ADEM Rule 335-3-14-.04(23)(m)1.

These items are covered in the following Sections.

Mercedes-Benz U.S. International



2. EMISSIONS UNITS

2.1 VOC PTE

ADEM’s PAL rule requires applicants to provide the PTE for the Facility by emissions unit. The

PTE is meant to reflect the maximum capacity to emit a pollutant based upon its physical and

operational design, taking into account any enforceable limits. The Facility currently operates

under a VOC PAL of 859.55 tpy, which is an enforceable limit that establishes the VOC PTE for

the Facility. However, for the purposes of this application and the evaluation of the appropriate

PAL level for renewal, MBUSI calculated the current Facility-wide VOC PTE assuming that the

current VOC PAL level is not in effect.

In the original PAL application, MBUSI organized the Facility into 10 different emissions units

according to the type of activity carried out by those emissions units. This approach is consistent

with past PSD and TVOP applications that have been submitted to ADEM over the years. For

continuity, we have used the same groups in this application.

Table 2-1 lists the 10 emissions units at the Facility and the VOC PTE for each emissions unit.

MBUSI has determined that the Facility-wide VOC PTE, excluding the current PAL, is 860.44

tpy. In general, the VOC PTE is based on recent actual operating information and material usage

and production rates that were then adjusted to assume maximum possible operation of three

shifts/day, seven days per week and 50 weeks per year. Appendix A provides detailed emissions

calculations of the VOC PTE for each of these emissions units and the assumptions used.




Table 2-1 MBUSI Facility-wide VOC PTE

Emissions Unit VOC PTE (tpy)

Body Shop Negligible

Paintshop 664.56

Touch-Up 40.61

Assembly Shop 1.35

Energy Center Boilers 5.32

Emergency Engines 1.47

Other Natural Gas Combustion 6.11

Tank Farm 3.07

Fueling 0.42

Miscellaneous VOC 137.54

TOTAL 860.44

2.2 DESIGNATION OF EMISSIONS UNITS

ADEM’s PAL rule requires the application to include a designation of whether an emissions unit

is classified as small (less than 40 tpy, the significance threshold for VOC), significant (40 to 100

tpy), or major (100 tpy and greater) based on their PTE. Table 2-2 provides this designation for

the 10 emissions units at MBUSI.




Table 2-2 PTE and Designation of Emissions Units at MBUSI

Emissions Unit Designation

(Small, Significant, Minor)

Body Shop Small

Paintshop Major

Touch-Up Significant

Assembly Shop Small

Energy Center Boilers Small

Emergency Engines Small

Other Natural Gas Combustion Small

Tank Farm Small

Fueling Small

Miscellaneous VOC Major

2.3 LIST OF APPLICABLE FEDERAL AND STATE REGULATORY REQUIREMENTS

As required by ADEM’s PAL rule, MBUSI has included a list of the Federal and State regulatory

requirements applicable to the emissions units denoted in Section 2.1 in Table 2-3 and Table 2-4.




Table 2-3 Federal Requirements Applicable to MBUSI

Statutory/

Regulatory

Requirement

Citation

Description of Requirement Applicability Emissions Units to Which

Requirement is Applicable

40 CFR 60

Subpart A

New Source Performance

Standards (NSPS):

General Provisions

Procedural guidelines for construction and

startup, performance testing schedules and

procedures, and other notification and

recordkeeping requirements apply when a

facility is subject to one or more NSPS.

Paintshop

Touch-Up

Miscellaneous VOC

Energy Center Boilers

40 CFR 60

Subpart Dc

NSPS: Small Industrial-

Commercial-Institutional

Steam Generating Units

Constructed, Modified, or

Reconstructed After June 9,

1989

Daily fuel use recordkeeping requirement

applies to the Energy Center boilers

[maximum heat input rates between 10 -

100 million British thermal units per hour

(MMBtu/hr)].


40 CFR 60

Subpart MM

NSPS: Automobile and Light-

Duty Truck Surface Coating

Operations

VOC standards apply to prime coat,

guidecoat and topcoat automobile coating

operations.

Paintshop

40 CFR 60

Subpart IIII

NSPS: Stationary

Compression Ignition Internal

Combustion Engines

Certain work practice and recordkeeping

requirements apply to the emergency

generators and fire pumps.

Emergency Engines

40 CFR 60

Subpart JJJJ

NSPS: Stationary Spark

Ignition Internal Combustion

Engines




Emergency Engines




Statutory/

Regulatory

Requirement

Citation

Description of Requirement Applicability Emissions Units to Which

Requirement is Applicable

40 CFR 63

Subpart A

National Emission Standard

for Hazardous Air Pollutants

(NESHAP) for Source

Categories: General Provisions

Certain general provisions apply including

requirements for performance tests,

notifications, monitoring, recordkeeping,

and reporting.

Paintshop

Touch-Up

Miscellaneous VOC

40 CFR 63

Subpart IIII

NESHAP: Automotive and

Light-Duty Truck Surface

Coating

The rule applies to MBUSI, including

emission limits, monitoring,

recordkeeping, and reporting requirements,

work practices, and compliance

demonstration requirements.

Paintshop

Touch-Up

Miscellaneous VOC

40 CFR 63

Subpart

ZZZZ

NESHAP: Stationary

Reciprocating Internal

Combustion Engines




Emergency Engines

40 CFR 63

Subpart

DDDDD

NESHAP: Industrial,

Commercial and Institutional

Boilers and Process Heaters

Certain work practices (annual tune-up and

one-time energy assessment),

recordkeeping and notifications apply.


40 CFR 64 Compliance Assurance

Monitoring (CAM)

Applies to the regenerative thermal

oxidizers (RTOs). Paintshop

40 CFR 82

Subpart F

Protection of Stratospheric

Ozone

Recycling and Emissions

Reduction

Applies to appliances using Class I and

Class II refrigerants. Facility




Table 2-4 State Requirements Applicable to MBUSI

Statutory/

Regulatory

Requirement

Citation

Description of Requirement Applicability

Emissions Units to

Which Requirement is

Applicable

Code of Alabama

§22-28-16(d)

Alabama Pollution Control Act

Permits Requirement to have a permit applies. Facility

ADEM Rule

335-1-7

Air Division Operating Permit Fees

Fee Schedule

Requirements to pay fees associated with

air emissions apply. Facility

ADEM Rule

335-3-1-.04

General Provisions: Monitoring,

Records, and Reporting

Requirements to conduct monitoring,

maintain records, submit reports using

methods and procedures as prescribed

apply.

Facility

ADEM Rule

335-3-1-.05

General Provisions: Sampling &

Test Methods

Requirements to use approved sampling

and test methods, and procedures apply. Facility

ADEM Rule

335-3-1.07

General Provisions: Maintenance

and Malfunctioning of Equipment

Requirement to notify ADEM of equipment

shutdowns and malfunctions applies. Facility

ADEM Rule

335-3-1-.08 Prohibition of Air Pollution Prohibition of air pollution applies. Facility

ADEM Rule

335-3-1-.10 Circumvention

Prohibition of installation of a device or

using other means to conceals or dilutes

emissions without reducing the total

amount of air contaminant applies.

Facility

ADEM Rule

335-3-3-.02

Control of Open Burning and

Incineration: Incinerators

Odor minimization requirement applies to

RTOs. Paintshop




Statutory/

Regulatory

Requirement

Citation


Emissions Units to


Applicable

ADEM Rule

335-3-4-.01

Control of Particulate Emissions:

Visible Emissions

Visible emissions of limit of 20% opacity

(and up to 40% for not more than six

minutes in any 60-minute period) applies.

Paintshop


Emergency Engines

Other Natural Gas

Combustion

ADEM Rule

335-3-4-.02


Fugitive Dust and Fugitive

Emissions

Requirement to minimize airborne dust

from roads and material handling applies. Facility

ADEM Rule

335-3-4-.03


Fuel Burning Equipment

Particulate matter emissions limit of 0.5 to

0.2 lb/MMBtu of heat input applies to fuel

burning operations.


Emergency Engines

Other Natural Gas

Combustion

ADEM Rule

335-3-4-.04

Control of Particulate Emissions

Process Industries: General (raw

materials)

Particulate emissions limit based on hourly

process weight of raw materials is met with

more stringent BACT particulate limits.

Body Shop

Paintshop

ADEM Rule

335-3-5-.01

Control of Sulfur Compound

Emissions: Fuel Combustion

Sulfur dioxide emissions limit of 4.0

lb/MMBtu applies to fuel burning

equipment.

Paintshop


Emergency Engines

Other Natural Gas

Combustion




Statutory/

Regulatory

Requirement

Citation


Emissions Units to


Applicable

ADEM Rule

335-3-6-.03

Control of Organic Emissions:

Storage of VOC

Applies to VOCs with a true vapor pressure

greater than or equal to 1.5 psia under

storage conditions. Requirement to use

pressure vessels or to equip tanks with

submerged fill pipes, floating roof, or vapor

recovery system applies to storage tanks

with capacity greater than 1,000 gallons.

Tank Farm

ADEM Rule

335-3-6-.07


Gasoline Dispensing Facilities –

Stage 1

Vapor control and fuel use recordkeeping

requirements apply to MBUSI storage tanks

and filling station.

Tank Farm

ADEM Rule

335-3-6-.11(5)


Surface Coating

(Automobile and Light Duty Truck

Manufacturing)

VOC limits apply to coating operations.

Paintshop

Touch-up

Miscellaneous VOC

ADEM Rule

335-3-6-.12 Solvent Metal Cleaning

Cold cleaner operating practices relating to

freeboard height, container labeling, drip

time, cover closure when not in use apply.

Miscellaneous VOC

ADEM Rule

335-3-6-.20

Leaks from Gasoline Tank Trucks

and Vapor Collection Systems

Requirements for design and operation of

vapor collection system and loading

equipment and for repair and retesting

vapor collection or control systems apply.

Tank Farm

ADEM Rule

335-3-10 NSPS

NSPS requirements in 40 CFR 60

incorporated by reference.

Paintshop

Touch-up


Miscellaneous VOC




Statutory/

Regulatory

Requirement

Citation


Emissions Units to


Applicable

ADEM Rule

335-3-11-.01 NESHAP: General NESHAP incorporated by reference.

Paintshop

Touch-up


Miscellaneous VOC

ADEM Rule

335-3-11-.06(86)

NESHAP: Surface Coating of

Automobiles and Light-Duty

Trucks

NESHAP incorporated by reference.

Paintshop

Touch-up

Miscellaneous VOC

ADEM Rule

335-3-14

Air Permits

Requirement to obtain air permit and

maintain copy on-site applies. Requirement

to provide sampling and testing facilities

applies.

Facility

ADEM Rule

335-3-16

Major Source Operating Permits

Requirement to submit permit application

within 12 months of startup applies;

requirement to file permit onsite will apply

after the permit for which application is

being made is issued; requirement to

maintain sampling and testing facilities

applies.

Facility




2.4 LIST OF APPLICABLE EMISSIONS LIMITATIONS

As required by ADEM’s PAL rule, MBUSI has included a list of the emissions limitations for the

Facility from the current TVOP No. 413-0034 dated April 2, 2017.

Operating Permit Summary No. 02: Storage Tanks with Stage I Recovery

• Stage 1

o Maintain proper Stage I recovery system on two 12,000-gallon gasoline storage

tanks

Operating Permit Summary No. 03: 97.9 MMBtu/hr Natural Gas-Fired Boiler

• Opacity of Boiler Stacks

o 10% opacity limit

• Fuel Usage

o Only natural gas will be used for these units

• Continuous Compliance

o Annual tune-ups will be conducted

Operating Permit Summary No. 010: Motor Vehicle Assembly Plant

• VOC Emissions

o Facility-wide: 640.0 tpy per rolling 12-month period

• NSPS

o Primecoat: E-coat – 1.34 lb VOC/gallon of applied coating solids (gacs)

o Guidecoat: Primer/Surfacer and Sealer/Deadener – 11.68 lb VOC/gacs

o Topcoat: Topcoat and Clearcoat – 12.27 lb VOC/gacs

• NESHAP

o E-Coat, Primer/Surfacer/Topcoat/Final Repair/Glass Bonding Primer and

Adhesive Operations/Adhesives and Sealers Not Used for Glass Bonding Systems

– 0.60 lb HAP/gacs




o Adhesive/Sealers Not Used for Glass Bonding Systems – 0.010 lb HAP/lb of

material used

o Deadener – 0.010 lb HAP/lb of material used

• BACT VOC Limits

o Primecoat: E-coat – 0.20 lb/gacs

o Guidecoat: Primer/Surfacer and Oven – 5.10 lb/gacs

o Topcoat: Topcoat and Clearcoat Booths and Oven – 7.10 lb/gacs

o Sealer/Deadener/Adhesive – 0.40 lb/gal, as applied

o Blackout – 1.00 lb/gal, as applied

o RTO Nos. 3-1, 3-2, 3-3 and 3-4: 95% removal efficiency

• BACT Particulate Matter (PM) Limits (gr/acf)

o Primer/Surfacer Booth Exhausts – 0.0021

o Primer Sanding Exhausts – 0.0015

o Basecoat Booth Exhausts – 0.0011

o Clearcoat Manual Exhaust – 0.0015

o Clearcoat Robot Exhaust – 0.0019

o Final Repair Exhausts – 0.0007

• BACT Nitrogen Oxides (NOx) Limits (lb/MMBtu heat input, except as noted)

o E-Coat Oven – 0.10

o Sealer/Deadener Ovens – 0.10

o Primer/Surfacer Ovens – 0.10

o Topcoat/Clearcoat Ovens – 0 .10

o Primecoat Booth Air Supply Houses – 0.10

o Topcoat Booth Air Supply Houses – 0.10

o Touchup Air Supply Houses – 0.10

o Blackout/Cavity Wax Air Supply Houses – 0.10

o Incinerator RTO 3-1, 3-2 – 3.6 lb/hr

o Incinerator RTO 3-3 – 3.6 lb/hr




• BACT Carbon Monoxide (CO) Limits

o Incinerator RTO 3-1, 3-2 – 5.0 lb/hr

o Incinerator RTO 3-3 – 5.0 lb/hr

• Other VOC Limits

o E-Coat Oven No. 2 Integrated Oxidizer – 90% removal efficiency

o Sealer Oven No. 3 Integrated Oxidizer – 90% removal efficiency

• Fuel Usage

o Only natural gas will be used in combustion equipment other than diesel emergency

engines and gasoline engines

• Tank Filling

o Stage II vapor control system or onboard vapor recovery system required

Operating Permit Summary No. 011: 33.4 MMBtu/hr Natural Gas-Fired Boiler


o 10% opacity limit observation of 5% or greater requires investigation and corrective

action

• NOX Emissions

o 1.35 lb/hr or 0.04 lb/MMBtu

• CO Emissions


• PM/PM10 Emissions


• Fuel Usage

o Only natural gas will be used

Operating Permit Summary No. 012: 98 MMBtu/hr Natural Gas-Fired Boiler


o 10% opacity




• Continuous Compliance

o Annual tune-ups will be conducted

Operating Permit Summary No. 013: Abrasive Blasting Units (3) with Dust Collector

• Opacity

o 10% opacity limit

• PM Emissions

o Unit shall not discharge in excess of E = 3.59(P0.62) where P is the process weight

in tons/hr

Operating Permit Summary No. 020 and 021

• Opacity

o 10% opacity limit

2.5 LIST OF APPLICABLE WORK PRACTICES PLANS

As required by ADEM’s PAL rule, MBUSI is identifying applicable work practice plans. The

Facility has three work practice plans in place that affect the paintshop emissions units. The first

two work practice plans are required by 40 CFR §63.3094(b):

• A work practice plan to minimize organic HAP emissions from the storage, mixing, and

conveying of coatings, thinners, and cleaning materials used in, and waste materials

generated by, all coating operations for which emission limits are established under the 40

CFR 63 Subpart IIII.

• A work practice plan to minimize organic HAP emissions from cleaning and from purging

of equipment associated with all coating operations for which emission limits are

established under the 40 CFR 63 Subpart IIII.

The third work practice plan is required pursuant to 40 CFR §63.3100(f). The Facility is required

to implement the following plan for affected coating operations for which compliance is

demonstrated by taking credit for an emissions reduction associated with any control device:



2-14 MBUSI PAL Renewal Application

February 2018

• A written startup, shutdown, and malfunction plan (SSMP) for each such control device

and any associated emissions capture system according to 40 CFR §63.6(e)(3).




3. BASELINE ACTUAL VOC EMISSIONS CALCULATION

As required by the ADEM PAL rule, MBUSI has provided baseline actual emissions for the

Facility from 2013 through 2017. Typically, a baseline period is a 24-month period from the past

10 years. MBUSI limited its determination of the baseline period to a 24-month period within the

last five years since the Facility went through significant equipment and operating changes prior

to those five years. As noted earlier, MBUSI ceased operation of the original Plant 1 paintshop in

2009, and subsequently went through an expansion to recapture some of the lost production

capacity and to accommodate production of the Mercedes-Benz C-class vehicle. MBUSI believes

that a baseline period selected from 2013 through 2017 is most representative of existing

operations.

Appendix B provides detailed baseline actual emissions that were compiled using monthly VOC

reports and annual emissions reports that MBUSI has submitted to ADEM for calendar years 2013

through 2017. The highest annual VOC emissions averaged over a consecutive 24 months during

2013 through 2017 was 436.60 tpy. That 24-month period was June 2015 through May 2017.




4. PROPOSED PAL LEVEL

ADEM Rule 335-3-14-.04(23)(j)(4) specifies how the PAL level is to be adjusted at the time a

PAL is renewed. In particular, the rule states that ADEM “may set the PAL at a level that he or

she determines to be more representative of the source's baseline actual emissions, or that he or

she determines to be more appropriate considering air quality needs, advances in control

technology, anticipated economic growth in the area, desire to reward or encourage the source's

voluntary emissions reductions, or other factors as specifically identified by the Director in his or

her written rationale.” However, pursuant to ADEM Rule 335-3-14-.04(23)(j)(4)(iii), ADEM is

not permitted to set a PAL level greater than the applicant’s PTE.

MBUSI is proposing that ADEM renew the Facility’s PAL permit while retaining the current VOC

PAL level of 859.55 tpy. As shown in Section 2, MBUSI determined that the VOC PTE for the

Facility is higher than the VOC PAL level, even using the current equipment and while still being

able to demonstrate compliance with applicable BACT and NSPS limits for VOC as shown in

Table 4-1. The original PAL level of 859.55 tpy was set based on production projections of

285,000 vehicles per year (90,000 from Plant 1 and 195,000 from Plant 2). After the paintshop

expansion addressed in the 2011 air permit, MBUSI projected an actual future production rate of

304,000 vehicles per year. MBUSI estimates that the Facility has the capacity to produce up to

371,000 vehicles under a maximum operating schedule of three shifts per day, seven days per week

and 50 weeks a year. MBUSI believes that it is critical to retain the flexibility it has under the

existing PAL permit to be able to respond quickly to changes in market demand and technologies.




Table 4-1 Comparison of MBUSI VOC PTE and Permit Limits

Source VOC Limit

(lb/gacs)

Emissions Based on

VOC PTE1

(lb/gacs)

E-Coat BACT 0.20 0.15

Guidecoat/Primer Surfacer

BACT 5.10 1.30

Topcoat BACT 7.10 5.69

E-Coat NSPS 1.34 0.15

Guidecoat/Primer Surfacer (plus

sealer and deadener) NSPS 11.68 0.24

Topcoat NSPS 12.27 5.69

1 See Table A-2 in Appendix A for supporting calculations.




5. MONITORING, RECORDKEEPING AND NOTIFICATION REQUIREMENTS

ADEM Rule 335-3-14-.04(23)(1) through (23)(n) specifies the minimum monitoring

recordkeeping and notification requirements for a PAL permit. MBUSI proposes to satisfy these

requirements by using the same emissions calculation, monitoring, recordkeeping and notification

requirements in the current PAL permit.

APPENDIX A - VOC PTE CALCULATIONS

Emissions UnitVOC PTE

(tons/yr)

Designation (Small,

Significant, Major)

Body Shop Negligible Small

Paint Shop 664.56 Major

Touch-Up 40.61 Significant

Assembly Shop 1.35 Small

Energy Center Boilers 5.32 Small

Emergency Engines 1.47 Small

Other Natural Gas Combustion 6.11 Small

Tank Farm 3.07 Small

Fueling 0.42 Small

Miscellaneous VOC 137.54 Major

TOTAL 860.44 --

MBUSI Potential to Emit VOC

Facility-wide Emissions and Designation of Emissions Units

Table A-1

MBUSI PAL Renewal Application.xlsx February 2018

Coating

CategoryProduct Name

MSC

NumberUsage1

(gal/vehicle)

Total

Gallons

Used2

VOC3

(lb/gal)

Solids

(% vol)Repair Split

Gallons in

Coating

Line

Gallons for

Repair/

Touch-Up

Transfer

Efficiency4

Booth Split

(Non-

Oven)4

CC Auto

Split

Oven

Capture

Efficiency4

RTO Control

Efficiency5

Coating Line

Gross VOC

(lbs)

Coating Line

Net

Uncontrolled

VOC

(lbs)

Coating Line

Controlled

VOCs

(lbs)

Touch-Up/

Repair VOC

Emissions

(lbs/year)

Touch-Up/

Repair VOC

Emissions

(tons/year)

VOC Emissions

Not Including

Repair/

Touch-Up

(lbs/year)

VOC Emissions

Not Including

Repair/

Touch-Up

(tons/year)

Applied

Solids

(gallons)

lbs VOC/

gal ACS

E-Coat Cathoguard Paste 2409 0.21 77,478 0.01 48.92% 0% 77,478 0.00 100.0% 20.0% 0.0% 80.0% 95% 774.78 154.96 30.99 0.00 0.00 185.95 0.09 37,902

E-Coat Cathoguard Resin 2407 1.63 605,508 0.22 35.82% 0% 605,508 0.00 100.0% 20.0% 0.0% 80.0% 95% 130,790 26,158 5,232 0.00 0.00 31,390 15.69 216,893

E-Coat Dowanol PNB 2480 0.01 3,434 7.34 0.00% 0% 3,434 0.00 100.0% 20.0% 0.0% 80.0% 95% 25,204 5,041 1,008 0.00 0.00 6,049 3.02 0.00

0.00 0.00 37,624 18.81 254,795 0.15

Guidecoat Silver Gray Hemmelrath 3298 1.06 393,962 1.10 33.80% 0% 393,962 0.00 85.0% 30.6% 0.0% 69.4% 95% 433,358 132,608 15,038 0.00 0.00 147,645 73.82 113,185

0.00 0.00 147,645 73.82 113,185 1.30

Basecoat Brilliant Blue 3353 1.02 377,808 1.83 20.46% 5% 358,918 18,890 75.9% 98.1% 0.0% 1.9% 95% 656,820 644,340 623.98 34,569 17.28 644,964 322.48 58,670

Clearcoat ProGloss 40A-Comp 3000 0.48 178,166 4.05 44.16% 5% 169,257 8,908 75.9% 69.0% 55.1% 31.0% 95% 685,616 95,301 29,516 36,085 18.04 124,816 62.41 59,717

Clearcoat ProGloss 40B-Comp 3001 0.16 59,668 2.64 64.00% 5% 56,685 2,983 75.9% 69.0% 55.1% 31.0% 95% 149,648 20,801 6,442 7,876 3.94 27,243 13.62 28,984

78,531 39.27 797,024 398.51 147,371 5.41

Sealer One Component Adhesive 2440 2.12 789,168 0.21 95.11% 0% 789,168 0.00 100.0% 30.6% 0.0% 69.4% 95% 165,725 50,712 5,751 0.00 0.00 56,463 28.23 750,596

0.00 0.00 56,463 28.23 750,596 0.08

Touch-up Only Glasurit 352-500 2577 9.65E-04 358.59 7.50 1.00% 100% 0.00 358.59 100.0% 0.0% 0.0% 0.0% 95% 0.00 0.00 0.00 2,689 1.34 0.00 0.00 3.59

2,689 1.34 0.00 0.00 3.59 0.00

81,220 40.61 1,038,756 519.38 -- --1 Usage rates are based on values from the 2016 annual report plus 10%.2 Based on a maximum potential annual production of:

371,543 vehicles/year based on maximum operating hours of 3 shifts/day, 7 days/week, 50 weeks/year3 For guidecoat and basecoat, used VOC content for highest VOC content coating in this category used within the last five years.4 For guidecoat, basecoat, clearcoat and sealer, based on lowest test value in last five years. For e-coat, based on assumption that 80% of emissions is captured within the oven. 5 Based on permit requirement for minimum destruction efficiency.

Table A-2

Sealer Subtotal:

Touch-up Only Coating Subtotal:

TOTAL VOC EMISSIONS:


Paintshop Coating and Repair/Touch-Up

E-Coat Subtotal:

Guidecoat Subtotal:

Topcoat Subtotal:


Material Category Product Name1 MSC Number

Density

(lb/gal)

VOC Content

(lb/gal)

Gross

Potential

Gallons

Used/Year2

Estimated

Recovery

Rate3

Net Gallons

Used/Year

VOC After

Purge

Recovery

(lbs/year)

VOC After

Purge

Recovery

(tons/year)

Purge Waterborne Purge 3156 8.29 0.80 108,900 0% 108,900 87,120 43.56

Purge Solventborne Purge 2996 7.34 7.34 60,654 54% 27,689 203,236 101.62

290,356 145.181 Primary materials used in 2016.2 Gross potential annual usage is based on the peak monthly usage in 2016 plus 10% multiplied by 12 .3 Based on lowest annual recovery rate in last five years (i.e., 2014).


Paintshop Waterborne and Solventborne Purge Solvent


Table A-3


Description Number of Tests1 Miles Per TestVOC Emissions Factor2

(g/mi/test)VOC Emissions (lbs/year) VOC Emissions (tons/year)

Vehicle Test Center 349,974 20 0.14 2,158 1.08

Roll Test 349,974 5 0.14 539.61 0.27

2,698 1.351 The number of tests are based on maximum potential annual production.2 Emissions factors are from Daimler.


Assembly Shop


Table A-4


Emissions UnitBoiler Size

(MMBtu/hr)

Maximum Fuel

Use

(MMBtu/year)

VOC Emissions

Factor1

(lb/MMcf)

VOC Emissions2

(lbs/year)

VOC Emissions2

(tons/year)

Boiler 801A 98.0 858,480 5.50 4,540 2.27

Boiler 802A 98.0 858,480 5.50 4,540 2.27

Boiler 803 33.5 293,460 5.50 1,552 0.78

10,632 5.321 Emissions factors based on AP-42, Table 1.4-2.

2 Emissions are based on the following:

Heating Value of Natural Gas: 1,040 Btu/cf

Hours of Operation Per Year: 8,760 hrs/yr




Table A-5


Generator ID Gen. Size

(kW)

Gen. Size

(hp)

VOC Emissions

Factor1,2

(lb/hp-hr)

VOC Emissions3

(lbs/year)

VOC Emissions3

(tons/year)

GEN-2 45 60 1.59E-03 48.02 0.02

GEN-3 45 60 1.59E-03 48.02 0.02

GEN-4 45 60 1.59E-03 48.02 0.02

GEN-7 45 60 1.59E-03 48.02 0.02

GEN-8 45 60 1.59E-03 48.02 0.02

GEN-9 99 133 1.59E-03 105.74 0.05GEN-10 99 133 1.59E-03 105.74 0.05GEN-11 45 60 1.59E-03 47.70 0.02GEN-12 146 195 1.59E-03 155.03 0.08GEN-13 146 195 1.59E-03 155.03 0.08

GEN-17 (Paint Shop North) 80 122 3.05E-05 1.86 9.30E-04

811.18 0.41

Generator ID Gen. Size

(kW)

Gen. Size

(hp)

VOC Emissions

Factor1

(lb/hp-hr)

VOC Emissions2

(lbs/year)

VOC Emissions2

(tons/year)

GEN-1 (Training Center) 347 465 2.47E-03 574.28 0.29

FP-1 (East) 343 460 2.47E-03 568.10 0.28

FP-2 (West) 343 460 2.47E-03 568.10 0.28GEN-14 60 80 2.47E-03 98.80 0.05GEN-15 74 99 2.47E-03 122.27 0.06

GEN-16 (MLC Building) 200 318 9.86E-04 156.84 0.08

FP-3 (North) 216 289 2.82E-04 40.82 0.02

2,129 1.061 AP-42, Table 3.3-1. Emissions factors for GEN-16 (MLC Generator) and FP-3 (North) are from vendor data.

2,940 1.47

Table A-6

Diesel Emergency Generators Subtotal:


2 Based on 500 hours of operation per year.


Emergency Engines

Natural Gas Emergency Engines

3 Based on 500 hours of operation per year.

Natural Gas Emergency Generators Subtotal:

Diesel Emergency Engines

2 The Btu/hp-hr conversion for natural gas is from http://www.api.org/~/media/Files/EHS/climate-

change/2009_GHG_COMPENDIUM.ashx.

1 AP-42, Table 3.2-2 for a 4-cycle lean-burn engine. VOC factor for the Paint Shop North GEN is from vendor data.


Emissions UnitTotal Heat Input

(MMBtu/hr)VOC Emissions

1

(lbs/year)

VOC Emissions1

(tons/year)

Total Paint Shop Ovens 92.7 4,293 2.15

Total RTOs 32.0 1,482 0.74

Total Air Supply Units 139.0 6,439 3.22

TOTAL VOC EMISSIONS: 263.7 12,215 6.11

1 Emissions are based on the following:

Hours of Operation: 8,760 hours/year

Heating Value of Natural Gas: 1,040 Btu/cf

VOC Emissions Factor: 5.5 lb/MMscf (AP-42 Section 1.4, Table 1.4-2)

Table A-7


Other Natural Gas Combustion Sources


Tank No. Tank Contents MSC CodeTotal VOC Emissions1

(lbs/yr)

Total VOC Emissions1

(tons/year)

T305 Gasoline (UL)2 125 3,007 1.50

T306 Gasoline (UL)2 125 3,007 1.50

T307 Diesel3 2509 11.09 0.01

T308 Diesel3 2509 11.09 0.01

T303 Coolant (Antifreeze)4 54 0.41 2.04E-04

T302 Windshield Washer 813 100.85 0.05

6,137 3.07

2 Gasoline calculations are based on controlled VOC emissions and HAP weight percent from the MSDSs. 3 Diesel is estimated to contribute trace amounts of benzene.

4 Antifreeze emissions are calculated based on historical data.

Table A-8


Tank Farm

TOTAL VOC EMISSIONS:1 Tank VOC emissions are calculated monthly. In calendar year 2016, the peak monthly VOC emissions for the tanks were

455.56 lbs (gasoline tanks), 1.68 lbs (diesel tanks), 0.03 lbs (coolant tank), and 7.64 lbs (windshield washer fluid tank) as

documented in MBUSI's monthly VOC reports. Therefore, VOC PTE from tanks is based on peak monthly emissions plus

10% annualized.


Description1

UL Gasoline

Dispensed2

(gal/yr)

VOC Emissions

Factor

(Uncontrolled)3

(lb/1000 gal)

Control

Efficiency4

VOC Emissions

Factor

(Controlled)

(lb/gal)

VOC Emissions

(lbs/yr)

VOC Emissions

(tons/yr)

Fuel filling of production vehicles5 1,350,994 11.0 95% 5.50E-04 743.05 0.37

Fuel filling of vehicles used onsite6 169,976 11.0 95% 5.50E-04 93.49 0.05

836.53 0.42

2 UL gasoline dispensed is based on the peak monthly usage in 2016 plus 10% multiplied by 12 .

5 Assumes use of Stage II or ORVR when production vehicles are filled.

Table A-9

4 VOC control efficiency for vehicles equipped using onboard refueling vapor recovery (ORVR) or Stage II vapor recovery assumed to be at least 95% based

on EPA rulemaking "Air Quality: Widespread Use for Onboard Refueling Vapor Recovery and Stage II Waiver" (May 16, 2012 Federal Register).

6 Assumes onsite vehicles equipped with ORVR.


Fueling

TOTAL VOC EMISSIONS:1 Fuel filling emissions include only those from gasoline filling. Diesel filling emissions are negligible.

3 Emissions factor for uncontrolled VOC emissions from AP-42 Table 5.2-7 "Evaporative Emissions from Gasoline Service Stations."


137.54 tons per year (based on peak monthly emissions plus 10% annualized)

MSC Number Description / product name

Gross Usage of

Direct Materials

in 2016

Units

Gross

Usage

(gal)

Density

(lb/gal)VOC wt%

Gross

Usage (lbs)

Net Usage

(gal)

VOC

Content

(lb/gal)

18 IPA - Indirect Materials 17,555 gal 17,555.0 6.59 0.90 115,687.5 17,555.0 5.93

272 Glass Bonding Primer 1,883 L 497.5 6.59 1.00 3,277.6 497.5 6.53

2798 Adhesive Betaseal 1893 11,675 L 3,084.2 11.35 0.00 35,005.3 3,084.2 0.00

2673 Betaseal 1970 13 L 3.4 10.43 0.01 35.8 3.4 0.03

3125 Adhesive EFBOND RA 820 107,846 KG 20,356.1 11.68 0.00 237,759.4 20,356.1 0.00

1213 Terostat 1211 33,919 kg 6,400.4 11.68 0.00 74,779.5 6,400.4 0.00

3080 Adhesive Terostat 3225 DC-25 209,571 KG 35,732.8 12.93 0.00 462,024.8 35,732.8 0.00

3284 Silkaflex 250 DM-3 (AC) 360 L 95.1 8.22 0.59 781.5 95.1 4.84

166 Sealing DBL 6069.20 Sikaflex 221 721 KG 148.8 10.68 0.02 1,589.5 148.8 0.24

3266 Versilok 254 Adhesive 1,222 KG 223.3 12.07 0.00 2,694.8 223.3 0.02

3285 Eftec EFBOND UA 248 407 KG 95.3 9.43 0.00 898.4 95.3 0.00

3290 Adhesive Sikaflex-DM6 1,396 KG 299.8 10.26 0.00 3,077.3 299.8 0.05

3267 Versilok 253 Adhesive 1,984 KG 439.5 9.95 0.00 4,373.0 439.5 0.00

3278 EFBOND RA 350 1,150 KG 209.6 12.10 0.20 2,536.3 209.6 0.00

3281 EFBOND RA 310 29,408 KG 5,550.9 11.68 0.00 64,834.3 5,550.9 0.00

3157 Betaseal 1948 Glass Bonding 402,243 KG 78,756.1 11.26 0.00 886,793.9 78,756.1 0.00

3288 Sikaflex 250 DM10 50,430 KG 10,323.1 10.77 0.00 111,179.5 10,323.1 0.00

3216 Sikaflex 234 9,846 KG 1,926.1 11.27 0.00 21,707.5 1,926.1 0.00

275 Glass Bonding Cleaner 1,883 KG 502.8 8.26 0.58 4,151.5 502.8 4.82

2591 Betaprime 5404 4 grams 0.0012 7.59 0.76 0.0 0.0 5.80

406 Brake Fluid 248,361 L 65,610.0 9.00 1.00 590,253.9 65,610.0 9.00

2503/3222 Bonnie Marlin Parts Wash 388 gal 388.0 8.50 0.25 3,298.0 388.0 2.04

18/2592 Prosat Alcohol Wipes 1,724 L 455.5 6.58 1.00 2,997.6 455.5 6.58

3215 BASF Flash Primer 850 L 224.5 12.85 0.05 2,885.4 224.5 0.64

3063 Flash Primer FU03-0101 385 KG 67.7 12.54 0.15 848.8 67.7 1.88

2387 Finesse IT Extra Fine 10 gal 10.0 8.35 0.14 83.5 10.0 1.17

2568 Glasurit 929-93 343 L 90.6 8.35 0.57 756.6 90.6 4.74

2566 Glasurit 352-91 620 L 163.7 7.28 1.00 1,191.4 163.7 7.28

2577 Glasurit 352-500 50 L 13.1 7.59 0.99 99.2 13.1 7.50

2567 Glasurit 923-109 655 L 173.0 8.26 0.47 1,428.7 173.0 3.90

828 Nalco 71D5+ 5 gal 4.9 7.00 0.58 34.0 4.9 4.17

3261 Nalco 71306 1,228 gal 1,228.0 9.00 0.27 11,052.0 1,228.0 2.45

3205 Nalco PD9604 3,844 gal 3,844.2 7.32 0.02 28,137.6 3,844.2 0.15

3442 Nalco 71309 926 gal 926.5 8.50 0.28 7,875.1 926.5 2.40

812 Nalco Pol-EZ 6500 660 gal 660.0 8.55 0.14 5,643.0 660.0 1.21

2837 Nalco 7768 200 gal 200.0 8.80 0.26 1,760.0 200.0 2.31

2498 Nalco PC-11 1,037 gal 1,037.3 10.40 0.10 10,787.6 1,037.3 1.02

2978 Biocide 2,045 gal 2,045.0 8.50 0.01 17,382.5 2,045.0 0.07

2947 Chemico 7915 3,165 gal 3,165.0 8.37 0.25 26,491.1 3,165.0 2.09

2946 Chemico 7831 2,220 gal 2,220.0 8.57 0.15 19,025.4 2,220.0 1.28

2688 Chemico 2500 88 gal 88.0 8.01 0.10 704.9 88.0 0.80

2578 Oakite 318 1,210 gal 1,210.0 6.77 1.00 8,191.7 1,210.0 6.77

1213 Sealer (Body Shop) 33,919 kg 6,404.5 11.68 0.00 74,779.5 6,404.5 0.00

2743 Sealer (Body Shop Betamate 1044-3) 0 kg 0.0 11.01 0.03 0.0 0.0 0.37

3081 BETAMATE 1041G 59,620 kg 12,506.2 10.51 0.02 131,440.1 12,506.2 0.19

574 Formic Acid 1,154 gal 1,154.5 10.10 0.95 11,660.0 1,154.5 9.60

VOCs are generated through the use of miscellaneous VOC-containing products throughout the plant, such as cleaners, polishing materials, sealers, adhesives,

and automotive fluids. The particular products and the mix in which they are used change from month to month. Miscellaneous VOC emissions are tracked

monthly. In calendar year 2016, the peak monthly VOC emissions for miscellaneous materials was 10.42 tons (December 2016) as documented in MBUSI's

monthly VOC reports. Therefore, VOC PTE from miscellaneous materials is:

Some example materials and the total amounts used in calendar year 2016 are provided below to illustrate the types of emissions included with the

Miscellaneous VOC category.


Miscellaneous VOC from Miscellaneous Material Usage

Table A-10


APPENDIX B - BASELINE ACTUAL VOC EMISSIONS

MonthVOC Emissions

1

(ton/month)

12-Month Rolling Total for

VOC Emissions (tons/yr)

Baseline Annual Actual VOC

Emissions (tons/yr)2

Jan-13 18.28 - -

Feb-13 25.20 - -

Mar-13 15.61 - -

Apr-13 22.10 - -

May-13 22.10 - -

Jun-13 22.54 - -

Jul-13 21.88 - -

Aug-13 21.28 - -

Sep-13 17.86 - -

Oct-13 19.63 - -

Nov-13 24.64 - -

Dec-13 17.08 248.21 -

Jan-14 13.94 243.87 -

Feb-14 27.47 246.14 -

Mar-14 23.85 254.38 -

Apr-14 26.86 259.13 -

May-14 20.74 257.77 -

Jun-14 24.34 259.57 -

Jul-14 28.13 265.82 -

Aug-14 38.48 283.01 -

Sep-14 36.97 302.13 -

Oct-14 38.87 321.37 -

Nov-14 25.65 322.38 -

Dec-14 30.94 336.25 292.23

Jan-15 27.89 350.20 297.03

Feb-15 30.59 353.32 299.73

Mar-15 36.27 365.74 310.06

Apr-15 35.29 374.18 316.65

May-15 30.40 383.83 320.80

Jun-15 34.66 394.15 326.86

Jul-15 38.81 404.83 335.32

Aug-15 39.48 405.83 344.42

Sep-15 35.59 404.45 353.29

Oct-15 40.78 406.36 363.86

Nov-15 30.34 411.04 366.71

Dec-15 29.06 409.16 372.70

Jan-16 32.23 413.50 381.85

Feb-16 34.65 417.55 385.44

Mar-16 34.28 415.56 390.65

Apr-16 41.25 421.52 397.85

May-16 40.24 431.36 407.60

Table B-1

MBUSI Baseline Actual Emissions

VOC Emissions from January 2013 to December 2017


MonthVOC Emissions

1

(ton/month)

12-Month Rolling Total for

VOC Emissions (tons/yr)

Baseline Annual Actual VOC

Emissions (tons/yr)2

Table B-1

MBUSI Baseline Actual Emissions

VOC Emissions from January 2013 to December 2017

Jun-16 36.24 432.94 413.55

Jul-16 28.30 422.44 413.63

Aug-16 45.44 428.40 417.12

Sep-16 38.86 431.67 418.06

Oct-16 40.77 431.66 419.01

Nov-16 39.43 440.75 425.90

Dec-16 36.08 447.77 428.46

Jan-17 31.68 447.22 430.36

Feb-17 37.23 449.80 433.68

Mar-17 37.28 452.79 434.18

Apr-17 31.68 443.22 432.37

May-17 38.86 441.84 436.60

Jun-17 26.57 432.18 432.56

Jul-17 27.69 431.57 427.00

Aug-17 42.34 428.46 428.43

Sep-17 34.52 424.13 427.90

Oct-17 34.54 417.90 424.78

Nov-17 31.26 409.73 425.24

Dec-17 27.94 401.59 424.68

1 Baseline annual actual emissions represent an annualized rolling 24-month period.

1 VOC emissions data from monthly VOC reports and annual emissions inventories previously submitted to ADEM.


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