ATIEVA USA INC. CASA...

$Page 1: ATIEVA USA INC. CASA GRANDEbloximages.chicago2.vip.townnews.com/pinalcentral.com/...S:\Word\PERMITS\Issued.c\C31230.ISS.docx PERMIT #C31230.000 1 (3/28/2017) Lucid Motors – Casa$
S:\Word\PERMITS\Issued.c\C31230.ISS.docx PERMIT #C31230.000

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(3/28/2017) Lucid Motors – Casa Grande

ATIEVA USA INC. – CASA GRANDE

1. INTRODUCTION .............................................................................................................................................. 4

2. LISTING OF (FEDERALLY ENFORCEABLE) APPLICABLE REQUIREMENTS ........................................................... 4

3. COMPLIANCE CERTIFICATION ......................................................................................................................... 5

A. COMPLIANCE PLAN ................................................................................................................................................. 5 B. COMPLIANCE SCHEDULE ........................................................................................................................................... 5

4. AUTHORITY TO CONSTRUCT ........................................................................................................................... 5

A. GENERALLY ............................................................................................................................................................ 5 B. MINOR NEW SOURCE REVIEW REQUIREMENTS ............................................................................................................ 6

5. EMISSION LIMITATIONS AND CONTROLS ....................................................................................................... 8

A. APPLICABLE LIMITATIONS ......................................................................................................................................... 8 B. ALLOWABLE EMISSIONS ........................................................................................................................................... 8 C. MINOR SOURCE STATUS - VOC'S AND HAP'S .............................................................................................................. 8

1. Major Source Thresholds ................................................................................................................................. 8

2. Annual Emission Cap and Product Use Limitations ......................................................................................... 9

3. Consumables Expansion .................................................................................................................................. 9

4. Consumable Expansion Notification ................................................................................................................ 9

D. SPRAY PAINT AND OTHER SURFACE COATING OPERATIONS ............................................................................................. 9 E. CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS - RTO OPERATING REQUIREMENTS ............................................ 10

1. Minimum Destruction Efficiency.................................................................................................................... 10

2. Temperature Monitoring System .................................................................................................................. 10

3. Minimum Operating Temperature ................................................................................................................ 10

F. CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS - ADR OPERATING REQUIREMENTS ............................................ 10 1. Minimum Destruction Efficiency.................................................................................................................... 10

2. ADR parameters ............................................................................................................................................ 10

G. CONTROL OF PARTICULATE MATTER EMISSIONS ......................................................................................................... 10 1. Mass Emissions Limitation ............................................................................................................................ 11

a. Particulate Emissions – Fuel Burning Equipment ...................................................................................................... 11 b. Particulate Emissions – Fossil Fuel Fired Industrial Equipment and Stationary Rotating Machinery ........................ 11

H. NITROGEN OXIDES EMISSION .................................................................................................................................. 11 1. Boilers and Water Heaters ............................................................................................................................ 11

2. RTOs and other Unclassified Sources............................................................................................................. 11

I. SULFUR DIOXIDE EMISSIONS ................................................................................................................................... 11 1. Boilers and Water Heaters ............................................................................................................................ 11

2. RTOs and other Unclassified Sources............................................................................................................. 11

J. OPACITY LIMITS .................................................................................................................................................... 12 1. SIP Limitation ................................................................................................................................................. 12

2. Visibility Limiting Standard ............................................................................................................................ 12

K. PARTICULATE MATTER REASONABLE PRECAUTIONS ..................................................................................................... 12 L. SURFACE STABILIZATION......................................................................................................................................... 13 M. NSPS (SUBPART MM) STANDARDS – AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS .................. 13

1. For each Electrodeposition prime coat operation: ........................................................................................ 14

2. For each nonelectrodeposition prime coat operation: .................................................................................. 14

N. NSPS (SUBPART IIII) STANDARDS – STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION ENGINES .................... 14 O. FUEL USE LIMITATIONS ...................................................................................................................................... 14

1. Primary Fuels ................................................................................................................................................. 14


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P. GENERAL MAINTENANCE OBLIGATION ...................................................................................................................... 15

6. COMPLIANCE DEMONSTRATION .................................................................................................................. 15

A. VOC AND HAP EMISSIONS MONITORING AND RECORDKEEPING ................................................................................... 15 1. Product Labeling ............................................................................................................................................ 15

2. Consumable Log ............................................................................................................................................ 15

3. Monthly Usage Summary .............................................................................................................................. 15

B. REGULAR EMISSIONS MONITORING AND RECORDKEEPING ............................................................................................ 16 1. Non-instrumental emissions monitoring - oxides of nitrogen and carbon monoxide ................................... 16

2. SOx monitoring .............................................................................................................................................. 16

3. Opacity monitoring ........................................................................................................................................ 17

C. OPERATIONAL MONITORING ................................................................................................................................... 17 1. Spray Booths Operation Monitoring ............................................................................................................. 17

2. ADR and RTO Operation Monitoring ............................................................................................................. 17

3. ADR and RTO Planned Shutdowns ................................................................................................................. 17

D. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS MONITORING PROVISIONS ..... 18 E. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS REPORTING AND RECORDKEEPING

PROVISIONS ................................................................................................................................................................. 18 F. NSPS (SUBPART MM) AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS PERFORMANCE TEST AND

COMPLIANCE PROVISION ................................................................................................................................................ 19 G. NSPS (SUBPART IIII) INTERNAL COMBUSTION ENGINE (ICE) OPERATIONAL COMPLIANCE DEMONSTRATION ......................... 20 H. PERFORMANCE TESTING......................................................................................................................................... 20

1. Generally Applicable Test Program Requirements ........................................................................................ 20 a. Test Requirement ..................................................................................................................................................... 21 b. Test Protocol ............................................................................................................................................................. 21 c. Timing of initial and subsequent tests ...................................................................................................................... 21 d. Test Report ............................................................................................................................................................... 21

2. RTO Testing - Destruction Efficiency Verification .......................................................................................... 21

3. ADR Testing ................................................................................................................................................... 22

4. Capture Efficiency Testing ............................................................................................................................. 22

I. RECORDKEEPING ................................................................................................................................................... 22 J. SEMI-ANNUAL COMPLIANCE REPORTING................................................................................................................... 23 K. ANNUAL REGULAR COMPLIANCE/COMPLIANCE PROGRESS CERTIFICATION ....................................................................... 23

7. OTHER REPORTING OBLIGATIONS ................................................................................................................ 23

A. DEVIATIONS FROM PERMIT REQUIREMENTS ............................................................................................................... 23 B. NOTIFICATION OF CONSTRUCTION, START-UP AND INITIAL COMPLIANCE ......................................................................... 23

1. Notification of Construction & Start-up ......................................................................................................... 23

2. NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations Notification

Requirements ....................................................................................................................................................... 24

C. ANNUAL EMISSIONS INVENTORY .............................................................................................................................. 24

8. FEE PAYMENT ............................................................................................................................................... 24

9. GENERAL CONDITIONS ................................................................................................................................. 25

A. TERM ................................................................................................................................................................. 25 B. BASIC OBLIGATION ................................................................................................................................................ 25 C. DUTY TO SUPPLEMENT APPLICATION ........................................................................................................................ 25 D. RIGHT TO ENTER ................................................................................................................................................... 25 E. TRANSFER OF OWNERSHIP ...................................................................................................................................... 25 F. POSTING OF PERMIT .............................................................................................................................................. 25 G. PERMIT REVOCATION FOR CAUSE ............................................................................................................................. 26


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H. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS ......................................................................................... 26 I. PERMIT EXPIRATION AND RENEWAL ......................................................................................................................... 26 J. SEVERABILITY ....................................................................................................................................................... 26 K. PERMIT SHIELD..................................................................................................................................................... 26 L. PERMIT REVISIONS ................................................................................................................................................ 27 M. PERMIT RE-OPENING ......................................................................................................................................... 27 N. RECORD RETENTION .......................................................................................................................................... 28 O. SCOPE OF LICENSE CONFERRED ............................................................................................................................ 28 P. EXCESS EMISSION REPORTS; EMERGENCY PROVISION .................................................................................................. 28

10. EQUIPMENT ................................................................................................................................................. 29

A. PERMITTED EQUIPMENT ......................................................................................................................................... 29 B. INSIGNIFICANT ACTIVITIES ...................................................................................................................................... 31

11. EMISSION INVENTORY TABLE ....................................................................................................................... 31

APPENDIX A: SEMI-ANNUAL REPORT ................................................................................................................... 32


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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 336111: 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 #503-57-001F, 503-57-001J, 503-57-002B, 503-

57-002C, 503-57-002E, 503-57-004A, 503-57-004B, 503-57-005A, 503-57-005B. 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 §3-1-084.

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:

7-3-1.1 Visible Emissions; General

(6/16/80) 47 FR 15579 (4/12/82)

7-3-1.2 Emission Standards - Particulate Emissions - Fugitive Dust

(3/31/75) 43 FR 50531 (11/15/78)

7-3-5.1.B Fuel-Burning Equipment – Nitrogen Oxide Emissions

(3/31/75) 43 FR 50534 (11/15/78)]

7-3-1.7 Fuel-Burning Equipment – Particulate Emissions

(3/31/75) 43 FR 50531 (11/15/78)


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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:

2-8-300 Visibility Limiting Standard

(5/18/05) 71 FR 15043 (3/27/06)

4-2-040 Fugitive Dust Standards

(6/29/93) 72 FR 41896 (08/01/07)

5-22-960 Fossil Fuel Fired Steam Generator Sulfur Dioxide Emission Limitation

(2/22/95) 65 FR 58359 (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 60.390. 60.91, 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 60.4202, 60.4205(b), 60.4207(b),

60.4206, 60.4211(a),(c),(f).

E. General Provisions, 40 CFR 60, Subpart A, 40 CFR 60.1-60.19 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 §§3-1-081.C, 3-1-083.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 §§3-1-060.B.1, 3-1-083.A.7.c)

Insofar as the Permittee is currently in compliance, no compliance schedule to attain compliance is

required.

4. Authority to Construct

A. Generally

[Federally enforceable pursuant to PCAQCD Code §§3-1-010, 3-1-040 ( 10/12/95) approved as

a SIP element at 65 FR 79742 (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


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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 §3-3-203, 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 §§3-1-010, 3-1-040 (10/12/95) approved as a

SIP element at 65 FR 79742 (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 §3-1-084 (8/15/94) approved as a

SIP element at 61 FR 15717 (12/20/00)] (Code §3-1-081.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



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




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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


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


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


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);


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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 § 3-1-082 (11/3/93) approved as SIP

Elements at 65 FR 79742 (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 § 3-1-040 (10/12/95) approved as SIP

Elements at 65 FR 79742 (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§3-2-180, 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 §§1-3-140.74a, 3-1-050)

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

§1-3-140.74a. 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 §3-1-084 (8/15/94) approved as SIP

Elements at 61 FR 15717 (4/9/96)]

1. Major Source Thresholds

a. VOC Emissions


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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 email 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 §5-13-390)

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 ("PM10"), 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.


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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


Elements at 61 FR 15717 (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 1450̊ 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


Elements at 61 FR 15717 (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


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1. Mass Emissions Limitation

a. Particulate Emissions – Fuel Burning Equipment

[PGCAQCD Reg. 7-3-1.7 (3/31/75) approved as a SIP element at 43 FR 50531

(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-.0.231, 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 §5-23-1010 and §5-21-930)

The maximum allowable emissions shall be determined by the following

equation:

E = 1.02Q0.769 where:

E = the maximum allowable particulate emissions rate in pounds-mass per

hour and

Q = 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. 7-3-5.1.B (3/31/75)

approved as a SIP element at 43 FR 50531 (11/15/78)] (Code §5-22-970)

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 §5-24-1030.A.3.)

The Permittee shall not emit more than 500 parts per million of nitrogen oxides expressed

as NO2 from the RTOs and any unclassified source.

I. Sulfur Dioxide Emissions

1. Boilers and Water Heaters

[Federally Enforceable Provision pursuant Code §5-22-960 (2/22/95) approved as a

SIP element at 65 FR 58359 (9/29/00)]

The steam boilers and water heaters shall only burn gaseous fuel.

2. RTOs and other Unclassified Sources

(Code §5-24-1030.A.2)


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The permittee shall not emit more than 600 parts per million of sulfur dioxide from the

RTOs and any unclassified source.

J. Opacity Limits

1. SIP Limitation

[Federally enforceable pursuant to PGAQCD Reg. 7-3-1.1 (8/7/80) approved as a SIP

element at 47 FR 15580 (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 §2-8-300 (5/18/05) approved as a SIP element

at 71 FR 15043 (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 §4-2-040 (6/29/93) approved as a SIP element at 72

FR 41896 (8/1/07) and PGAQD Reg. 7-3-1.2 (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 all-

terrain vehicles, trucks, cars, cycles, bikes, or buggies, without taking reasonable


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


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.


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 §4-1-030, 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 §4-9-340.

2. 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 4-9-

320.

6. 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 §4-9-340.

7. Permittee shall not allow silt loading equal to or greater than 0.33 oz/ft2 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 60.390. 60.392]

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


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. 0.17 kilogram of VOC per liter of applied coating solids when the solids

turnover ratio is 0.16 or greater.

b. 0.17 × 350 (0.160-RT) kg of VOC per liter of applied coating solids when the solids

turnover ratio is greater than or equal to 0.040 and less than 0.160.

c. When the solids turnover ratio is less than 0.040, there is no emission limit.

2. For each nonelectrodeposition prime coat operation:

a. 0.17 kilogram of VOC per liter of applied coating solids.

b. 1.40 kilograms of VOC per liter of applied coating solids from each guide coat

operation.

c. 1.47 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 60.4202(a), 60.4205(b)(c), 60.4206, 60.4211(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 89.112 and 40 CFR 89.113

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 §§3-1-081)

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 §5-23-1010.F)

c. Federal Fuel limitations

[Federally enforceable pursuant to 40 CFR 60.4207.b]

For 2007 and later engines Permittee shall use a diesel fuel that meets the

requirements in 40 CFR 80.510(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;


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 §3-1-081 (9/5/01)

approved as a SIP element at 66 FR 63166 (12/5/01)

P. General Maintenance Obligation

[Federally Enforceable Provision pursuant to code §3-1-081.E (9/5/01) approved as a SIP

element at 66 FR 63166 (12/5/01)](Code §8-1-030.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 §3-1-084 (8/15/94) approved as a SIP

element at 61 FR 15717 (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. the manufacturer's product identification number

iii. the relevant material data safety sheet (MSDS) or environmental data

sheet (EDS) number and issue date;

iv. 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


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 §3-1-083.A (2/22/95)) approved as a SIP

element at 65 FR 79742 (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 31st 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


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

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.

C. Operational Monitoring

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 1450̊ F(1-

hr average) or the ADR desorption temperature fall below 370oF (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


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 60.394]

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. 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.

iii. 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 60.395]

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

60.392 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 60.392 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 60.393 and

§6.H of this permit.

b. For thermal incinerators, if no such periods occur, the owner or operator shall

submit a negative report.


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 60.393]

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 60.392 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.


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 §60.392 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 60.4211.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 §3-1-083 (2/22/95) and §3-1-170 (11/3/93)

approved as a SIP element at 65 FR 79742 (12/20/00)]

1. Generally Applicable Test Program Requirements


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.


22


iii. If the Permittee can demonstrate that a group of two or more RTOs

accept flows consisting of substantially identical HAP species and

quantities the Permittee may propose in the HAP test protocol to only

test one RTO in each group. Approval to test a singular unit within the

group will be assessed on a case-by-case basis.

3. ADR Testing

a. Permittee shall conduct a performance test to verify the VOC destruction

efficiency of any ADR within 60 days after achieving maximum production rate

at which the ADR 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 control efficiency performance test shall be repeated

annually at each ADR, no later than 12 months after the previous test.

4. Capture Efficiency Testing

a. Permittee shall conduct a capture efficiency or paint retention performance test

to verify the VOC balance assumed in the initial application for each of the

following spray booth operations within 60 days after achieving maximum

production rate at which the associated spray booth will be operated, but no later

than 180 days after commissioning using a mass balance approach as defined in

the protocol.

Process A03 E-Coat

Process A04 Sealers

Process A05 Antichip

Process A06 Liquid Appplied Sound Deadener (LASD)

Process A08 Primer

Process A09 Basecoat

Process A19 Clearcoat

b. Subsequent capture efficiency tests are not required unless the design and/or

process parameters (such as but not limited to booth design and transportation

time to the oven) associated with the original test are changed. Should the design

and/or process parameters associated with the original test change the Permittee

shall include a capture efficiency test protocol in the next annual test protocol

submittal and shall conduct such tests on the same timeline as the annual VOC

destruction efficiency testing.

I. Recordkeeping


element at 65 FR 79742 (12/20/00)]

Permittee shall maintain records of:

a. All information required pursuant to any federally enforceable provision of this

permit, recorded in a permanent form suitable for inspection.

b. All measurements, including continuous monitoring systems, monitoring

devices and performance testing measurements; all monitoring device

calibration checks, adjustments and maintenance performed on these systems or

devices.


23


c. The occurrence and duration of any start-up, shutdown or malfunction in the

operation of the permitted facility or any air pollution control equipment. For

purposes of this provision, a "shut-down" means a cessation of operations at the

entire facility for more than seven days, and a "start-up" constitutes the

reactivation of the facility after a "shut-down."

J. Semi-Annual Compliance Reporting


element at 65 FR 79742 (12/20/00)]

Permittee shall submit a semi-annual report of emissions by submitting a copy of so much of the

Monthly Usage Summary as may be required to reflect product use in the preceding calendar

half. The report shall be submitted to the District within 30 days after the end of each half

calendar year. Appendix A is a form which may be used for the report.

K. Annual Regular Compliance/Compliance Progress Certification


Element at 65 FR 79742 (12/20/00)]

Permittee shall annually submit a certification of compliance with the provisions of this permit.

The certification shall:

1. Be signed by a responsible official, namely the proprietor, a general partner, the

president, secretary, treasurer or vice-president of the corporation, or such other person as

may be approved by the Control Officer as an administrative amendment to this permit;

2. Acknowledge that the product-use limitations under this permit constitute an emissions

limitation;

3. Verify whether or not Permittee has complied with respect to the product use limitations

under this permit;

4. Verify whether compliance with respect to each such term or condition has

been continuous or intermittent;

5. Verify that the compliance certification is based upon records documenting compliance

with the product use limitations under this permit; and

6. Be postmarked within thirty (30) days of the start of each calendar year.

7. Other Reporting Obligations

A. Deviations from Permit Requirements

[Federally Enforceable Provision pursuant to code §3-1-081.A.5.b (9/5/01) approved as a SIP

element at 66 FR 63166 (12/5/01)]

Permittee shall report any deviation from the requirements of this permit along with the

probable cause for such deviation, and any corrective actions or preventative measures taken to

the District within ten days of the deviation unless earlier notification is required by the

provisions of this permit.

B. Notification of Construction, Start-up and Initial Compliance

1. Notification of Construction & Start-up

[Federally Enforceable, pursuant to 40 CFR Part 60.7]


24


(Code §3-1-083)

For new facilities and modification of existing facilities, the Permittee shall notify the

Administrator and the District in writing of:

a. The anticipated date of initial start-up of each facility of the source for which

construction or modification is allowed by this permit; notice shall be sent not

more than sixty (60) days nor less than thirty (30) days prior to such date;

b. The actual date of commencement of construction; notice shall be sent within

thirty (30) days of such date; and

c. The actual date of start-up; notice shall be sent within fifteen (15) days after

such date.

2. NSPS (Subpart MM) Automobile and Light Duty Truck Surface Coating Operations

Notification Requirements

[Federally enforceable pursuant to 40 §60.395]

Each owner or operator of an affected facility shall submit an initial compliance report

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 shall

include the following data:

a. The owner or operator shall report the volume weighted average mass of VOC

per volume of applied coating solids for each affected facility.

b. Where compliance is achieved through the use of incineration, the owner or

operator shall include the following additional data in the control device initial

NSPS Subpart MM performance test required by 40 CFR 60.8(a) and §6.H of

this permit or subsequent performance tests at which destruction efficiency is

determined: the combustion temperature, the total mass of VOC per volume of

applied coating solids before and after the incinerator, capture efficiency, the

destruction efficiency of the incinerator used to attain compliance with the

applicable emission limit specified in 40 CFR 60.392 and §5.M of this permit

and a description of the method used to establish the fraction of VOC captured

and sent to the control device.

C. Annual Emissions Inventory


element at 65 FR 79742 (12/2/00)]

Permittee shall complete and submit to the District an annual emissions inventory, disclosing

actual emissions for the preceding calendar year.

The submittal shall be made on a form provided by the District. The inventory is due by the

latter of March 31, or ninety (90) days after the form is furnished by the District.

8. Fee Payment

(Code §3-7-600)

As an essential obligation under this permit, a permit fee shall be assessed by the District and paid by

Permittee in accord with the provisions of Code Chapter 3, Article 7, as they may exist at the time the fee is

due. The permit fee shall be due annually on or before the anniversary date of the issuance of an individual


25


permit, or formal grant of approval to operate under a general permit, or at such other time as may be

designated now or hereafter by rule. The District will notify the Permittee of the amount to be due, as well

as the specific date on which the fee is due.

9. General Conditions

A. Term

(Code §3-1-089)

This permit shall have a term of five (5) years, measured from the date of issuance.

B. Basic Obligation

(Code §3-1-081)

Permittee shall operate in compliance with all conditions of this permit, the Pinal County Air

Quality Control District ("the District") Code of Regulations ("Code"), and all State and Federal

laws, statutes, and codes relating to air quality that apply to these facilities. Any permit

noncompliance is grounds for enforcement action; for a permit termination, revocation and

reissuance, or revision; or for denial of a permit renewal application and may additionally constitute

a violation of the CAA.

C. Duty to Supplement Application

(Code §§3-1-050.H., 3-1-081.A.8.e., 3-1-087.A.1.c., 3-1-110)

Even after the issuance of this permit, a Permittee, who as an applicant failed to include all

relevant facts, or who submitted incorrect information in an application, shall, upon becoming

aware of such failure or incorrect submittal, promptly submit a supplement to the application,

correcting such failure or incorrect submittal. In addition, Permittee shall furnish to the District

within thirty days any information that the Control Officer may request in writing to determine

whether cause exists for modifying, revoking and reissuing, or terminating this permit or to

determine compliance with this permit and/or the Code.

D. Right to Enter

(Code §§3-1-132, 8-1-050)

Authorized representatives of the District shall, upon presentation of proper credentials and a

showing that the District representative is equipped with certain safety equipment, namely a hard

hat, be allowed:

1. To enter upon the premises where the source is located or in which any records are required to

be kept under the terms and conditions of this permit;

2. To inspect any equipment, operation, or method required in this permit; and

3. To sample emissions from the source.

E. Transfer of Ownership

(Code §3-1-090)

This permit may be transferred from one person to another by notifying the District at least 30

days in advance of the transfer. The notice shall contain all the information and items required by

Code §3-1-090. The transfer may take place if not denied by the District within 10 days of the

receipt of the transfer notification.

F. Posting of Permit


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(Code §3-1-100)

Permittee shall firmly affix the permit, an approved facsimile of the permit, or other approved

identification bearing the permit number, upon such building, structure, facility or installation for

which the permit was issued. In the event that such building, structure, facility or installation is so

constructed or operated that the permit cannot be so placed, the permit shall be mounted so as to

be clearly visible in an accessible place within a reasonable distance of the equipment or

maintained readily available at all times on the operating premises.

G. Permit Revocation for Cause

(Code §3-1-140)

The Director of the District (“Director") may revoke this permit for cause, which cause shall

include occurrence of any of the following:

1. The Director has reasonable cause to believe that the permit was obtained by fraud or

material misrepresentation;

2. Permittee failed to disclose a material fact required by the permit application form or a

regulation applicable to the permit;

3. The terms and conditions of the permit have been or are being violated.

H. Certification of Truth, Accuracy, and Completeness

(Code §3-1-175)

Any application form, report, or compliance certification submitted pursuant to the Code shall

contain certification by a responsible official of truth, accuracy, and completeness. This

certification and any other certification required under Chapter 3 of the Code shall state that, based

on information and belief formed after reasonable inquiry, the statements and information in the

document are true, accurate, and complete.

I. Permit Expiration and Renewal

(Code §3-1-089)

Expiration of this permit will terminate the facility’s right to operate unless a timely application for renewal has been submitted in accordance with §§3-1-050, 3-1-055 and 3-1-060, or a substitute

application for general permit under §3-5-490 is submitted. For Class I permit renewals, a timely

application is one that is submitted at least 6 months, but not greater than 18 months prior to the

date of permit expiration. For Class II or Class III permit renewals, a timely application is one that

is submitted at least 3 months, but not greater than 12 months prior to the date of permit

expiration.

J. Severability

(Code §3-1-081.A.7)

The provisions of this permit are severable, and if any provision of this permit is held invalid the

remainder of this permit shall not be affected thereby.

K. Permit Shield

(Code §§3-1-081.A.8.b, 3-1-102)

1. Compliance with the terms of this permit shall be deemed compliance with any

applicable requirement identified in this permit.


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2. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of this permit.

L. Permit Revisions

(Code Chapter 3, Article 2)

1. This permit may be revised, reopened, revoked and reissued, or terminated for cause.

Other than as expressly provided in Code Chapter 3, Article 2, the filing of a request by

the permittee for a permit revision, revocation and reissuance, or termination, or of a

notification of planned changes or anticipated noncompliance does not stay any permit

condition.

2. The permittee shall furnish to the Control Officer, within a reasonable time, any

information that the Control officer may request in writing to determine whether cause

exists for revising, revoking and reissuing, or terminating the permit or to determine

compliance with the permit.

3. Permit amendments, permit revisions, and changes made without a permit revision shall

conform to the requirements in Article 2, Chapter 3, of the Code.

4. Should this source become subject to a standard promulgated by the Administrator

pursuant to CAA §112(d), then Permittee shall, within twelve months of the date on

which the standard is promulgated, submit an application for a permit revision

demonstrating how the source will comply with the standard. (Code §3-1-050.C.5)

5. Revision to Permit Provisions Designated as Federally Enforceable Pursuant to Code §3-

1-084 [Federally Enforceable Provision pursuant to code §3-1-084 (8/15/94) approved

as a SIP Element at 61 FR 15717 (4/9/96)]

As an express condition of preserving the federal enforceability of any provision of this

permit designated "federally enforceable" pursuant to Code §3-1-084, Permittee shall not

make any facility allowed change that would contravene such provision, until thirty (30)

days after the Permittee has previously furnished notice of the proposed change to the

District and to the Administrator, to thereby allow the Administrator opportunity to

comment upon the continued "federal enforceability" of the subject provision after the

proposed change.

M. Permit Re-opening

(Code §3-1-087)

1. This permit shall be reopened if either:

a. The Control Officer determines that it contains a material mistake or that

inaccurate statements were made in establishing the emissions standards or other

terms or conditions of it;

b. The Control Officer determines that it needs to be revised or revoked to assure

compliance with the applicable requirements; or

c. The EPA makes a material objection to any of those federally enforceable

designations under Code §3-1-084 after the normal EPA review period is ended.

2. If this permit must be reopened or revised, the District will notify the permittee in accord

with Code §3-1-087.A.3.


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N. Record Retention

(Code §3-1-083.A.2.b)

Permittee shall retain for a period of five (5) years all documents required under this permit,

including reports, monitoring data, performance testing, support information, calibration and

maintenance records, and all original recordings or physical records of required continuous

monitoring instrumentation.

O. Scope of License Conferred

(Code §3-1-081.A.8.d)

This permit does not convey any property rights of any sort, or any exclusive privilege.

P. Excess Emission Reports; Emergency Provision

(Code §3-1-081.E, Code §8-1-030)

1. To the extent Permittee may wish to offer a showing in mitigation of any potential

penalty, underlying upset events resulting in excess emissions shall reported as follows:

a. The permittee shall report to the Control Officer any emissions in excess of the

limits established by this permit. Such report shall be in two parts:

i. Notifications by telephone or facsimile within 24 hours or the next

business day, whichever is later, of the time when the owner or operator

first learned of the occurrence of excess emissions, including all available

information required under subparagraph b. below.

ii. Detailed written notification within 3 working days of the initial

occurrence containing the information required under subparagraph b.

below.

b. The excess emissions report shall contain the following information:

i. The identity of each stack or other emission point where the excess

emissions occurred.

ii. The magnitude of the excess emissions expressed in the units of the

applicable limitation.

iii. The time and duration or expected duration of the excess emissions.

iv. The identity of the equipment from which the excess emissions occurred.

v. The nature and cause of such emissions.

vi. If the excess emissions were the result of a malfunction, steps taken to

remedy the malfunction and the steps taken or planned to prevent the

recurrence of such malfunctions.

vii. The steps that were or are being taken to limit the excess emissions. To

the extent this permit defines procedures governing operations during

periods of start-up or malfunction, the report shall contain a list of steps

taken to comply with this permit.


29


viii. To the extent excess emissions are continuous or recurring, the initial

notification shall include an estimate of the time the excess emissions will

continue. Continued excess emissions beyond the estimated date will

require an additional notification.

2. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to

exceed a technology-based emission limitation under the permit, due to unavoidable

increases in emissions attributable to the emergency. An emergency shall not include

noncompliance to the extent caused by improperly designed equipment, lack of

preventative maintenance, careless or improper operation, or operator error.

3. An emergency constitutes an affirmative defense to an action brought for noncompliance

with such technology-based emission limitations if the conditions of the following

subparagraph are met.

4. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs, or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s) of the

emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of emergency the permittee took all reasonable steps to

minimize levels of emissions that exceeded the emissions standards or other

requirements in the permit; and

d. The permittee submitted notice of the emergency to the Control Officer by

certified mail or hand delivery within 2 working days of the time when

emissions limitations were exceeded due to emergency. The notice shall contain

a description of the emergency, any steps taken to mitigate emissions, and

corrective action taken.

10. Equipment

A. Permitted equipment

Equipment for which emissions are allowed by this permit are as follows:

ID Equipment/Process Rating

(MMBtu/hr) Fuel Type Manufacturer

VOC Processes

A01 Cleaner Stage Eisenmann

A02 Pre Treatment Stage Eisenmann

A03 E-Coat Eisenmann

A04 Sealers Eisenmann

A05 Antichip Eisenmann

A06 Liquid Applied Sound Deadener

(LASD) Eisenmann


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A07 Foam

A08 Primer Eisenmann

A09 Basecoat Eisenmann

A10 Clearcoat Eisenmann

A11 In Line Reprocess – Finesse

(Spot Repair In Paint Shop) Eisenmann

A12 Final Line Reprocess

(Spot Repair In General Assembly) Eisenmann

A13 Chemical Management

A14 Wax Line Eisenmann

A15 Paint Shop - Others

A16 Body Shop

A17 General Assembly - Others

Ovens

B01 ED Oven 1 6.761 Natural Gas Eisenmann

B02 Sealer Oven 1.690 Natural Gas Eisenmann

B03 Primer Oven 2.817 Natural Gas Eisenmann

B04 Heated Flash Oven 1 1.690 Natural Gas Eisenmann

B05 Top Coat Oven 2.817 Natural Gas Eisenmann

Emission Control Devices

B06 ADR 1.024 Natural Gas Eisenmann

B07 RTO 1 2.151 Natural Gas Eisenmann

Water Boilers

C01 Water Boiler Paint Shop 14 Natural Gas Cleaver Brooks




Air Rotation Units

C05 AHU Body Shop 1.25 Natural Gas ICE




C09 AHU Assembly 1.25 Natural Gas ICE

C10 AHU General Assembly 1.25 Natural Gas ICE



Emergency Generators

D01 Emergency Generator 463 hp Diesel John Deere



31







Firewater Pump

FWP01 Firewater Pump 575 hp Diesel Aurora

Fugitive Dust

FD1 Vehicle Test Track

B. Insignificant Activities

1. Five diesel storage tanks, each with capability of 40,000 gallons or less

2. Manual sanding and welding

3. Hand held aerosol can spray painting

4. Lab equipment used exclusively for chemical and physical analyses

5. Building maintenance and janitorial activites

11. Emission Inventory Table

See technical support document (TSD)


32


Appendix A: Semi-Annual Report

Permit C31230.000

Abstract

This constitutes an annual report, documenting emissions and use of emission-generating materials during the

subject reporting period.

Facility - Atieva USA, INC

Lucid Motors

S.W. corner of Peters and Thorton Road, Casa Grande, AZ 85122

Reporting Period - January to June ☐ or July to December ☐ Year ______

Parametric emissions report

Natural gas burned during reporting period ..................................................................... therms

Emissions report

Volatile organic compounds emitted during reporting period ............................................. Tons

HAP emissions emitted during reporting period ................................. Total HAPs _________________ tons

Highest Single HAP ____________________________________________ name ________________ tons

Operations report

Did any ADR/RTO by-pass events occur (§4.B.5)? Yes ☐ No ☐

If yes what were the estimated VOC and HAP emissions? ________ tons of HAP ________ tons of VOC

Were the VOC cap of 80 tpy, individual HAPs cap of 8 tpy or total HAP cap of 20 tpy exceeded (§5.C.2)?

Yes ☐ No ☐

Did the RTO rolling 1-hour average combustion zone temperature fall below 1450oF (§5.E.3)? Yes ☐ No ☐

If any three-hour period 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 submit the report required by §6.E.2.

Did the pressure drop across the ADR exceed 12 mbar (§5.F.2)? Yes ☐ No ☐

Did the ADR desorption temperature fall below 370oF (§5.F.2)? Yes ☐ No ☐

Were open and vacant areas stabilized (§5.L)? Yes ☐ No ☐

Were the NSPS Subpart MM VOC limits met (§5.M)? Yes ☐ No ☐

Records and Monitoring

Were the VOC and HAP records and reports maintained (§6.A)? Yes ☐ No ☐

Were the opacity screens conducted (§6.B.3)? Yes ☐ No ☐

Were the daily spray booth inspections and checks conducted (§6.C.1)? Yes ☐ No ☐


33


Were the daily and annual inspections of the ADR and RTO conducted (§6.C.2)? Yes ☐ No ☐

Were the NSPS Subpart MM records and reports maintained and submitted (§6.E)? Yes ☐ No ☐

Were the NSPS Subpart MM calculations performed (§6.F)? Yes ☐ No ☐

Testing

Was the annual RTO test conducted (§6.H.2)? Yes ☐ No ☐

Was the annual ADR test conducted (§6.H.3)? Yes ☐ No ☐

Has the HAP testing been conducted within the last 60 months (§6.H.2)? Yes ☐ No ☐

Was the capture efficiency testing conducted (§6.H.4)? Yes ☐ No ☐

Reporting

Were any deviations reported for this period (§7.A)? Yes ☐ No ☐

Were the initial notifications submitted (§7.B)? Yes ☐ No ☐

Was the annual emission inventory submitted (§7.C)? Yes ☐ No ☐

Certification by Responsible Official

I certify that, based on information and belief formed after reasonable inquiry, that the statements and information in

this report are true, accurate and complete.

Signed ____________________________________________

Print Name ________________________________________

Title ______________________________________________

Date_____________ Contact Phone Number _____________________

Mail to - Pinal County Air Quality Control District

PO Box 987

Florence, AZ 85132

Date post:	25-Apr-2018
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