notice of decision: approval -effective immediatelypermits.air.idem.in.gov/36237f.pdfvaleo north...

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Michael R. Pence Carol S. Comer Governor Commissioner

An Equal Opportunity Employer

Recycled Paper

To: Interested Parties Date: December 28, 2015 From: Matthew Stuckey, Chief Permits Branch Office of Air Quality Source Name: Valeo North America, Inc. Permit Level: Federally Enforceable State Operating Permit (FESOP) Significant Permit Revision Permit Number: 031-36237-00014 Source Location: 1100 East Barachel Lane Greensburg, Indiana Type of Action Taken: Modification at an existing source Revisions to permit requirements

Notice of Decision: Approval - Effective Immediately

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, I have issued a decision regarding the matter referenced above. The final decision is available on the IDEM website at: http://www.in.gov/apps/idem/caats/ To view the document, select Search option 3, then enter permit 36237. If you would like to request a paper copy of the permit document, please contact IDEM’s central file room:

Indiana Government Center North, Room 1201 100 North Senate Avenue, MC 50-07 Indianapolis, IN 46204 Phone: 1-800-451-6027 (ext. 4-0965) Fax (317) 232-8659

Pursuant to IC 13-15-5-3, this permit is effective immediately, unless a petition for stay of effectiveness is filed and granted according to IC 13-15-6-3, and may be revoked or modified in accordance with the provisions of IC 13-15-7-1.

(continues on next page)

If you wish to challenge this decision, IC 4-21.5-3 and IC 13-15-6-1 require that you file a petition for administrative review. This petition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204, within eighteen (18) calendar days of the mailing of this notice. The filing of a petition for administrative review is complete on the earliest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope containing the document, if the document is mailed to

OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued

by the carrier, if the document is sent to the OEA by private carrier. The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons represented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and (6) identification of the terms and conditions which, in the judgment of the person making the

request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.

If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451-6027, ext. 3-0178.

Enclosures Final-Permit 4/4/14

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 2 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers

TABLE OF CONTENTS

SECTION A SOURCE SUMMARY ......................................................................................................... 4

A.1 General Information [326 IAC 2-8-3(b)] A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)] A.3 Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-8-3(c)(3)(I)] A.4 FESOP Applicability [326 IAC 2-8-2]

SECTION B GENERAL CONDITIONS ................................................................................................. 10

B.1 Definitions [326 IAC 2-8-1] B.2 Permit Term [326 IAC 2-8-4(2)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)] B.3 Term of Conditions [326 IAC 2-1.1-9.5] B.4 Enforceability [326 IAC 2-8-6][IC 13-17-12] B.5 Severability [326 IAC 2-8-4(4)] B.6 Property Rights or Exclusive Privilege [326 IAC 2-8-4(5)(D)] B.7 Duty to Provide Information [326 IAC 2-8-4(5)(E)] B.8 Certification [326 IAC 2-8-3(d)][326 IAC 2-8-4(3)(C)(i)][326 IAC 2-8-5(1)] B.9 Annual Compliance Certification [326 IAC 2-8-5(a)(1)] B.10 Compliance Order Issuance [326 IAC 2-8-5(b)] B.11 Preventive Maintenance Plan [326 IAC 1-6-3][326 IAC 2-8-4(9)] B.12 Emergency Provisions [326 IAC 2-8-12] B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] B.14 Termination of Right to Operate [326 IAC 2-8-9][326 IAC 2-8-3(h)] B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326

IAC 2-8-4(5)(C)][326 IAC 2-8-7(a)][326 IAC 2-8-8] B.16 Permit Renewal [326 IAC 2-8-3(h)] B.17 Permit Amendment or Revision [326 IAC 2-8-10][326 IAC 2-8-11.1] B.18 Operational Flexibility [326 IAC 2-8-15][326 IAC 2-8-11.1] B.19 Source Modification Requirement [326 IAC 2-8-11.1] B.20 Inspection and Entry [326 IAC 2-8-5(a)(2)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] B.21 Transfer of Ownership or Operational Control [326 IAC 2-8-10] B.22 Annual Fee Payment [326 IAC 2-7-19][326 IAC 2-8-4(6)][326 IAC 2-8-16][326 IAC 2-

1.1-7] B.23 Credible Evidence [326 IAC 2-8-4(3)][326 IAC 2-8-5][62 FR 8314][326 IAC 1-1-6]

SECTION C SOURCE OPERATION CONDITIONS ............................................................................. 20

Emission Limitations and Standards [326 IAC 2-8-4(1)] ......................................................... 20 C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less

Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2] C.2 Overall Source Limit [326 IAC 2-8] C.3 Opacity [326 IAC 5-1] C.4 Open Burning [326 IAC 4-1][IC 13-17-9] C.5 Incineration [326 IAC 4-2][326 IAC 9-1-2] C.6 Fugitive Dust Emissions [326 IAC 6-4] C.7 Asbestos Abatement Projects [326 IAC 14-10][326 IAC 18][40 CFR 61, Subpart M] C.8 Performance Testing [326 IAC 3-6] C.9 Compliance Requirements [326 IAC 2-1.1-11] C.10 Compliance Monitoring [326 IAC 2-8-4(3)][326 IAC 2-8-5(a)(1)] C.11 Instrument Specifications [326 IAC 2-1.1-11][326 IAC 2-8-4(3)][326 IAC 2-8-5(1)] Corrective Actions and Response Steps [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)] ..................... 24 C.12 Risk Management Plan [326 IAC 2-8-4][40 CFR 68] C.13 Response to Excursions or Exceedances [326 IAC 2-8-4][326 IAC 2-8-5] C.14 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-8-

4][326 IAC 2-8-5]


Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] ......................................... 25 C.15 General Record Keeping Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-5] C.16 General Reporting Requirements [326 IAC 2-8-4(3)(C)][326 IAC 2-1.1-11] Stratospheric Ozone Protection ................................................................................................. 26 C.17 Compliance with 40 CFR 82 and 326 IAC 22-1

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS .............................................................. 27

Emission Limitations and Standards [326 IAC 2-8-4(1)] .......................................................... 30 D.1.1 BACT Limit [326 IAC 8-1-6] D.1.2 FESOP Minor Limits [326 IAC 2-8-4] D.1.3 Particulate [326 IAC 6-3] D.1.4 Incinerators [326 IAC 4-2-2] D.1.5 Preventive Maintenance Plan [326 IAC 2-8-4(9)] Compliance Determination Requirements [326 IAC 2-8-4(1)] ................................................. 32 D.1.6 Volatile Organic Compounds (VOC) [326 IAC 8-1-2][326 IAC 8-1-4] D.1.7 Particulate Control D.1.8 VOC Control D.1.9 Testing Requirements [326 IAC 2-1.1-11] D.1.10 VOC Emissions Compliance Monitoring Requirements [326 IAC 2-8-4(1)][326 IAC 2-8-5(a)(1)] ..................... 33 D.1.11 Vorcinerator Afterburner Temperature D.1.12 Parametric Monitoring - Vorcinerator Afterburner Duct Pressure or Fan Amperage Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-16] ............... 34 D.1.13 Record Keeping Requirements D.1.14 Reporting Requirements

SECTION D.2 EMISSION UNIT OPERATION CONDITIONS ................................................................. 36 Emission Limitations and Standards [326 IAC 2-8-4(1)] .......................................................... 36 D.2.1 Particulate [326 IAC 6-2-4]

SECTION D.3 EMISSION UNIT OPERATION CONDITIONS ................................................................. 37

Emission Limitations and Standards [326 IAC 2-8-4(1)] .......................................................... 37 D.3.1 Particulate [326 IAC 6-3-2] D.3.2 Preventive Maintenance Plan [326 IAC 2-8-4(9)] Compliance Determination Requirements [326 IAC 2-8-4(1)] ................................................. 37 D.3.3 Particulate Control

CERTIFICATION ........................................................................................................................................ 38

EMERGENCY OCCURRENCE REPORT .................................................................................................. 39 FESOP Quarterly Report .......................................................................................................................... 41

FESOP Quarterly Report .......................................................................................................................... 42

FESOP Quarterly Report .......................................................................................................................... 43

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT .............................................. 44

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 4 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 through A.4 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application. A.1 General Information [326 IAC 2-8-3(b)]

The Permittee owns and operates a stationary automotive condenser, radiator, and cooling module fabrication operation.

Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 General Source Phone Number: (812) 527-3028 SIC Code: 3714 (Other Motor Vehicle Parts Manufacturing) County Location: Decatur Source Location Status: Attainment for all criteria pollutants Source Status: Federally Enforceable State Operating Permit Program

Minor Source, under PSD and Emission Offset Rules Minor Source, Section 112 of the Clean Air Act Not 1 of 28 Source Categories

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)]

This stationary source consists of the following emission units and pollution control devices: (a) One (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process,

consisting of the following: (1) One (1) Core assembly process, identified as Core Assembly, constructed in

1995, consisting of associated fin mills, core builders, tube mills, turbulators, and other related equipment, using evaporative oils containing no more than of two and four tenths (2.4) pounds of VOC per gallon of oil, uncontrolled and exhausting inside the building. This process was approved for modification in 2013 for construction of an additional tube mill. Alternative Operating Scenario 1 (AOS1): Approved in 2015 for modification, for the use of evaporative oils containing no more than four and eighty-four hundredths (4.84) pounds of VOC per gallon of oil when the Core assembly process is operating in conjunction with Braze Line #8 radiator production, with VOC emissions controlled by the Braze Line #8 Vorcinerator afterburner. The equipment under the core assembly process is not stationary and can be moved from one location to another within the facility depending on the production needs.

(2) One (1) braze line, identified as Braze Line #1, constructed in 1991, with a

maximum capacity of two hundred (200) aluminum cores (2,000 pounds) per hour and consisting of the following:


(A) One (1) natural gas-fired core conditioning oven with a maximum heat input capacity of three and two tenths (3.2) MMBtu per hour, uncontrolled and exhausting at stack PE-20;

(B) One (1) spray fluxer with a maximum capacity of eleven (11.0) pounds of

flux per hour, uncontrolled and exhausting outside the building; (C) One (1) natural gas-fired flux dry-off oven a maximum heat input capacity

of one and two tenths (1.2) MMBtu per hour, uncontrolled and exhausting at stack PE-22; and

(D) One (1) nitrogen electric braze oven and cool down station, uncontrolled

and exhausting at stacks PE-23 and PE-24, respectively.

(3) One (1) super braze line, identified as Braze Line #2, constructed in 1995, approved for modification in 2013, with a maximum capacity of two hundred fifty (250) aluminum cores (7,600 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting at stack PE-31;

(B) One (1) nitrogen electric braze oven and cool down station, uncontrolled

and exhausting at stacks PE-35 and PE-36, respectively. (4) One (1) braze line, identified as Braze Line #3, constructed in 1996, with a

maximum capacity of two hundred fifty (250) aluminum cores (3,800 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting at stack PE-44;



of one and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-47; and



maximum capacity of one hundred thirty (130) aluminum cores (2,250 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of two and five tenths (2.5) MMBtu per hour, uncontrolled and exhausting at stack PE-59;


flux per hour, uncontrolled and exhausting outside the building;


(C) One (1) natural gas-fired flux dry-off oven a maximum heat input capacity of one and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-62; and



maximum capacity of five hundred (500) aluminum cores (7,500 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting to stack PE-600A, B;



of one and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-602; and

(D) One (1) nitrogen electric braze oven and cool down station exhausting at

stacks PE-603A and PE-603B, respectively. (7) One (1) braze line, identified as Braze Line #8, constructed in 2009 and

approved in 2015 for modification, with a maximum capacity of two hundred (200) radiators (5,718 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, with VOC emissions controlled by a Vorcinerator afterburner, and exhausting at stack PE-59;

(B) One (1) spray fluxer with a maximum capacity of eighty-eight (88.0)

pounds (40,000 grams) of flux per hour, uncontrolled and exhausting outside the building;

(C) One (1) natural gas-fired flux dry-off oven with a maximum heat input

capacity of eight tenths (0.8) MMBtu per hour and exhausting at stack PE-702;

(D) One (1) natural gas-fired braze furnace convection pre-heat chamber

with a maximum input capacity of two (2.0) MMBtu per hour, uncontrolled and exhausting at stack PE-702; and

(E) One (1) electric braze oven and cool down station, uncontrolled and

exhausting at stacks PE-703A and PE-703B, respectively. (8) Powder coating operations including the following:

(A) One (1) electrostatic powder paint booth and filter system, identified as

paint booth #2, constructed in 1989 and approved in 2015 for modification, with a maximum material usage rate of sixty (60.00) pounds of paint per hour, controlled by one (1) integral cartridge filter system used to reclaim the unused powder paint for reuse, and a second filter system for particulate control, and exhausting inside the building;


(B) One (1) natural gas-fired paint dry-off oven, identified as Paint Bake

Oven 1, constructed in 1989, with a maximum heat input capacity of one and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-605; and

(C) One (1) natural gas-fired paint hook burn-off oven, constructed in 1989,

with a maximum heat input capacity of four hundred seventy-five thousandths (0.475) MMBtu per hour, uncontrolled and exhausting at stack PE-28.

(D) One (1) paint bake oven, identified as Paint Bake Oven 2, approved in

2015 for construction, with a maximum heat input capacity of 3.00 MMBtu/hr, uncontrolled and exhausting to a stack.

(9) Two (2) robotic arc welders, each with a maximum electrode consumption of two

and one tenth (2.1) pounds per hour, uncontrolled and exhausting inside the building.

(10) One (1) tube mill with brazing and fluxing stations, constructed in 2014,

consisting of the following units: (A) One (1) brazing station, with a maximum capacity of 700,000 aluminum

tubes (5250 tons) per year, and using an electric braze oven. (B) One (1) flux station, with a maximum capacity of 1.35 gallons per hour of

oil and flux, using filters as particulate control, and exhausting to stacks PE-901 through PE-910.

(11) One (1) spray fluxer, identified as Stand-Alone Spray Fluxer, with a maximum

capacity of eleven (11.0) pounds of flux per hour, uncontrolled and exhausting outside the building.

(b) One (1) abrasive blast booth, identified as blast booth, constructed in September 2008, with a maximum blasting rate of 1,000 lbs/hr, using a filter as control, and exhausting indoors.

(c) One (1) injection molding manufacturing and treating operation consisting of the

following:

(1) One (1) Engel 1900 T Duo 16050 injection molding machine, identified as IM1, permitted in 2014, with a maximum capacity of 1,000 pounds per hour of polypropylene resin (reactor grade homopolymer), uncontrolled and exhausting indoors.

(2) One (1) Engel Duo 4550 770 T injection molding machine, identified as IM2,

permitted in 2014, with a maximum capacity of 500 pounds per hour of polypropylene resin (reactor grade homopolymer), uncontrolled and exhausting indoors.

(3) One (1) molding treatment station, identified as molding treatment, permitted in

2014, with a maximum throughput of 0.1 gallons per day of mold cleaner, 0.1 gallons per day of mold release, and 0.1 gallons per day of mold shield rust preventative, each dispensed from 12-ounce aerosol spray cans, uncontrolled and exhausting indoors.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 8 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers A.3 Insignificant Activities [326 IAC 2-7-1(21)][326 IAC 2-8-3(c)(3)(I)]

This stationary source also includes the following insignificant activities: (a) One (1) natural gas-fired boiler, installed in 2001, with a maximum heat input capacity of

one and forty-six tenths (1.46) MMBtu per hour, uncontrolled and exhausting inside the building. [326 IAC 6-2-4]

(b) Brazing equipment, cutting torches, soldering equipment, welding equipment.

[326 IAC 6-3] (c) Paved and unpaved roads and parking lots with public access. [326 IAC 6-4] (d) Combustion source flame safety purging on startup. (e) Storage tanks with capacity less than or equal to 1,000 gallons and annual throughputs

less than 12,000 gallons. (f) Vessels storing lubricating oils, hydraulic oils, machining oils, and machining fluids. (g) Application of oils, greases, lubricants, or other nonvolatile materials applied as

temporary protective coatings. (h) Machining where an aqueous cutting coolant continuously floods the machining interface. (i) Cleaners and solvents having a vapor pressure equal to less than two (2.0) kPa; fifteen

(15) mm Hg; or two (2.0) psi measured at thirty-eight (38 ºC) degrees Celsius (100 ºF). (j) Closed loop heating and cooling system. (k) Forced and induced draft cooling tower system not regulated under a NESHAP. (l) Quenching operations used with heat treating processes. (m) Heat exchanger cleaning and repair. (n) Process vessel degassing and cleaning to prepare for internal repairs. (o) Purging of gas lines and vessels that is related to routine maintenance and repair of

buildings, structures, or vehicles at the source where air emissions from those activities would not be associated with any production process.

(p) Equipment used to collect any material that might be released during a malfunction,

process upset, or spill cleanup, including catch tanks, temporary liquid separators, tanks, and fluid handling equipment.

(q) Blow-down for any of the following: sight glass, boiler, compressors, pumps, and cooling

tower. (r) On-site fire and emergency response training approved by the department. (s) Stationary fire pumps. (t) Four (4) natural gas fired air handlers, identified as #1 through #4, each constructed in

1989, each with a heat input capacity of 2.475 MMBtu/hr, each using no controls, and each exhausting indoors


(u) Two (2) natural gas fired air handlers, identified as #5 and #6, each constructed in 1989, each with a heat input capacity of 3.013 MMBtu/hr, each using no controls, and each exhausting indoors.

(v) Two (2) natural gas fired air handlers, identified as #7 and #8, each constructed in 1995, each with a maximum heat input capacity of 2.475 MMBtu/hr, each using no controls, and each exhausting indoors.

(w) Two (2) natural gas fired air handlers, identified as #9 and #10, each constructed in 1998,

each with a maximum heat input capacity of 3.575 MMBtu/hr, each using no controls, and each exhausting indoors.

(x) Two (2) natural gas fired air handlers, identified as #11 and #12, each constructed in

2000, each with a maximum heat input capacity of 3.575 MMBtu/hr, each using no controls, and each exhausting indoors.

(y) One (1) natural gas fired air handler, identified as #13(Prototype), constructed in 2000,

with a heat input capacity of 1.65 MMBtu/hr, using no controls, and exhausting indoors.

A.4 FESOP Applicability [326 IAC 2-8-2] This stationary source, otherwise required to have a Part 70 permit as described in 326 IAC 2-7-2(a), has applied to the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ) to renew a Federally Enforceable State Operating Permit (FESOP).

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 10 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-8-1] Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail.

B.2 Permit Term [326 IAC 2-8-4(2)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)]

(a) This permit, F031-29500-00014, is issued for a fixed term of ten (10) years from the issuance date of this permit, as determined in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date of this permit.

(b) If IDEM, OAQ, upon receiving a timely and complete renewal permit application, fails to

issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, until the renewal permit has been issued or denied.

B.3 Term of Conditions [326 IAC 2-1.1-9.5]

Notwithstanding the permit term of a permit to construct, a permit to operate, or a permit modification, any condition established in a permit issued pursuant to a permitting program approved in the state implementation plan shall remain in effect until: (a) the condition is modified in a subsequent permit action pursuant to Title I of the Clean Air

Act; or (b) the emission unit to which the condition pertains permanently ceases operation.

B.4 Enforceability [326 IAC 2-8-6][IC 13-17-12]

Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to emit, are enforceable by IDEM, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act.

B.5 Severability [326 IAC 2-8-4(4)]

The provisions of this permit are severable; a determination that any portion of this permit is invalid shall not affect the validity of the remainder of the permit.

B.6 Property Rights or Exclusive Privilege [326 IAC 2-8-4(5)(D)]

This permit does not convey any property rights of any sort or any exclusive privilege. B.7 Duty to Provide Information [326 IAC 2-8-4(5)(E)]

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ 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. Upon request, the Permittee shall also furnish to IDEM, OAQ copies of records required to be kept by this permit.

(b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.

B.8 Certification [326 IAC 2-8-3(d)][326 IAC 2-8-4(3)(C)(i)][326 IAC 2-8-5(1)]

(a) A certification required by this permit meets the requirements of 326 IAC 2-8-5(a)(1) if:


(1) it contains a certification by an "authorized individual", as defined by 326 IAC 2-1.1-1(1), and

(2) the certification states that, based on information and belief formed after

reasonable inquiry, the statements, and information in the document are true, accurate, and complete.

(b) The Permittee may use the attached Certification Form, or its equivalent, with each

submittal requiring certification. One (1) certification may cover multiple forms in one (1) submittal.

(c) An "authorized individual" is defined at 326 IAC 2-1.1-1(1).

B.9 Annual Compliance Certification [326 IAC 2-8-5(a)(1)]

(a) The Permittee shall annually submit a compliance certification report which addresses the status of the source's compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices. All certifications shall cover the time period from January 1 to December 31 of the previous year, and shall be submitted no later than July 1 of each year to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) The annual compliance certification report required by this permit shall be considered

timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) The annual compliance certification report shall include the following:

(1) The appropriate identification of each term or condition of this permit that is the

basis of the certification; (2) The compliance status; (3) Whether compliance was continuous or intermittent; (4) The methods used for determining the compliance status of the source, currently

and over the reporting period consistent with 326 IAC 2-8-4(3); and (5) Such other facts, as specified in Sections D of this permit, as IDEM, OAQ may

require to determine the compliance status of the source. The submittal by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

B.10 Compliance Order Issuance [326 IAC 2-8-5(b)]

IDEM, OAQ may issue a compliance order to this Permittee upon discovery that this permit is in nonconformance with an applicable requirement. The order may require immediate compliance or contain a schedule for expeditious compliance with the applicable requirement.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 12 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers B.11 Preventive Maintenance Plan [326 IAC 1-6-3][326 IAC 2-8-4(9)]

(a) A Preventive Maintenance Plan meets the requirements of 326 IAC 1-6-3 if it includes, at a minimum: (1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement. The Permittee shall implement the PMPs.

(b) If required by specific condition(s) in Section D of this permit where no PMP was

previously required, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMPs) no later than ninety (90) days after issuance of this permit or ninety (90) days after initial start-up, whichever is later, including the following information on each facility: (1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement. If, due to circumstances beyond the Permittee's control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The PMP extension notification does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). The Permittee shall implement the PMPs.

(c) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and within a

reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions. The PMPs and their submittal do not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).


(d) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation, Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.

B.12 Emergency Provisions [326 IAC 2-8-12]

(a) An emergency, as defined in 326 IAC 2-7-1(12), is not an affirmative defense for an action brought for noncompliance with a federal or state health-based emission limitation except as provided in 326 IAC 2-8-12.

(b) An emergency, as defined in 326 IAC 2-7-1(12), constitutes an affirmative defense to an

action brought for noncompliance with a health-based or technology-based emission limitation if the affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that describe the following: (1) An emergency occurred and the Permittee can, to the extent possible, identify

the causes of the emergency; (2) The permitted facility was at the time being properly operated; (3) During the period of an emergency, the Permittee took all reasonable steps to

minimize levels of emissions that exceeded the emission standards or other requirements in this permit;

(4) For each emergency lasting one (1) hour or more, the Permittee notified IDEM,

OAQ, or Southeast Regional Office within four (4) daytime business hours after the beginning of the emergency, or after the emergency was discovered or reasonably should have been discovered; Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, Compliance and Enforcement Branch), or Telephone Number: 317-233-0178 (ask for Office of Air Quality, Compliance and Enforcement Branch) Facsimile Number: 317-233-6865 Southeast Regional Office phone: (812) 358-2027; fax: (812) 358-2058.

(5) For each emergency lasting one (1) hour or more, the Permittee submitted the

attached Emergency Occurrence Report Form or its equivalent, either by mail or facsimile to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 within two (2) working days of the time when emission limitations were exceeded due to the emergency. The notice fulfills the requirement of 326 IAC 2-8-4(3)(C)(ii) and must contain the following: (A) A description of the emergency; (B) Any steps taken to mitigate the emissions; and


(C) Corrective actions taken. The notification which shall be submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(6) The Permittee immediately took all reasonable steps to correct the emergency.

(c) In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of proof.

(d) This emergency provision supersedes 326 IAC 1-6 (Malfunctions). This permit condition is in addition to any emergency or upset provision contained in any applicable requirement.

(e) The Permittee seeking to establish the occurrence of an emergency shall make records available upon request to ensure that failure to implement a PMP did not cause or contribute to an exceedance of any limitations on emissions. However, IDEM, OAQ may require that the Preventive Maintenance Plans required under 326 IAC 2-8-3(c)(6) be revised in response to an emergency.

(f) Failure to notify IDEM, OAQ by telephone or facsimile of an emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this condition shall constitute a violation of 326 IAC 2-8 and any other applicable rules.

(g) Operations may continue during an emergency only if the following conditions are met:

(1) If the emergency situation causes a deviation from a technology-based limit, the

Permittee may continue to operate the affected emitting facilities during the emergency provided the Permittee immediately takes all reasonable steps to correct the emergency and minimize emissions.

(2) If an emergency situation causes a deviation from a health-based limit, the

Permittee may not continue to operate the affected emissions facilities unless:

(A) The Permittee immediately takes all reasonable steps to correct the emergency situation and to minimize emissions; and

(B) Continued operation of the facilities is necessary to prevent imminent

injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw material of substantial economic value.

Any operations shall continue no longer than the minimum time required to prevent the situations identified in (g)(2)(B) of this condition.

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5]

(a) All terms and conditions of permits established prior to F031-29500-00014 and issued pursuant to permitting programs approved into the state implementation plan have been either: (1) incorporated as originally stated, (2) revised, or


(3) deleted.

(b) All previous registrations and permits are superseded by this permit. B.14 Termination of Right to Operate [326 IAC 2-8-9][326 IAC 2-8-3(h)]

The Permittee's right to operate this source terminates with the expiration of this permit unless a timely and complete renewal application is submitted at least nine (9) months prior to the date of expiration of the source's existing permit, consistent with 326 IAC 2-8-3(h) and 326 IAC 2-8-9.

B.15 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-8-

4(5)(C)][326 IAC 2-8-7(a)][326 IAC 2-8-8] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause.

The filing of a request by the Permittee for a Federally Enforceable State Operating Permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-8-4(5)(C)] The notification by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-15-7-2 or if IDEM, OAQ determines any of the following: (1) That this permit contains a material mistake. (2) That inaccurate statements were made in establishing the emissions standards

or other terms or conditions. (3) That this permit must be revised or revoked to assure compliance with an

applicable requirement. [326 IAC 2-8-8(a)]

(c) Proceedings by IDEM, OAQ to reopen and revise this permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. Such reopening and revision shall be made as expeditiously as practicable. [326 IAC 2-8-8(b)]

(d) The reopening and revision of this permit, under 326 IAC 2-8-8(a), shall not be initiated before notice of such intent is provided to the Permittee by IDEM, OAQ at least thirty (30) days in advance of the date this permit is to be reopened, except that IDEM, OAQ may provide a shorter time period in the case of an emergency. [326 IAC 2-8-8(c)]

B.16 Permit Renewal [326 IAC 2-8-3(h)]

(a) The application for renewal shall be submitted using the application form or forms prescribed by IDEM, OAQ and shall include the information specified in 326 IAC 2-8-3. Such information shall be included in the application for each emission unit at this source, except those emission units included on the trivial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).


Request for renewal shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) A timely renewal application is one that is:

(1) Submitted at least nine (9) months prior to the date of the expiration of this permit; and

(2) If the date postmarked on the envelope or certified mail receipt, or affixed by the

shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) If the Permittee submits a timely and complete application for renewal of this permit, the

source's failure to have a permit is not a violation of 326 IAC 2-8 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-8-3(g), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.17 Permit Amendment or Revision [326 IAC 2-8-10][326 IAC 2-8-11.1] (a) Permit amendments and revisions are governed by the requirements of 326 IAC 2-8-10

or 326 IAC 2-8-11.1 whenever the Permittee seeks to amend or modify this permit.

(b) Any application requesting an amendment or modification of this permit shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 Any such application does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-8-10(b)(3)]

B.18 Operational Flexibility [326 IAC 2-8-15][326 IAC 2-8-11.1] (a) The Permittee may make any change or changes at the source that are described in 326

IAC 2-8-15(b) and (c) without a prior permit revision, if each of the following conditions is met: (1) The changes are not modifications under any provision of Title I of the Clean Air

Act; (2) Any approval required by 326 IAC 2-8-11.1 has been obtained;


(3) The changes do not result in emissions which exceed the limitations provided in this permit (whether expressed herein as a rate of emissions or in terms of total emissions);

(4) The Permittee notifies the:

Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 and United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590 in advance of the change by written notification at least ten (10) days in advance of the proposed change. The Permittee shall attach every such notice to the Permittee's copy of this permit; and

(5) The Permittee maintains records on-site, on a rolling five (5) year basis, which document all such changes and emission trades that are subject to 326 IAC 2-8-15(b)(1) and (c). The Permittee shall make such records available, upon reasonable request, for public review.

Such records shall consist of all information required to be submitted to IDEM, OAQ in the notices specified in 326 IAC 2-8-15(b)(1) and (c).

(b) Emission Trades [326 IAC 2-8-15(b)]

The Permittee may trade emissions increases and decreases at the source, where the applicable SIP provides for such emission trades without requiring a permit revision, subject to the constraints of Section (a) of this condition and those in 326 IAC 2-8-15(b).

(c) Alternative Operating Scenarios [326 IAC 2-8-15(c)] The Permittee may make changes at the source within the range of alternative operating scenarios that are described in the terms and conditions of this permit in accordance with 326 IAC 2-8-4(7). No prior notification of IDEM, OAQ, or U.S. EPA is required.

(d) Backup fuel switches specifically addressed in, and limited under, Section D of this permit shall not be considered alternative operating scenarios. Therefore, the notification requirements of part (a) of this condition do not apply.

B.19 Source Modification Requirement [326 IAC 2-8-11.1]

A modification, construction, or reconstruction is governed by the requirements of 326 IAC 2.

B.20 Inspection and Entry [326 IAC 2-8-5(a)(2)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee's right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized representative to perform the following:


(a) Enter upon the Permittee's premises where a FESOP source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit;

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

(c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit;

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.

B.21 Transfer of Ownership or Operational Control [326 IAC 2-8-10]

(a) The Permittee must comply with the requirements of 326 IAC 2-8-10 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.

(b) Any application requesting a change in the ownership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and new Permittee. The application shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 Any such application does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-8-10(b)(3)]

B.22 Annual Fee Payment [326 IAC 2-7-19][326 IAC 2-8-4(6)][326 IAC 2-8-16][326 IAC 2-1.1-7]

(a) The Permittee shall pay annual fees to IDEM, OAQ no later than thirty (30) calendar days of receipt of a billing. Pursuant to 326 IAC 2-7-19(b), if the Permittee does not receive a bill from IDEM, OAQ the applicable fee is due April 1 of each year.

(b) Failure to pay may result in administrative enforcement action or revocation of this permit. (c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233-

4230 (ask for OAQ, Billing, Licensing, and Training Section), to determine the appropriate permit fee.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 19 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers B.23 Credible Evidence [326 IAC 2-8-4(3)][326 IAC 2-8-5][62 FR 8314][326 IAC 1-1-6]

For the purpose of submitting compliance certifications or establishing whether or not the Permittee has violated or is in violation of any condition of this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether the Permittee would have been in compliance with the condition of this permit if the appropriate performance or compliance test or procedure had been performed.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 20 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION C SOURCE OPERATION CONDITIONS

Entire Source

Emission Limitations and Standards [326 IAC 2-8-4(1)]

C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less Than One Hundred (100) Pounds per Hour [326 IAC 6-3-2] Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process not exempt under 326 IAC 6-3-1(b) or (c) which has a maximum process weight rate less than 100 pounds per hour and the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per hour.

C.2 Overall Source Limit [326 IAC 2-8] The purpose of this permit is to limit this source's potential to emit to less than major source levels for the purpose of Section 502(a) of the Clean Air Act. (a) Pursuant to 326 IAC 2-8:

(1) The potential to emit any regulated pollutant, except particulate matter (PM) and

greenhouse gases (GHGs), from the entire source shall be limited to less than one hundred (100) tons per twelve (12) consecutive month period.

(2) The potential to emit any individual hazardous air pollutant (HAP) from the entire

source shall be limited to less than ten (10) tons per twelve (12) consecutive month period; and

(3) The potential to emit any combination of HAPs from the entire source shall be

limited to less than twenty-five (25) tons per twelve (12) consecutive month period.

(4) The potential to emit greenhouse gases (GHGs) from the entire source shall be

limited to less than one hundred thousand (100,000) tons of CO2 equivalent emissions (CO2e) per twelve (12) consecutive month period.

(b) Pursuant to 326 IAC 2-2 (PSD), potential to emit particulate matter (PM) from the entire

source shall be limited to less than two hundred fifty (250) tons per twelve (12) consecutive month period.

(c) This condition shall include all emission points at this source including those that are

insignificant as defined in 326 IAC 2-7-1(21). The source shall be allowed to add insignificant activities not already listed in this permit, provided that the source's potential to emit does not exceed the above specified limits.

(d) Section D of this permit contains independently enforceable provisions to satisfy this

requirement.

C.3 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-1 (Applicability) and 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute

averaging period as determined in 326 IAC 5-1-4.


(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

C.4 Open Burning [326 IAC 4-1][IC 13-17-9] The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-1-4, or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1.

C.5 Incineration [326 IAC 4-2][326 IAC 9-1-2]

The Permittee shall not operate an incinerator except as provided in 326 IAC 4-2 or in this permit. The Permittee shall not operate a refuse incinerator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

C.6 Fugitive Dust Emissions [326 IAC 6-4]

The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions).

C.7 Asbestos Abatement Projects [326 IAC 14-10][326 IAC 18][40 CFR 61, Subpart M] (a) Notification requirements apply to each owner or operator. If the combined amount of

regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square feet on other facility components, or at least thirty-five (35) cubic feet on all facility components, then the notification requirements of 326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present.

(b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as necessary, including, but not limited to the following: (1) When the amount of affected asbestos containing material increases or

decreases by at least twenty percent (20%); or (2) If there is a change in the following:

(A) Asbestos removal or demolitions start date;

(B) Removal or demolition contractor; or

(C) Waste disposal site.

(c) The Permittee shall ensure that the notice is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2).

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3).


All required notifications shall be submitted to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The notice shall include a signed certification from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project. The notifications do not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square feet on any other facility components or a total of at least 0.75 cubic feet on all facility components.

(f) Demolition and Renovation The Permittee shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 61.145(a).

(g) Indiana Licensed Asbestos Inspector The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Licensed Asbestos Inspector to thoroughly inspect the affected portion of the facility for the presence of asbestos.

Testing Requirements [326 IAC 2-8-4(3)]

C.8 Performance Testing [326 IAC 3-6] (a) For performance testing required by this permit, a test protocol, except as provided

elsewhere in this permit, shall be submitted to: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date. The notification submitted by the Permittee does not require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ not later than forty-five (45) days after the completion of the testing. An extension may be granted by IDEM, OAQ if the Permittee submits to IDEM, OAQ a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 23 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers Compliance Requirements [326 IAC 2-1.1-11]

C.9 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved by the commissioner or the U. S. EPA.

Compliance Monitoring Requirements [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)]

C.10 Compliance Monitoring [326 IAC 2-8-4(3)][326 IAC 2-8-5(a)(1)] (a) For new units:

Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for new emission units shall be implemented on and after the date of initial start-up.

(b) For existing units:

Unless otherwise specified in this permit, for all monitoring requirements not already legally required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance to begin such monitoring. If due to circumstances beyond the Permittee's control, any monitoring equipment required by this permit cannot be installed and operated no later than ninety (90) days after permit issuance the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 in writing, prior to the end of the initial ninety (90) day compliance schedule, with full justification of the reasons for the inability to meet this date. The notification which shall be submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

C.11 Instrument Specifications [326 IAC 2-1.1-11][326 IAC 2-8-4(3)][326 IAC 2-8-5(1)]

(a) When required by any condition of this permit, an analog instrument used to measure a parameter related to the operation of an air pollution control device shall have a scale such that the expected maximum reading for the normal range shall be no less than twenty percent (20%) of full scale. The analog instrument shall be capable of measuring values outside of the normal range.

(b) The Permittee may request that the IDEM, OAQ approve the use of an instrument that

does not meet the above specifications provided the Permittee can demonstrate that an alternative instrument specification will adequately ensure compliance with permit conditions requiring the measurement of the parameters.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 24 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers Corrective Actions and Response Steps [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)]

C.12 Risk Management Plan [326 IAC 2-8-4][40 CFR 68] If a regulated substance, as defined in 40 CFR 68, is present at a source in more than a threshold quantity, the Permittee must comply with the applicable requirements of 40 CFR 68.

C.13 Response to Excursions or Exceedances [326 IAC 2-8-4][326 IAC 2-8-5]

Upon detecting an excursion, where a response step is required by the D Section or an exceedance of a limitation in this permit: (a) The Permittee shall take reasonable response steps to restore operation of the emissions

unit (including any control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing excess emissions.

(b) The response shall include minimizing the period of any startup, shutdown, or

malfunction. The response may include, but is not limited to, the following: (1) initial inspection and evaluation; (2) recording that operations returned or are returning to normal without operator

action (such as through response by a computerized distribution control system); or

(3) any necessary follow-up actions to return operation to normal or usual manner of

operation. (c) A determination of whether the Permittee has used acceptable procedures in response to

an excursion or exceedance will be based on information available, which may include, but is not limited to, the following: (1) monitoring results; (2) review of operation and maintenance procedures and records; and/or (3) inspection of the control device, associated capture system, and the process.

(d) Failure to take reasonable response steps shall be considered a deviation from the

permit. (e) The Permittee shall record the reasonable response steps taken.

C.14 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-8-4][326 IAC 2-8-5]

(a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall submit a description of its response actions to IDEM, OAQ, no later than seventy-five (75) days after the date of the test.

(b) A retest to demonstrate compliance shall be performed no later than one hundred eighty (180) days after the date of the test. Should the Permittee demonstrate to IDEM, OAQ that retesting in one hundred eighty (180) days is not practicable, IDEM, OAQ may extend the retesting deadline

(c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests.


The response action documents submitted pursuant to this condition do require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)]

C.15 General Record Keeping Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-5] (a) Records of all required monitoring data, reports, and support information required by this

permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. Support information includes the following, where applicable:

(AA) All calibration and maintenance records. (BB) All original strip chart recordings for continuous monitoring

instrumentation. (CC) Copies of all reports required by the FESOP.

Records of required monitoring information include the following, where applicable: (AA) The date, place as defined in this permit, and time of sampling or

measurements. (BB) The dates analyses were performed. (CC) The company or entity that performed the analyses. (DD) The analytical techniques or methods used. (EE) The results of such analyses. (FF) The operation conditions as existing at the time of sampling or

measurement. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time.

(b) Unless otherwise specified in this permit, for all record keeping requirements not already legally required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance or the date of initial start-up, whichever is later, to begin such record keeping.

C.16 General Reporting Requirements [326 IAC 2-8-4(3)(C)][326 IAC 2-1.1-11] (a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring

Report or its equivalent. Proper notice submittal under Section B - Emergency Provisions satisfies the reporting requirements of this paragraph. Any deviation from permit requirements, the date(s) of each deviation, the cause of the deviation, and the response steps taken must be reported except that a deviation required to be reported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. This report shall be submitted not later than thirty (30) days after the end of the reporting period. The Quarterly Deviation and Compliance Monitoring Report shall include a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an "authorized individual" as defined by 326 IAC 2-1.1-1(1). A deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit.


(b) The address for report submittal is: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(c) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(d) Reporting periods are based on calendar years, unless otherwise specified in this permit.

For the purpose of this permit, “calendar year” means the twelve (12) month period from January 1 to December 31 inclusive.

Stratospheric Ozone Protection

C.17 Compliance with 40 CFR 82 and 326 IAC 22-1 Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, the Permittee shall comply with applicable standards for recycling and emissions reduction.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 27 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: (a) One (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process, consisting

of the following: (1) One (1) Core assembly process, identified as Core Assembly, constructed in 1995,

consisting of associated fin mills, core builders, tube mills, turbulators, and other related equipment, using evaporative oils containing no more than of two and four tenths (2.4) pounds of VOC per gallon of oil, uncontrolled and exhausting inside the building. This process was approved for modification in 2013 for construction of an additional tube mill.

Alternative Operating Scenario 1 (AOS1): Approved in 2015 for modification, for the use of evaporative oils containing no more than four and eighty-four hundredths (4.84) pounds of VOC per gallon of oil when the Core assembly process is operating in conjunction with Braze Line #8, with VOC emissions controlled by the Braze Line #8 Vorcinerator afterburner. The equipment under the core assembly process is not stationary and can be moved from one location to another within the facility depending on the production needs.

(2) One (1) braze line, identified as Braze Line #1, constructed in 1991, with a maximum

capacity of two hundred (200) aluminum cores (2,000 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of three and two tenths (3.2) MMBtu per hour, uncontrolled and exhausting at stack PE-20;

(B) One (1) spray fluxer with a maximum capacity of eleven (11.0) pounds of flux per

hour, uncontrolled and exhausting outside the building; (C) One (1) natural gas-fired flux dry-off oven a maximum heat input capacity of one

and two tenths (1.2) MMBtu per hour, uncontrolled and exhausting at stack PE-22; and

(D) One (1) nitrogen electric braze oven and cool down station, uncontrolled and

exhausting at stacks PE-23 and PE-24, respectively. (3) One (1) super braze line, identified as Braze Line #2, constructed in 1995, approved for

modification in 2013, with a maximum capacity of two hundred fifty (250) aluminum cores (7,600 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting at stack PE-31;

(B) One (1) nitrogen electric braze oven and cool down station, uncontrolled and

exhausting at stacks PE-35 and PE-36, respectively. (4) One (1) braze line, identified as Braze Line #3, constructed in 1996, with a maximum

capacity of two hundred fifty (250) aluminum cores (3,800 pounds) per hour and


consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting at stack PE-44;



and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-47; and



capacity of one hundred thirty (130) aluminum cores (2,250 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of two and five tenths (2.5) MMBtu per hour, uncontrolled and exhausting at stack PE-59;






capacity of five hundred (500) aluminum cores (7,500 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of four (4.0) MMBtu per hour, uncontrolled and exhausting to stack PE-600A, B;




(D) One (1) nitrogen electric braze oven and cool down station exhausting at stacks

PE-603A and PE-603B, respectively. (7) One (1) braze line, identified as Braze Line #8, constructed in 2009 and approved in 2015

for modification, with a maximum capacity of two hundred (200) radiators (5,718 pounds) per hour and consisting of the following:


(A) One (1) natural gas-fired core conditioning oven with a maximum heat input capacity of four (4.0) MMBtu per hour, with VOC emissions controlled by a Vorcinerator afterburner, and exhausting at stack PE-59;

(B) One (1) spray fluxer with a maximum capacity of eighty-eight (88.0) pounds

(40,000 grams) of flux per hour, uncontrolled and exhausting outside the building; (C) One (1) natural gas-fired flux dry-off oven with a maximum heat input capacity of

eight tenths (0.8) MMBtu per hour and exhausting at stack PE-702; (D) One (1) natural gas-fired braze furnace convection pre-heat chamber with a

maximum input capacity of two (2.0) MMBtu per hour, uncontrolled and exhausting at stack PE-702; and

(E) One (1) electric braze oven and cool down station, uncontrolled and exhausting

at stacks PE-703A and PE-703B, respectively. (8) Powder coating operations including the following:

(A) One (1) electrostatic powder paint booth and filter system, identified as paint

booth #2, with a maximum material usage rate of twenty-three (23.0) pounds of paint per hour, controlled by one (1) integral cartridge filter system used to reclaim the unused powder paint for reuse, and a second filter system for particulate control, and exhausting inside the building;

(B) One (1) natural gas-fired paint dry-off oven, with a maximum heat input capacity of one and five tenths (1.5) MMBtu per hour, uncontrolled and exhausting at stack PE-605; and

(C) One (1) natural gas-fired paint hook burn-off oven, with a maximum heat input capacity of four hundred seventy-five thousandths (0.475) MMBtu per hour, uncontrolled and exhausting at stack PE-28.

(D) One (1) paint bake oven, identified as Paint Bake Oven 2, approved in 2015 for construction, with a maximum heat input capacity of 3.00 MMBtu/hr, uncontrolled and exhausting to a stack.

(9) Two (2) robotic arc welders, each with a maximum electrode consumption of two and one

tenth (2.1) pounds per hour, uncontrolled and exhausting inside the building.

(10) One (1) tube mill with brazing and fluxing stations, constructed in 2014, consisting of the following units: (A) One (1) brazing station, with a maximum capacity of 700,000 aluminum tubes

(5250 tons) per year, and using an electric braze oven. (B) One (1) flux station, with a maximum capacity of 1.35 gallons per hour of oil and

flux, using filters as particulate control, and exhausting to stacks PE-901 through PE-910.

(11) One (1) spray fluxer, identified as Stand-Alone Spray Fluxer, with a maximum capacity of

eleven (11.0) pounds of flux per hour, uncontrolled and exhausting outside the building. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 30 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers Emission Limitations and Standards [326 IAC 2-8-4(1)]

D.1.1 BACT Limit [326 IAC 8-1-6] Pursuant to 326 IAC 8-1-6 (BACT), the Permittee shall comply with the following: (a) The VOC emissions from the evaporating oil usage in the one (1) NOCOLOK radiator,

condenser, and charge air cooler manufacturing process shall not exceed eighty-seven (87.0) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(b) The Permittee shall use oils containing no more than two and four tenths (2.4) pounds of

VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Lines #1, #2, #3, #5, and #6.

(c) Unless operating under Alternative Operating Scenario 1 (AOS1), the Permittee shall use

oils containing no more than two and four tenths (2.4) pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8.

(d) Braze Line #8 Radiator Production: Alternative Operating Scenario 1 (AOS1)

(1) The Permittee shall use oils containing no more than 4.84 pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 radiator production.

(2) The VOC emissions from the evaporating oil usage on all fin mills, tube mills, and

turbulator mills when the Core assembly process is operating in conjunction with Braze Line 8 radiator production shall not exceed eighty-eight hundredths (0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(3) VOC emissions from Braze Line 8 radiator production shall be controlled by the

Vorcinerator afterburner. (4) The overall efficiency for the Vorcinerator (including the capture efficiency and

destruction efficiency) shall be at least 95%, or the VOC outlet concentration shall not exceed 10 ppmv.

(e) The Permittee shall use a micro-coat application system on all fin mills, tube mills, and

turbulator mills to minimize oil usage. D.1.2 FESOP Minor Limits [326 IAC 2-8-4]

Pursuant to 326 IAC 2-8-4 (FESOP), the VOC emissions from evaporating oil usage on all fin mills, tube mills, and turbulator mills in the Core assembly process and flux usage on the tube mill with brazing and fluxing stations shall not exceed 95.81 tons of VOC per twelve (12) consecutive month period, with compliance determined at the end of each month. Compliance with this limit, combined with the potential to emit of VOC from all other units at the source, shall limit the potential to emit of VOC from the entire source to less than 100 tons per twelve (12) consecutive month period and shall render the requirements of 326 IAC 2-7 (Part 70 Permit Program) not applicable.

D.1.3 Particulate [326 IAC 6-3]

(a) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from each of the brazing operations,


performed in the electric braze ovens, and accompanying cool down stations shall not exceed the pounds per hour limitations listed in the table below:

Emission ID Process Weight Rate 326 IAC 6-3

Allowable Emission Rate (lbs/hour) (lbs/hour) (tons/hour)

Line #1 Braze Oven

& Cool Down Station 2,000 1.00 4.10

Line #2 Braze Oven


Line #3 Braze Oven


Line #5 Braze Oven


Line #6 Braze Oven


Line #8 Braze Oven


Tube Mill (brazing) 1,200 0.6 2.91 (b) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing

Processes), the allowable particulate emission rate from the electrostatic powder paint booth (identified as paint booth #2), comprising the powder coating operation, shall not exceed the pounds per hour limitation listed in the table below:

Emission ID Process Weight Rate 326 IAC 6-3

Allowable Emission Rate (lbs/hour) (lbs/hour) (tons/hour)

Paint Booth #2 23 0.012 0.21 These limitations were calculated as follows: Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation: E = 4.10 P 0.67 where E = rate of emission in pounds per hour and P = process weight rate in tons per hour

D.1.4 Incinerators [326 IAC 4-2-2]

Pursuant to 326 IAC 4-2-2 (Incinerators), the paint hook burn-off oven shall: (a) Consist of primary and secondary chambers or the equivalent; (b) Be equipped with a primary burner unless burning wood products; (c) Comply with 326 IAC 5-1 and 326 IAC 2;


(d) Be maintained, operated, and burn waste in accordance with the manufacturer's specifications or an operation and maintenance plan as specified in 326 IAC 4-2-2(c); and

(e) Not emit particulate matter in excess of five-tenths (0.5) pounds of particulate matter per

one thousand (1,000) pounds of dry exhaust gas under standard conditions corrected to fifty percent (50%) excess air for incinerators.

If any of the above requirements are not met, the Permittee shall stop charging the incinerator until adjustments are made that address the underlying cause of the deviation.

D.1.5 Preventive Maintenance Plan [326 IAC 2-8-4(9)]

A Preventive Maintenance Plan is required for these facilities and any associated control equipment. Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements [326 IAC 2-8-4(1)]

D.1.6 Volatile Organic Compounds (VOC) [326 IAC 8-1-2][326 IAC 8-1-4] Compliance with the VOC content and usage limits contained in Conditions D.1.1(a), D.1.1(d)(2), and D.1.2 shall be determined pursuant to 326 IAC 8-1-4(a)(3) and 326 IAC 8-1-2(a) by preparing or obtaining from the manufacturer the copies of the “as supplied” and “as applied” VOC data sheets. IDEM, OAQ, reserves the authority to determine compliance using Method 24 in conjunction with the analytical procedures specified in 326 IAC 8-1-4.

D.1.7 Particulate Control

In order to comply with Condition D.1.3(b), the integral cartridge filter system used in conjunction with the electrostatic powder coating operation, shall be in operation and control emissions from the one (1) electrostatic powder paint booth (identified as paint booth #2) at all times when paint booth #2 is in operation.

D.1.8 VOC Control

When operating under AOS1, in order to assure compliance with Condition D.1.1(d)(2), the Vorcinerator afterburner for VOC control shall be in operation and control emissions from the Braze Line #8 core conditioning oven facility at all times the Braze Line #8 core conditioning oven facility is in operation.

D.1.9 Testing Requirements [326 IAC 2-1.1-11]

Not later than 180 days after the issuance date of this permit, Permit No 031-36237-00014, the Permittee shall perform VOC testing of the Vorcinerator afterburner utilizing methods approved by the commissioner at least once every 5 years from the date of the most recent valid compliance demonstration. Testing shall be conducted in accordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C – Performance Testing contains the Permittee’s obligation with regard to the performance testing required by this condition.

D.1.10 VOC Emissions (a) Compliance with the VOC emissions limit in Condition D.1.1(a) shall be demonstrated by

the summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

V = [Σ(CL x UL) + 0.05 x Σ(CAOS1 x UAOS1)] 2,000

Where V = VOC emissions (tons/month)


Unless operating under AOS1: CL = VOC content of a single oil containing no more than 2.4 pounds of

VOC per gallon of oil processed on Braze Lines #1, #2, #3, #5, #6, and #8 (lb/gal)

UL = Usage of a single oil containing no more than 2.4 pounds of VOC per gallon of oil processed on Braze Lines #1, #2, #3, #5, #6, and #8 (gal/mo)

When operating under AOS1

CAOS1 = VOC content of a single oil containing no more than 4.84 pounds of VOC per gallon of oil processed on Braze Line #8 (lb/gal)

UAOS1 = Usage of a single oil containing no more than 4.84 pounds of VOC per gallon of oil processed on Braze Lines #8 (gal/mo)

(b) Compliance with the VOC emissions limit in Condition D.1.1(d)(2) shall be demonstrated

by the summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

VAOS1 = [ 0.05 x Σ(CAOS1 x UAOS1)] 2,000

Where VAOS1 = VOC emissions when operating under Alternative Operating

Scenario 1 (tons/month) CAOS1 = VOC content of a single oil containing no more than 4.84 pounds of

VOC per gallon of oil processed on Braze Line #8 (lb/gal) UAOS1 = Usage of a single oil containing no more than 4.84 pounds of VOC

per gallon of oil processed on Braze Lines #8 (gal/mo) (c) Compliance with the VOC emissions limit in Condition D.1.2 shall be demonstrated by the

summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

E = [Σ(CL x UL) + 0.05 x Σ(CAOS1 x UAOS1) + Σ (CF x UF)] 2,000

Where E = VOC emissions (tons/month)

CL = VOC content of a single oil containing no more than 2.4 pounds of VOC per gallon of oil processed on Braze Lines #1, #2, #3, #5, #6, and #8 (lb/gal)




CF = VOC content of a single flux used on the tube mill with brazing and fluxing stations (lb/gal)

UF = Usage of a single flux used on the tube mill with brazing and fluxing stations (gal/mo)

Compliance Monitoring Requirements [326 IAC 2-8-4(1)][326 IAC 2-8-5(a)(1)]

D.1.11 Vorcinerator Afterburner Temperature (a) A continuous monitoring system shall be calibrated, maintained, and operated on the

Vorcinerator afterburner for measuring operating temperature. For the purpose of this


condition, continuous means no less often than once per fifteen (15) minutes. The output of this system shall be recorded as 3-hour average. From the date of startup until the stack test results are available, the Permittee shall operate the Vorcinerator afterburner at or above the 3-hour average temperature of 1,472°F.

(b) The Permittee shall determine the 3-hour average temperature from the latest valid stack

test that demonstrates compliance with limits in Condition D.1.1(d)(4). (c) On and after the date the stack test results are available, the Permittee shall operate the

Vorcinerator afterburner at or above the 3-hour average temperature as observed during the latest compliant stack test.

(d) If the 3-hour average temperature falls below the above mentioned 3-hour average

temperature, the Permittee shall take a reasonable response. Section C - Response to Excursions or Exceedances contains the Permittee's obligation with regard to the response steps required by this condition. Failure to take response steps shall be considered a deviation from this permit.

D.1.12 Parametric Monitoring - Vorcinerator Afterburner Duct Pressure or Fan Amperage

(a) The Permittee shall determine the appropriate duct pressure or fan amperage from the latest valid stack test that demonstrates compliance with limits in Condition D.1.1(d)(4).

(b) The duct pressure or fan amperage shall be observed at least once per day when the

Vorcinerator afterburner is in operation. On and after the date the stack test results are available, the duct pressure or fan amperage shall be maintained within the normal range as established in latest compliant stack test.

(c) When, for any one reading, the duct pressure or fan amperage is outside the above

mentioned range, the Permittee shall take a reasonable response. Section C - Response to Excursions and Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is outside the above mentioned range is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(d) The instruments used for determining the pressure drop shall comply with Section C –

Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated or replaced at least once every six (6) months.

Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-16]

D.1.13 Record Keeping Requirements (a) To document the compliance status with Conditions D.1.1 and D.1.2, the Permittee shall

maintain records in accordance with (1) through (8) below. Records maintained for (1) through (8) shall be taken as stated below and shall be complete and sufficient to establish compliance with the VOC content and VOC usage limits established in Conditions D.1.1 and D.1.2 . (1) The VOC content of each evaporating oil used. (2) The amount of each evaporating oil used on a monthly basis. Records shall

include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.

(3) The total VOC input for each month.


(4) During periods when operating under AOS1:

(A) The VOC content of each evaporating oil used. (B) The amount of each evaporating oil used on a monthly basis. Records

shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.

(C) The total VOC input for each month. (D) The total VOC emitted from the input of evaporative oils when operating

under AOS1 for each month and each compliance period. (5) The total VOC emitted from the input of evaporative oils for each month and each

compliance period.

(6) The VOC content of flux used in the tube mill with brazing and fluxing stations.

(7) The amount of flux used in the tube mill with brazing and fluxing stations on a monthly basis. Records shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.

(8) The amount of VOC emitted from the input of evaporative oil and flux for each

month and each compliance period. (b) To document the compliance status with Condition D.1.11, the Permittee shall maintain

continuous temperature records for the Vorcinerator afterburner and the 3-hour average temperature used to demonstrate compliance during the most recent compliant stack test.

(c) To document the compliance status with Condition D.1.12, the Permittee shall maintain

daily records of the duct pressure or fan amperage for the Vorcinerator afterburner. The Permittee shall include in its daily record when the readings are not taken and the reason for the lack of the readings (e.g. the process did not operate that day).

(d) Section C - General Record Keeping Requirements contains the Permittee's obligations

with regard to the records required by this condition.

D.1.14 Reporting Requirements A quarterly summary of the information to document the compliance status with Conditions D.1.1(a), D.1.1(d)(2) and D.1.2 shall be submitted using the reporting forms located at the end of this permit, or their equivalent, not later than thirty (30) days after the end of the quarter being reported. Section C - General Reporting contains the Permittee's obligation with regard to the reporting required by this condition. The report submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an “authorized individual” as defined by 326 IAC 2-1.1-1(1).

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 36 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION D.2 EMISSION UNIT OPERATION CONDITIONS

Emission Unit Description [326 IAC 2-8-4(10)]: Boiler (a) One (1) natural gas-fired boiler, installed in 2001, with a maximum heat input capacity of one and

forty-six tenths (1.46) million British thermal units (MMBtu) per hour. [326 IAC 6-2-4] (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-8-4(1)]

D.2.1 Particulate [326 IAC 6-2-4] Pursuant to 326 IAC 6-2-4 (Particulate Emission Limitations for Sources of Indirect Heating), PM emissions from the one (1) natural gas-fired boiler shall not exceed six tenths (0.6) lbs PM per MMBtu.

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 37 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers SECTION D.3 EMISSION UNIT OPERATION CONDITIONS

Emission Unit Description [326 IAC 2-8-4(10)]: (b) One (1) abrasive blasting booth, identified as blast booth, constructed in September 2008, with a

maximum blasting rate of 1000 pounds per hour, using a filter as control, and exhausting indoors. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-8-4(1)]

D.3.1 Particulate [326 IAC 6-3-2] Pursuant to 326 IAC 6-3-2, the particulate matter (PM) from the abrasive blast booth shall not exceed 2.58 pounds per hour when operating at a process weight rate of 0.50 tons per hour. The pound per hour limitation was calculated with the following equation:

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation:

E = 4.10 P 0.67 where E = rate of emission in pounds per hour and

P = process weight rate in tons per hour

D.3.2 Preventive Maintenance Plan [326 IAC 2-8-4(9)] A Preventive Maintenance Plan is required for this facility and its associated control device. Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements [326 IAC 2-8-4(1)]

D.3.3 Particulate Control In order to comply with Condition D.3.1, the filter shall be in operation and control emissions from the abrasive blast booth at all times the abrasive blast booth is in operation.


INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) CERTIFICATION

Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014

This certification shall be included when submitting monitoring, testing reports/results

or other documents as required by this permit.

Please check what document is being certified: Annual Compliance Certification Letter Test Result (specify)___________________________________________________ Report (specify)_______________________________________________________ Notification (specify)____________________________________________________ Affidavit (specify)_______________________________________________________ Other (specify)_________________________________________________________

I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. Signature: Printed Name: Title/Position: Date:




100 North Senate Avenue MC 61-53 IGCN 1003

Indianapolis, Indiana 46204-2251 Phone: (317) 233-0178

Fax: (317) 233-6865

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) EMERGENCY OCCURRENCE REPORT

Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 This form consists of 2 pages Page 1 of 2

This is an emergency as defined in 326 IAC 2-7-1(12)

• The Permittee must notify the Office of Air Quality (OAQ), within four (4) daytime business hours (1-800-451-6027 or 317-233-0178, ask for Compliance Section); and

• The Permittee must submit notice in writing or by facsimile within two (2) working days (Facsimile Number: 317-233-6865), and follow the other requirements of 326 IAC 2-8-12

If any of the following are not applicable, mark N/A

Facility/Equipment/Operation: Control Equipment: Permit Condition or Operation Limitation in Permit: Description of the Emergency: Describe the cause of the Emergency:

Valeo North America, Inc. Significant Permit Revision No. 031-36237-00014 Page 40 of 45 Greensburg, Indiana Revised by: Doug Logan F031-29500-00014 Permit Reviewer: Hannah L. Desrosiers If any of the following are not applicable, mark N/A Page 2 of 2

Date/Time Emergency started: Date/Time Emergency was corrected: Was the facility being properly operated at the time of the emergency? Y N Describe: Type of Pollutants Emitted: TSP, PM-10, SO2, VOC, NOX, CO, Pb, other: Estimated amount of pollutant(s) emitted during emergency: Describe the steps taken to mitigate the problem: Describe the corrective actions/response steps taken: Describe the measures taken to minimize emissions: If applicable, describe the reasons why continued operation of the facilities are necessary to prevent imminent injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by: Title / Position: Date: Phone:




FESOP Quarterly Report

Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing process. Parameter: Volatile Organic Compounds (VOCs) Limit: Volatile Organic Compound (VOC) emissions from the evaporating oil usage in

the one (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process shall not exceed eighty-seven (87) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total

No deviation occurred in this quarter. Deviation/s occurred in this quarter. Deviation has been reported on: ___________________________

Submitted by: _________________________________________ Title / Position: _________________________________________ Signature: _________________________________________ Date: _________________________________________ Phone: _________________________________________





Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing process. Parameter: Volatile Organic Compounds (VOCs) Limit: The VOC emissions from the evaporating oil usage on all fin mills, tube mills, and

turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 shall not exceed eighty-eight hundredths (0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total







Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing process. Parameter: Volatile Organic Compounds (VOCs) Limit: The VOC emissions from evaporating oil and flux usage on all fin mills, tube

mills, and turbulator mills in the Core assembly process and flux usage on the tube mill with brazing and fluxing stations shall not exceed 95.81 tons of VOC per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total






FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP)

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014

Months: ___________ to ____________ Year: ______________ Page 1 of 2

This report shall be submitted quarterly based on a calendar year. Proper notice submittal under Section B - Emergency Provisions satisfies the reporting requirements of paragraph (a) of Section C - General Reporting. Any deviation from the requirements of this permit, the date(s) of each deviation, the probable cause of the deviation, and the response steps taken must be reported. A deviation required to be reported pursuant to an applicable requirement that exists independent of the permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. Additional pages may be attached if necessary. If no deviations occurred, please specify in the box marked "No deviations occurred this reporting period". NO DEVIATIONS OCCURRED THIS REPORTING PERIOD. THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD Permit Requirement (specify permit condition #) Date of Deviation:

Duration of Deviation:

Number of Deviations: Probable Cause of Deviation: Response Steps Taken: Permit Requirement (specify permit condition #) Date of Deviation:


Number of Deviations: Probable Cause of Deviation: Response Steps Taken:


Page 2 of 2 Permit Requirement (specify permit condition #) Date of Deviation:






Number of Deviations: Probable Cause of Deviation: Response Steps Taken:

Form Completed by: Title / Position: Date:

Phone:

Indiana Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for a Significant Permit Revision to a

Federally Enforceable State Operating Permit (FESOP) Renewal

Source Description and Location Source Name: Valeo North America, Inc. Source Location: 1100 East Barachel Lane, Greensburg, IN 47240 County: Decatur SIC Code: 3714 (Other Motor Vehicle Parts Manufacturing) Operation Permit No.: F 031-29500-00014 Operation Permit Issuance Date: March 10, 2011 Significant Permit Revision No.: 031-36237-00014 Permit Reviewer: Doug Logan On September 3, 2015, the Office of Air Quality (OAQ) received an application from Valeo North America, Inc. related to a modification to an existing stationary automotive condenser, radiator, and cooling module fabrication operation.

Existing Approvals The source was issued FESOP Renewal No. F031-29500-00014 on March 10, 2011. The source has since received the following approvals:

Permit Number Issuance Date Administrative Amendment No. 031-32682-00014 February 12, 2013 Minor Permit Revision No. 031-33052-00014 May 14, 2013 Minor Permit Revision No. 031-34108-00014 March 20, 2014 Administrative Amendment No. 031-35118-00014 December 18, 2014

County Attainment Status The source is located in Decatur County.

Pollutant Designation SO2 Better than national standards. CO Unclassifiable or attainment effective November 15, 1990. O3 Unclassifiable or attainment effective July 20, 2012, for the 2008 8-hour ozone standard.1

PM2.5 Unclassifiable or attainment effective April 5, 2005, for the annual PM2.5 standard. PM2.5 Unclassifiable or attainment effective December 13, 2009, for the 24-hour PM2.5 standard. PM10 Unclassifiable effective November 15, 1990. NO2 Cannot be classified or better than national standards. Pb Unclassifiable or attainment effective December 31, 2011.

1Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005.

(a) Ozone Standards Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions are considered when

Valeo North America, Inc. Page 2 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan

evaluating the rule applicability relating to ozone. Decatur County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(b) PM2.5

Decatur County has been classified as attainment for PM2.5. Therefore, direct PM2.5, SO2, and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(c) Other Criteria Pollutants

Decatur County has been classified as attainment or unclassifiable in Indiana for all other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

Fugitive Emissions

Since this type of operation is not one of the twenty-eight (28) listed source categories under 326 IAC 2-2, 326 IAC 2-3, or 326 IAC 2-7, and there is no applicable New Source Performance Standard that was in effect on August 7, 1980, fugitive emissions are not counted toward the determination of PSD, Emission Offset, and Part 70 Permit applicability.

Status of the Existing Source The table below summarizes the potential to emit of the entire source, prior to the proposed revision, after consideration of all enforceable limits established in the effective permits: This PTE table is from the TSD or Appendix A of AA No. 031-35118-00014, issued on December 18, 2014.

Process/ Emission Unit

Potential To Emit of the Entire Source Prior to Revision (tons/year)

PM PM10 PM2.5 SO2 NOx VOC CO

GHGs as

CO2e* Total HAPs

Worst Single HAP

Core Assembly (Process) (Fin Mills/ Tube Mills/Turbulators)

0 0 0 0 0

<87.0

0 0 3.3E-2 3.3E-2 (Toluene)

Core Conditioning Ovens (Combustion) 0.14 0.58 0.58 0.05 7.60 6.38 9176 0.143 0.137

(Hexane) Spray Fluxers (Process) 1.94 1.94 1.94 0 0 0 0 0 0 Flux Dry off Ovens (combustion) 0.05 0.21 0.21 0.02 2.79 2.34 3370 0.053 0.050

(Hexane) Braze Ovens with Cooling Stations (Process)

24.80 24.80 24.80 0 0 0 0 0 0

Tube Mill (flux) 2.21 2.21 2.21 0 0 0 0 0 0 Tube Mill (brazing) 3.31 3.31 3.31 0 0 0 0 0 0 0 Convection Pre Heat Chamber (Braze Line #8)(Combustion)

0.02 0.07 0.07 0.01 0.86 0.05 0.72 1037 0.016 0.015 (Hexane)

Electrostatic Powder Paint Booth (Process)** 0.50 0.50 0.50 0 0 0 0 0 0 0

Paint Dry Off Oven (Combustion) 0.01 0.05 0.05 3.9E-3 0.64 0.04 0.54 778 0.012 0.012

(Hexane) Paint Hook Burn Off Oven (Process) 6.57 6.57 6.57 0 0 0 0 0 0 0

Paint Hook Burn Off Oven (Combustion) 3.9E-3 0.02 0.02 1.2E-3 0.20 0.01 0.17 246 0.004 3.7E-3

(Hexane)



Potential To Emit of the Entire Source Prior to Revision (tons/year)

PM PM10 PM2.5 SO2 NOx VOC CO

GHGs as

CO2e* Total HAPs

Worst Single HAP

Robotic Welders (MIG) (Process) 0.44 0.44 0.44 0 0 0 0 0 0.039 0.023

(Nickel) Natural Gas Fired Boiler (Combustion) 0.01 0.05 0.05 3.8E-3 0.63 0.03 0.53 757 0.012 0.011

(Hexane) Air Handlers (Combustion) 0.30 1.20 1.20 0.09 15.81 0.87 13.28 19092 0.3 0.28

(Hexane) Abrasive Blasting Booth 17.52 15.07 15.07 0 0 0 0 0 0 0 Molding Treatment Operation − − − − − 0.33 − − 0.06 0.06

(hexane)

Injection molding machines 1.43 1.43 1.43 − − 1.33 − − 0.09

0.05 (formalde

hyde) New Tube Mill − − − − − 5.26 − − 2.1E-3 −

Total PTE of Entire Source 59.27 58.45 58.45 0.17 28.54 89.62 23.97 34,455 0.77 0.58

(Hexane) Title V Major Source Thresholds NA 100 100 100 100 100 100 100,000 25 10

PSD Major Source Thresholds 250 250 250 250 250 250 250 100,000 NA NA

Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant". *The 100,000 CO2e threshold represents the Title V and PSD subject to regulation thresholds for GHGs in order to determine whether a source’s emissions are a regulated NSR pollutant under Title V and PSD. **PTE of Powder Paint Booth is after integral cartridge filter system.

On June 23, 2014, in the case of Utility Air Regulatory Group v. EPA, cause no. 12-1146, (available at http://www.supremecourt.gov/opinions/13pdf/12-1146_4g18.pdf ) the United States Supreme Court ruled that the U.S. EPA does not have the authority to treat greenhouse gases (GHGs) as an air pollutant for the purpose of determining operating permit applicability or PSD Major source status. On July 24, 2014, the U.S. EPA issued a memorandum to the Regional Administrators outlining next steps in permitting decisions in light of the Supreme Court’s decision. U.S. EPA’s guidance states that U.S. EPA will no longer require PSD or Title V permits for sources “previously classified as ‘Major’ based solely on greenhouse gas emissions.” The Indiana Environmental Rules Board adopted the GHG regulations required by U.S. EPA at 326 IAC 2-2-1(zz), pursuant to Ind. Code § 13-14-9-8(h) (Section 8 rulemaking). A rule, or part of a rule, adopted under Section 8 is automatically invalidated when the corresponding federal rule, or part of the rule, is invalidated. Due to the United States Supreme Court Ruling, IDEM, OAQ cannot consider GHGs emissions to determine operating permit applicability or PSD applicability to a source or modification.

(a) This existing source is not a major stationary source under PSD (326 IAC 2-2), because no PSD

regulated pollutant is emitted at a rate of 250 tons per year or more, and it is not one of the twenty-eight (28) listed source categories as specified in 326 IAC 2-2-1(ff)(1).

(b) This existing source is not a major source of HAPs, as defined in 40 CFR 63.41, because the

unlimited potential to emit HAPs is less than ten (10) tons per year for any single HAP and less than twenty-five (25) tons per year of a combination of HAPs. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA).

http://www.supremecourt.gov/opinions/13pdf/12-1146_4g18.pdf%20on%20the%20Internet.%20U.S

Valeo North America, Inc. Page 4 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan Description of Proposed Revision The Office of Air Quality (OAQ) has reviewed an application, submitted by Valeo North America, Inc. on September 3, 2015, relating to reopening the BACT determination for the one (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process. The following is a list of the new emission units and pollution control devices:

(a) One (1) paint bake oven, identified as Paint Bake Oven 2, approved in 2015 for construction, with a maximum heat input capacity of 3.00 MMBtu/hr, uncontrolled and exhausting to a stack.

(b) One (1) spray fluxer, identified as Stand-Alone Spray Fluxer, with a maximum capacity of eleven (11.0) pounds of flux per hour, uncontrolled and exhausting outside the building.

The following is a list of the modified emission units and pollution control devices:

(a) One (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process, consisting of the following: (1) One (1) Core assembly process, identified as Core Assembly, constructed in

1995, consisting of associated fin mills, core builders, tube mills, turbulators, and other related equipment, using evaporative oils containing no more than of two and four tenths (2.4) pounds of VOC per gallon of oil, uncontrolled and exhausting inside the building. This process was approved for modification in 2013 for construction of an additional tube mill. Alternative Operating Scenario 1 (AOS1): Approved in 2015 for modification, for the use of evaporative oils containing no more than four and eighty-four hundredths (4.84) pounds of VOC per gallon of oil when the Core assembly process is operating in conjunction with Braze Line #8 radiator production, with VOC emissions controlled by the Braze Line #8 Vorcinerator afterburner. The equipment under the core assembly process is not stationary and can be moved from one location to another within the facility depending on the production needs.

(2) ... (7) One (1) braze line, identified as Braze Line #8, constructed in 2009 and approved

in 2015 for modification, with a maximum capacity of two hundred (200) radiators (5,718 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, with VOC emissions controlled by a Vorcinerator afterburner, and exhausting at stack PE-59;

(B) ...

(8) Powder coating operations including the following:

(A) One (1) electrostatic powder paint booth and filter system, identified as

paint booth #2, constructed in 1989 and approved in 2015 for modification, with a maximum material usage rate of sixty (60.00) pounds


of paint per hour, controlled by one (1) integral cartridge filter system used to reclaim the unused powder paint for reuse, and a second filter system for particulate control, and exhausting inside the building;

“Integral Part of the Process” Determination

As part of FESOP No. 031-21314-00014, issued on April 24, 2006, IDEM, OAQ previously determined that cartridge filter system is an integral part of the powder coating operations. IDEM, OAQ is not reevaluating this integral justification at this time. Therefore, the potential PM, PM10, and PM2.5 emissions from the powder coating operations will continue to be calculated after consideration of the cartridge filter system for purposes of determining permitting level. Operating conditions in the proposed permit will specify that the cartridge filter system shall operate at all times when the powder coating operations are in operation.

Enforcement Issues There are no pending enforcement actions related to this revision.

Emission Calculations See Appendix A of this TSD for detailed emission calculations.

Permit Level Determination – FESOP Revision The following table is used to determine the appropriate permit level under 326 IAC 2-8-11.1 (Permit Revisions). This table reflects the PTE before controls of the proposed revision. Control equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Increase in PTE Before Controls of the Modification

New Units Pollutant Potential To Emit (ton/yr)

PM 0.19 PM10 0.26 PM2.5 0.26 SO2 7.73E-03 VOC 1.29 CO 7.09E-02 NOX 1.08

Total HAPs 2.43E-02 Appendix A of this TSD reflects the unrestricted potential emissions of the modification.

PTE Change of the Modified Process

Pollutant PTE

Before Modification (ton/yr)

PTE After Modification

(ton/yr)

Increase from Modification

(ton/yr) PM 0.50 1.31 0.81

PM10 0.50 1.31 0.81 PM2.5 0.50 1.31 0.81 SO2 -- -- -- NOX -- -- --


PTE Change of the Modified Process

Pollutant PTE

Before Modification (ton/yr)

PTE After Modification

(ton/yr)

Increase from Modification

(ton/yr) VOC 88.85 97.89 9.04 CO -- -- --

Total HAPs 3.5E-02 6.60 6.56

Total PTE Increase due to the Modification

Pollutant PTE

New Emission Units (ton/yr)

Net Increase to PTE of Modified Emission Units

(ton/yr)

Total PTE for New and Modified Units

(ton/yr)

PM 0.19 0.81 1.00 PM10 0.26 0.81 1.07 PM2.5 0.26 0.81 1.07 SO2 7.73E-03 -- 7.73E-03 VOC 1.29 -- 1.29 CO 7.09E-02 9.04 9.11 NOX 1.08 -- 1.08

HAPs 2.43E-02 6.56 6.59 Pursuant to 326 IAC 2-8-11.1(f)(1)(C), this FESOP is being revised through a FESOP Significant Permit Revision because the proposed revision is not an Administrative Amendment or Minor Permit revision and the proposed revision is subject to 326 IAC 8-1-6.

PTE of the Entire Source After Issuance of the FESOP Revision The table below summarizes the potential to emit of the entire source reflecting adjustment of existing limits, with updated emissions shown as bold values and previous emissions shown as strikethrough values.


Potential To Emit of the Entire Source to accommodate the Proposed Revision (tons/year)

PM PM101 PM2.51,2 SO2 NOx VOC CO GHGs as

CO2e* Total HAPs

Worst Single HAP

Core Assembly (Process) (Fin Mills/ Tube Mills/Turbulators)3

0 0 0 0 0

<87.0 95.81

0 0 3.3E-2 6.60

3.3E-2 (Toluene)

Tube Mill (oil) (Process)4 0 0 0 0 0 0 0

Tube Mill (flux) (Process)4 2.21 2.21 2.21 0 0 0 0 Core Conditioning Ovens (Combustion) 0.14 0.58 0.58 0.05

4.56E-02 7.60 0.42 6.38 9176 0.143 0.14

0.137 (Hexane)

Spray Fluxers (Process) 1.94 2.11

1.94 2.11

1.94 2.11 0 0 0 0 0 0 0

Flux Dry off Ovens (combustion)

0.05 5.30E-02 0.21 0.21 0.02

1.67E-02 2.79 0.15 2.34 3370 0.053 5.37E-02

0.050 (Hexane)

Braze Ovens with Cooling Stations (Process)

24.80 24.80 24.80 0 0 0 0 0 0 0

Tube Mill (flux) 2.21 2.21 2.21 0 0 0 0 0 0




PM PM101 PM2.51,2 SO2 NOx VOC CO GHGs as

CO2e* Total HAPs

Worst Single HAP

Tube Mill (brazing) (Process)4 3.31 3.31 3.31 0 0 0 0 0 0 0

Convection Pre Heat Chamber (Braze Line #8)(Combustion)

0.02 1.63E-02

0.07 6.53E-02

0.07 6.53E-02

0.01 5.15E-03 0.86 0.05

4.72E-02 0.72 1037 0.016 1.62E-02

0.015 (Hexane)

Electrostatic Powder Paint Booth (Process)**5

0.50 1.31

0.50 1.31

0.50 1.31 0 0 0 0 0 0 0

Paint Dry Off Oven Bake Ovens (Combustion)

0.01 3.67E-02

0.05 0.15

0.05 0.15

3.9E-3 1.16E-02

0.64 1.93

0.04 0.11

0.54 1.62 778 0.012

3.65E-02 0.012

(Hexane)

Paint Hook Burn Off Oven (Process) 6.57 6.57 6.57 0 0 0 0 0 0 0

Paint Hook Burn Off Oven (Combustion)

3.9E-3 3.88E-03

0.02 1.55E-02

0.02 1.55E-02

1.2E-3 1.22E-03 0.20 0.01

1.12E-02 0.17 246 0.004 3.85E-03

3.7E-3 (Hexane)

Robotic Welders (MIG) (Process) 0.44 0.44 0.44 0 0 0 0 0 0.039

3.91E-02 0.023

(Nickel)

Natural Gas Fired Boiler (Combustion)

0.01 1.19E-02

0.05 4.76E-02

0.05 4.76E-02

3.8E-3 3.76E-03 0.63 0.03

3.45E-02 0.53 757 0.012 1.18E-02

0.011 (Hexane)

Air Handlers (Combustion) 0.30 1.20 1.20 0.09

9.49E-02 15.81 0.87 13.28 19092 0.3 0.30

0.28 (Hexane)

Abrasive Blasting Booth (Process) 17.52 15.07 15.07 0 0 0 0 0 0 0

Molding Treatment Operation (Process) − − − − − 0.33

0.29 − − 0.06 6.38E-02

0.06 (hexane)

Injection molding machines (Process) 1.43 1.43 1.43 − − 1.33 − − 0.09

9.03E-02 0.05

(formaldehyde)

New Tube Mill − − − − − 5.26 − − 2.1E-3 −

Total PTE of Entire Source

59.27 60.27

58.45 59.52

58.45 59.52

0.17 0.18

28.54 29.83

89.62 99.07

23.97 25.05 34,455 0.77

7.36 0.58

(Hexane) Title V Major Source Thresholds NA 100 100 100 100 100 100 100,000 25 10

PSD Major Source Thresholds 250 250 250 250 250 250 250 100,000 NA NA

1. Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant".

2. PM2.5 listed is direct PM2.5. 3. "Core Assembly" includes the tube mill added in AA 031-35118-00014, issued December 18, 2014. 4. "Tube Mill (n)" entries indicate the tube mill with brazing and fluxing stations added in MPR 031-34108-00014,

issued March 20, 2014. 5. PTE of Powder Paint Booth is after integral cartridge filter system. *The 100,000 CO2e threshold represents the Title V and PSD subject to regulation thresholds for GHGs in order to determine whether a source’s emissions are a regulated NSR pollutant under Title V and PSD. **PTE of Powder Paint Booth is after integral cartridge filter system.

The table below summarizes the potential to emit of the entire source after issuance of this revision, reflecting all limits, of the emission units. (Note: the table below was generated from the above table, with bold text un-bolded and strikethrough text deleted).




PM PM101 PM2.51,2 SO2 NOx VOC CO Total HAPs

Core Assembly (Process) (Fin Mills/ Tube Mills/Turbulators)3

0 0 0 0 0

95.81

0 6.60

Tube Mill (oil) (Process)4 0 0 0 0 0 0 0

Tube Mill (flux) (Process)4 2.21 2.21 2.21 0 0 0 0

Core Conditioning Ovens (Combustion) 0.14 0.58 0.58 4.56E-02 7.60 0.42 6.38 0.14

Spray Fluxers (Process) 2.11 2.11 2.11 0 0 0 0 0 Flux Dry off Ovens (combustion) 5.30E-02 0.21 0.21 1.67E-02 2.79 0.15 2.34 5.37E-02

Braze Ovens with Cooling Stations (Process)

24.80 24.80 24.80 0 0 0 0 0

Tube Mill (brazing) (Process)4 3.31 3.31 3.31 0 0 0 0 0

Convection Pre Heat Chamber (Braze Line #8)(Combustion)

1.63E-02 6.53E-02 6.53E-02 5.15E-03 0.86 4.72E-02 0.72 1.62E-02

Electrostatic Powder Paint Booth (Process)5 1.31 1.31 1.31 0 0 0 0 0

Paint Bake Ovens (Combustion) 3.67E-02 0.15 0.15 1.16E-02 1.93 0.11 1.62 3.65E-02

Paint Hook Burn Off Oven (Process) 6.57 6.57 6.57 0 0 0 0 0

Paint Hook Burn Off Oven (Combustion) 3.88E-03 1.55E-02 1.55E-02 1.22E-03 0.20 1.12E-02 0.17 3.85E-03

Robotic Welders (MIG) (Process) 0.44 0.44 0.44 0 0 0 0 3.91E-02

Natural Gas Fired Boiler (Combustion) 1.19E-02 4.76E-02 4.76E-02 3.76E-03 0.63 3.45E-02 0.53 1.18E-02

Air Handlers (Combustion) 0.30 1.20 1.20 9.49E-02 15.81 0.87 13.28 0.30

Abrasive Blasting Booth (Process) 17.52 15.07 15.07 0 0 0 0 0

Molding Treatment Operation (Process) − − − − − 0.29 − 6.38E-02

Injection molding machines (Process) 1.43 1.43 1.43 − − 1.33 − 9.03E-02

Total PTE of Entire Source 60.27 59.52 59.52 0.18 29.83 99.07 25.05 7.36

Title V Major Source Thresholds NA 100 100 100 100 100 100 25

PSD Major Source Thresholds 250 250 250 250 250 250 250 NA

1. Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant".

2. PM2.5 listed is direct PM2.5. 3. "Core Assembly" includes the tube mill added in AA 031-35118-00014, issued December 18, 2014. 4. "Tube Mill (n)" entries indicate the tube mill with brazing and fluxing stations added in MPR 031-34108-00014,

issued March 20, 2014. 5. PTE of Powder Paint Booth is after integral cartridge filter system.

Valeo North America, Inc. Page 9 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan (a) FESOP Status

This revision to an existing Title V minor stationary source will not change the minor status, because the potential to emit criteria pollutants and HAPs from the entire source will still be limited to less than the Title V major source threshold levels. Therefore, the source will still be subject to the provisions of 326 IAC 2-8 (FESOP).

(1) Criteria Pollutants

In order to comply with the requirements of 326 IAC 2-8-4 (FESOP), the source shall comply with the following:

(A) The VOC emissions from evaporating oil usage on all fin mills, tube mills, and

turbulator mills in the Core assembly process and flux usage on the tube mill with brazing and fluxing stations shall not exceed 95.81 tons of VOC per twelve (12) consecutive month period, with compliance determined at the end of each month.

Compliance with these limits, combined with the potential to emit VOC from all other emission units at this source, shall limit the source-wide total potential to emit of VOC to less than 100 tons per twelve (12) consecutive month period, and shall render the requirements of 326 IAC 2-7 (Part 70 Permits) not applicable.

Federal Rule Applicability Determination

(a) New Source Performance Standards (NSPS)

(1) There are no New Source Performance Standards (40 CFR Part 60) and 326 IAC 12 included for this proposed revision.

(b) National Emission Standards for Hazardous Air Pollutants (NESHAP)

(1) There are no National Emission Standards for Hazardous Air Pollutants (40 CFR Part 63), 326 IAC 14 and 326 IAC 20 included for this proposed revision.

(c) Compliance Assurance Monitoring (CAM)

Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is not included in the permit, because the potential to emit of the source is limited to less than the Title V major source thresholds and the source is not required to obtain a Part 70 or Part 71 permit.

State Rule Applicability Determination

(a) 326 IAC 2-8-4 (FESOP)

This revision to an existing Title V minor stationary source will not change the minor status, because the potential to emit criteria pollutants from the entire source will still be limited to less than the Title V major source threshold levels. Therefore, the source will still be subject to the provisions of 326 IAC 2-8 (FESOP). See PTE of the Entire Source After Issuance of the FESOP Revision Section above.

(b) 326 IAC 2-2 (Prevention of Significant Deterioration (PSD))

This modification to an existing PSD minor stationary source will not change the PSD minor status, because the potential to emit of all attainment regulated pollutants from the entire source will continue to be less than the PSD major source threshold levels. Therefore, pursuant to 326 IAC 2-2, the PSD requirements do not apply. See PTE of the Entire Source After Issuance of the FESOP Revision Section above.

Valeo North America, Inc. Page 10 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan (c) 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP))

The proposed revision is not subject to the requirements of 326 IAC 2-4.1, since the unlimited potential to emit of HAPs from the modified units is less than ten (10) tons per year for any single HAP and less than twenty-five (25) tons per year of a combination of HAPs.

(d) 326 IAC 6-2 (Particulate Emission Limitations for Source of Indirect Heating)

326 IAC 6-2-4 is not applicable to the one (1) paint bake oven, identified as Paint Bake Oven 2, because the unit does not use combustion for indirect heating as defined at 326 IAC 1-2-19.

(e) 326 IAC 6-3 (Particulate Emission Limitations for Manufacturing Processes)

IDEM, OAQ has determined that the cartridge filter system is integral to the powder coating operations. The potential to emit of the powder coating operations is 0.30 lb/hr, after controls. Pursuant to 326 IAC 6-3-1(b)(14), 326 IAC 6-3 is not applicable to the powder coating operations because the potential to emit PM is less than five hundred fifty-one thousandths (0.551) pound per hour.

(f) 326 IAC 8-1-6 (VOC Rules: General Reduction Requirements for New Facilities)

The NOCOLOK radiator, condenser, and charge air cooler manufacturing process has a potential to emit of greater than 25 tons of VOC per year and is not otherwise regulated by other provisions of 326 IAC 8. Therefore, the NOCOLOK radiator, condenser, and charge air cooler manufacturing process is subject to 326 IAC 8-1-6 and a Best Available Control Technology (BACT) is required to be applied to the NOCOLOK radiator, condenser, and charge air cooler manufacturing process.

Valeo North America, Inc. proposed that BACT for the facility located in Greensburg, Indiana would be the combination of work practice controls, thermal destruction, and VOC content and usage limits. This proposed limit is consistent with other BACT limits. Therefore, the BACT for the NOCOLOK radiator, condenser, and charge air cooler manufacturing process shall be as follows: (1) The VOC input from the evaporating oil usage in the one (1) NOCOLOK radiator,

condenser, and charge air cooler manufacturing process shall not exceed eighty seven (87.00) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(2) The Permittee shall use oils containing no more than two and four tenths (2.4) pounds of

VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Lines #1, #2, #3, #5, and #6;

(3) Unless operating under Alternative Operating Scenario 1 (AOS1), the Permittee shall use


(4) Alternative Operating Scenario 1 (AOS1)

(A) The Permittee shall use oils containing no more than 4.84 pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8.

(B) The VOC emissions from the evaporating oil usage on all fin mills, tube mills, and

turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 shall not exceed eighty-eight hundredths (0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.


(C) VOC emissions from Braze Line #8 shall be controlled by the Vorcinerator afterburner.

(D) The overall efficiency for the Vorcinerator (including the capture efficiency and


(5) The Permittee shall use a micro-coat application system on all fin mills, tube mills, and

turbulator mills to minimize oil usage. (g) 326 IAC 12 (New Source Performance Standards)

See Federal Rule Applicability Section of this TSD. (h) 326 IAC 20 (Hazardous Air Pollutants)

See Federal Rule Applicability Section of this TSD.

Compliance Determination, Monitoring and Testing Requirements (a) The compliance determination and monitoring requirements applicable to this proposed revision

are as follows:

Control Parameter Frequency Range Excursions and Exceedances

Vorcinerator afterburner

Afterburner Temperature1

Continuous (once per 15 min)

3-hour average ≥ 1,400 °F or the 3-hour average temperature from the latest compliant stack test

Response Steps

Duct Pressure or Fan Amperage1

Daily As determined during testing Response Steps

Notes: 1. These monitoring conditions are necessary because the control device must operate properly in order to

ensure compliance with 326 IAC 8-1-6 (BACT).

These monitoring conditions are necessary because the Vorcinerator afterburner for the Braze Line #8 core conditioning oven must operate properly to ensure compliance with 326 IAC 8-1-6 (BACT).

(b) The testing requirements applicable to this proposed revision are as follows:

Summary of Testing Requirements

Emission Unit

Control Device

Timeframe for Initial Testing*

Pollutant Frequency of Testing

Authority

Braze Line #8 core conditioning oven

Vorcinerator afterburner 180 days VOC Once every

5 years 326 IAC 2-8

* 180 days is 180 days after issuance of SPR No. 031-36237-00014.

Proposed Changes The following changes listed below are due to the proposed revision. Deleted language appears as strikethrough text and new language appears as bold text: Summary of Updates Throughout the Permit


(a) Descriptive information about the NOCOLOK radiator, condenser, and charge air cooler manufacturing process has been revised to reflect the modifications to the emissions units.

(b) IDEM added the rule citation 326 IAC 2-8-4(1) to the Compliance Determination Requirements subsection title in Sections D. 1 and D.3 to clarify the authority of these conditions.

Section A - Revisions

Section A has been revised to incorporate the appropriate updates detailed above under "Summary of Updates Throughout the Permit."

Section A has been revised as follows: ... A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-8-3(c)(3)]

This stationary source consists of the following emission units and pollution control devices: (a) One (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process,

consisting of the following: (1) One (1) Core assembly process, identified as Core Assembly, constructed in

1995, consisting of associated fin mills, core builders, tube mills, turbulators, and other related equipment, using evaporative oils containing a maximum VOC content of two and four tenths (2.4) no more than two and four tenths (2.4) pounds of VOC per gallon of oil or less, uncontrolled and exhausting inside the building. This process was approved for modification in 2013 for construction of an additional tube mill.


(2) ... (7) One (1) braze line, identified as Braze Line #8, constructed in 2009 and

approved in 2015 for modification, with a maximum capacity of two hundred (200) radiators (5,718 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat

input capacity of four (4.0) MMBtu per hour, uncontrolledwith VOC emissions controlled by a Vorcinerator afterburner, and exhausting at stack PE-59;

(B) ...

(8) Powder coating operations, constructed in 1989, and including the following:


(A) One (1) electrostatic powder paint booth and filter system, identified as paint booth #2, with a maximum material usage rate of twenty-three (23.0) sixty (60.00) pounds of paint per hour, controlled by one (1) integral cartridge filter system used to reclaim the unused powder paint for reuse, and a second filter system for particulate control, and exhausting inside the building;...

(B) ... (D) One (1) paint bake oven, identified as Paint Bake Oven 2, approved

in 2015 for construction, with a maximum heat input capacity of 3.00 MMBtu/hr, uncontrolled and exhausting to a stack.

(9) ... (11) One (1) spray fluxer, identified as Stand-Alone Spray Fluxer, with a

maximum capacity of eleven (11.0) pounds of flux per hour, uncontrolled and exhausting outside the building.

... Section D.1 - Revisions

(a) Section D.1 was updated to current model language. (b) Condition D.1.1 was revised to incorporate the reopened BACT determination (c) A new Condition D.1.2 - FESOP Minor Limits was added to limit the source-wide potential

to emit VOC to less than 100 tons per twelve (12) consecutive month period. (d) References to new VOC content and usage limits in Conditions D.1.1(d)(2) and D.1.2

were added to Condition D.1.6 Volatile Organic Compounds (VOC). (e) A new Condition D.1.8 - VOC Control was added to incorporate compliance determination

requirements for the Vorcinerator afterburner. (f) A new Condition D.1.9 - Testing Requirements was added to incorporate testing

requirements for the Vorcinerator afterburner. (g) A new condition D.1.10 - VOC Emissions was added to incorporate compliance

determination formulas for the VOC limits in Conditions D.1.1(a), D.1.1(d)(2), and D.1.2. (h) Compliance monitoring requirements for the Vorcinerator afterburner have been added in

new Condition D.1.11 - Vorcinerator Afterburner Temperature and Condition D.1.12 - Parametric Monitoring - Vorcinerator Afterburner Duct Pressure or Fan Amperage

(i) Record keeping requirements for new compliance determination and monitoring requirements were added to Condition D.1.13 - Record Keeping Requirements.

(j) Reporting requirements for the VOC usage limit in Conditions D.1.1(d)(2) and D.1.2 were added to Condition D.1.14 - Reporting Requirements.

(k) Section D.1 has been revised to incorporate the appropriate updates detailed above under "Summary of Updates Throughout the Permit."

(l) Conditions and paragraphs were renumbered as appropriate to insertions.

Section D.1 has been revised as follows: SECTION D.1 EMISSION EMISSIONS UNIT OPERATION CONDITIONS

Emission Emissions Unit Description [326 IAC 2-8-4(10)]: (a) One (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process, consisting

of the following: (1) One (1) Core assembly process, identified as Core Assembly, constructed in 1995,


consisting of associated fin mills, core builders, tube mills, turbulators, and other related equipment, using evaporative oils containing a maximum VOC content of two and four tenths (2.4) no more than two and four tenths (2.4) pounds of VOC per gallon of oil or less, uncontrolled and exhausting inside the building. This process was approved for modification in 2013 for construction of an additional tube mill.


(2) ... (7) One (1) braze line, identified as Braze Line #8, constructed in 2009 and approved in

2015 for modification, with a maximum capacity of two hundred (200) radiators (5,718 pounds) per hour and consisting of the following: (A) One (1) natural gas-fired core conditioning oven with a maximum heat input

capacity of four (4.0) MMBtu per hour, uncontrolledwith VOC emissions controlled by a Vorcinerator afterburner, and exhausting at stack PE-59;

(B) ...

(8) Powder coating operations, constructed in 1989, and including the following:

(A) One (1) electrostatic powder paint booth and filter system, identified as paint

booth #2, with a maximum material usage rate of twenty-three (23.0) sixty (60.00) pounds of paint per hour, controlled by one (1) integral cartridge filter system used to reclaim the unused powder paint for reuse, and a second filter system for particulate control, and exhausting inside the building;

(B) ... (D) One (1) paint bake oven, identified as Paint Bake Oven 2, approved in 2015

for construction, with a maximum heat input capacity of 3.00 MMBtu/hr, uncontrolled and exhausting to a stack.

(9) ...

(11) One (1) spray fluxer, identified as Stand-Alone Spray Fluxer, with a maximum

capacity of eleven (11.0) pounds of flux per hour, uncontrolled and exhausting outside the building.

(The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Valeo North America, Inc. Page 15 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan Emission Limitations and Standards [326 IAC 2-8-4(1)]

D.1.1 BACT Limit [326 IAC 8-1-6] Pursuant to 326 IAC 8-1-6 (BACT), the Permittee shall comply with the following: (a) The VOC input emissions from the evaporating oil usage in the one (1) NOCOLOK

radiator, condenser, and charge air cooler manufacturing process shall not exceed eighty-seven (87.0) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.


VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Lines #1, #2, #3, #5, and #6;

(c) Unless operating under Alternative Operating Scenario 1 (AOS1), the Permittee

shall use oils containing no more than two and four tenths (2.4) pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8.


(1) The Permittee shall use oils containing no more than 4.84 pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 radiator production.

(2) The VOC emissions from the evaporating oil usage on all fin mills, tube

mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 radiator production shall not exceed eighty-eight hundredths (0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(3) VOC emissions from Braze Line #8 radiator production shall be controlled

by the Vorcinerator afterburner. (4) The overall efficiency for the Vorcinerator (including the capture efficiency

and destruction efficiency) shall be at least 95%, or the VOC outlet concentration shall not exceed 10 ppmv.

(ce) The Permittee shall use a micro-coat application system on all fin mills, tube mills, and

turbulator mills to minimize oil usage. D.1.2 FESOP Minor Limits [326 IAC 2-8-4]

Pursuant to 326 IAC 2-8-4 (FESOP), the VOC emissions from evaporating oil usage on all fin mills, tube mills, and turbulator mills in the Core assembly process and flux usage on the tube mill with brazing and fluxing stations shall not exceed 95.81 tons of VOC per twelve (12) consecutive month period, with compliance determined at the end of each month. Compliance with this limit, combined with the potential to emit of VOC from all other units at the source, shall limit the potential to emit of VOC from the entire source to less than 100 tons per twelve (12) consecutive month period and shall render the requirements of 326 IAC 2-7 (Part 70 Permit Program) not applicable.

Valeo North America, Inc. Page 16 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan D.1.23 Particulate [326 IAC 6-3]

(a) ... D.1.34 Incinerators [326 IAC 4-2-2]

... D.1.45 Preventive Maintenance Plan [326 IAC 2-8-4(9)]

... Compliance Determination Requirements [326 IAC 2-8-4(1)] D.1.56 Volatile Organic Compounds (VOC) [326 IAC 8-1-2][326 IAC 8-1-4]

Compliance with the VOC content and usage limits contained in Condition D.1.1(a), D.1.1(d)(2), and D.1.2 shall be determined pursuant to 326 IAC 8-1-4(a)(3) and 326 IAC 8-1-2(a) by preparing or obtaining from the manufacturer the copies of the “as supplied” and “as applied” VOC data sheets. IDEM, OAQ, reserves the authority to determine compliance using Method 24 in conjunction with the analytical procedures specified in 326 IAC 8-1-4.

D.1.67 Particulate Control

In order to comply with Condition D.1.23(b), the integral cartridge filter system used in conjunction with the electrostatic powder coating operation, shall be in operation and control emissions from the one (1) electrostatic powder paint booth (identified as paint booth #2) at all times when paint booth #2 is in operation.

D.1.8 VOC Control

When operating under AOS1, in order to assure compliance with Condition D.1.1(d)(2), the Vorcinerator afterburner for VOC control shall be in operation and control emissions from the Braze Line #8 core conditioning oven facility at all times the Braze Line #8 core conditioning oven facility is in operation.

D.1.9 Testing Requirements [326 IAC 2-1.1-11]

Not later than 180 days after the issuance date of this permit, Permit No 031-36237-00014, the Permittee shall perform VOC testing of the Vorcinerator afterburner utilizing methods approved by the commissioner at least once every 5 years from the date of the most recent valid compliance demonstration. Testing shall be conducted in accordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C – Performance Testing contains the Permittee’s obligation with regard to the performance testing required by this condition.

D.1.10 VOC Emissions (a) Compliance with the VOC emissions limit in Condition D.1.1(a) shall be

demonstrated by the summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

V = [Σ(CL x UL) + 0.05 x Σ(CAOS1 x UAOS1)] 2,000

Where V = VOC emissions (tons/month) Unless operating under AOS1:


UL = Usage of a single oil containing no more than 2.4 pounds of


VOC per gallon of oil processed on Braze Lines #1, #2, #3, #5, #6, and #8 (gal/mo)

When operating under AOS1



(b) Compliance with the VOC emissions limit in Condition D.1.1(d)(2) shall be

demonstrated by the summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

VAOS1 = [ 0.05 x Σ(CAOS1 x UAOS1)] 2,000

Where VAOS1 = VOC emissions when operating under Alternative Operating

Scenario 1 (tons/month) CAOS1 = VOC content of a single oil containing no more than 4.84

pounds of VOC per gallon of oil processed on Braze Line #8 (lb/gal)


(c) Compliance with the VOC emissions limit in Condition D.1.2 shall be demonstrated

by the summation of twelve (12) consecutive monthly emission rates calculated by the following equation:

E = [Σ(CL x UL) + 0.05 x Σ(CAOS1 x UAOS1) + Σ (CF x UF)] 2,000

Where E = VOC emissions (tons/month)





CF = VOC content of a single flux used on the tube mill with brazing and fluxing stations (lb/gal)

UF = Usage of a single flux used on the tube mill with brazing and fluxing stations (gal/mo)

Compliance Monitoring Requirements [326 IAC 2-8-4][326 IAC 2-8-5(a)(1)]

D.1.11 Vorcinerator Afterburner Temperature (a) A continuous monitoring system shall be calibrated, maintained, and operated on

the Vorcinerator afterburner for measuring operating temperature. For the purpose


of this condition, continuous means no less often than once per fifteen (15) minutes. The output of this system shall be recorded as 3-hour average. From the date of startup until the stack test results are available, the Permittee shall operate the thermal oxidizer at or above the 3-hour average temperature of 1,472°F.

(b) The Permittee shall determine the 3-hour average temperature from the latest valid

stack test that demonstrates compliance with limits in Condition D.1.1(d)(4). (c) On and after the date the stack test results are available, the Permittee shall

operate the thermal oxidizer at or above the 3-hour average temperature as observed during the latest compliant stack test.

(d) If the 3-hour average temperature falls below the above mentioned 3-hour average

temperature, the Permittee shall take a reasonable response. Section C - Response to Excursions or Exceedances contains the Permittee's obligation with regard to the response steps required by this condition. Failure to take response steps shall be considered a deviation from this permit.

D.1.12 Parametric Monitoring - Vorcinerator Afterburner Duct Pressure or Fan Amperage

(a) The Permittee shall determine the appropriate duct pressure or fan amperage from the latest valid stack test that demonstrates compliance with limits in Condition D.1.1(d)(4).

(b) The duct pressure or fan amperage shall be observed at least once per day when

the Vorcinerator afterburner is in operation. On and after the date the stack test results are available, the duct pressure or fan amperage shall be maintained within the normal range as established in latest compliant stack test.

(c) When, for any one reading, the duct pressure or fan amperage is outside the above

mentioned range, the Permittee shall take a reasonable response. Section C - Response to Excursions and Exceedances contains the Permittee's obligation with regard to the reasonable response steps required by this condition. A reading that is outside the above mentioned range is not a deviation from this permit. Failure to take response steps shall be considered a deviation from this permit.

(d) The instruments used for determining the pressure drop shall comply with Section

C – Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ, and shall be calibrated or replaced at least once every six (6) months.

Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)][326 IAC 2-8-16]

D.1.713 Record Keeping Requirements (a) To document the compliance status with Condition Conditions D.1.1(a) and D.1.2, the

Permittee shall maintain records in accordance with (1) through (3) (8) below. Records maintained for (1) through (3) (8) shall be taken as stated below and shall be complete and sufficient to establish compliance with the VOC content and VOC usage limits established in Condition Conditions D.1.1 and D.1.2. (1) The VOC content of each evaporating oil used;. (2) The amount of each evaporating oils used on a monthly basis. Records shall

include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used; and.


(3) The total VOC usageinput for each month. (4) During periods when operating under AOS1:

(A) The VOC content of each evaporating oil used. (B) The amount of each evaporating oil used on a monthly basis.

Records shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.

(C) The total VOC input for each month.

(5) The total VOC emitted from the input of evaporative oils for each month

and each compliance period. (6) The VOC content of flux used in the tube mill with brazing and fluxing

stations.

(7) The amount of flux used in the tube mill with brazing and fluxing stations on a monthly basis. Records shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.

(7) The amount of VOC emitted from the input of evaporative oil and flux for

each month and each compliance period. (b) To document the compliance status with Condition D.1.11, the Permittee shall

maintain continuous temperature records for the Vorcinerator afterburner and the 3-hour average temperature used to demonstrate compliance during the most recent compliant stack test.

(c) To document the compliance status with Condition D.1.12, the Permittee shall

maintain daily records of the duct pressure or fan amperage for the Vorcinerator afterburner. The Permittee shall include in its daily record when the readings are not taken and the reason for the lack of the readings (e.g. the process did not operate that day).

(bd) Section C - General Record Keeping Requirements contains the Permittee's obligations

with regard to the records required by this condition.

D.1.814 Reporting Requirements A quarterly summary of the information to document the compliance status with Condition Conditions D.1.1(a), D.1.1(d)(2) and D.1.2 shall be submitted using the reporting form forms located at the end of this permit, or its their equivalent, not later than thirty (30) days after the end of the quarter being reported. Section C - General Reporting contains the Permittee's obligation with regard to the reporting required by this condition. The report submitted by the Permittee does require a certification that meets the requirements of 326 IAC 2-8-5(a)(1) by an “authorized individual” as defined by 326 IAC 2-1.1-1(1).

Section D.3 - Revisions

Section D.3 has been revised to incorporate the appropriate updates detailed above under "Summary of Updates Throughout the Permit."


Section D.3 has been revised as follows: ... Compliance Determination Requirements [326 IAC 2-8-4(1)] ... Reporting Forms - Revisions

(a) 326 IAC 2-8-12 states that the Permittee must notify IDEM within "four (4) daytime business hours" for emergencies. The FESOP Emergency Occurrence Report Form lacked the word 'daytime'. 'Daytime' is being added to be consistent with the rule. In addition, the existing rule cite is being corrected to refer to the FESOP rules.

(b) The FESOP Quarterly Report form for the VOC input to the NOCOLOK process was revised to incorporate the revised limit from Condition D.1.1(a).

(c) The Quarterly Report form has been modified to remove the numbered months. The Permittee should state which months are being reported.

(c) A new FESOP Quarterly Report form was added for the VOC emissions limit at Condition D.1.1(d)(2).

(d) A new FESOP Quarterly Report form was added for the FESOP VOC limit at Condition D.1.2.

Reporting Forms have been revised as follows: ...



100 North Senate Avenue MC 61-53 IGCN 1003

Indianapolis, Indiana 46204-2251 Phone: (317) 233-0178

Fax: (317) 233-6865

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) EMERGENCY OCCURRENCE REPORT

Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 This form consists of 2 pages Page 1 of 2

This is an emergency as defined in 326 IAC 2-7-1(12)

• The Permittee must notify the Office of Air Quality (OAQ), within four (4) daytime business hours (1-800-451-6027 or 317-233-0178, ask for Compliance Section); and

• The Permittee must submit notice in writing or by facsimile within two (2) working days (Facsimile Number: 317-233-6865), and follow the other requirements of 326 IAC 2-7-16 2-8-12

...

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT


OFFICE OF AIR QUALITY


FESOP Quarterly Report Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing process. Parameter: Volatile Organic Compounds (VOCs) Limit: Volatile Organic Compound (VOC) input emissions from the evaporating oil

usage of evaporating oils in the one (1) NOCOLOK radiator, condenser, and charge air cooler manufacturing process shall not exceed eighty-seven (87) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total

Month 1

Month 2

Month 3

...




Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing

process. Parameter: Volatile Organic Compounds (VOCs) Limit: The VOC emissions from the evaporating oil usage on all fin mills, tube

mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 shall not exceed eighty-eight hundredths


(0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total



INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY


FESOP Quarterly Report Source Name: Valeo North America, Inc. Source Address: 1100 East Barachel Lane, Greensburg, Indiana 47240 FESOP Permit No.: F031-29500-00014 Facility: NOCOLOK radiator, condenser, and charge air cooler manufacturing process. Parameter: Volatile Organic Compounds (VOCs) Limit: The VOC emissions from evaporating oil usage on all fin mills, tube mills,

and turbulator mills in the Core assembly process and flux usage on the tube mill with brazing and fluxing stations shall not exceed 95.81 tons of


VOC per twelve (12) consecutive month period, with compliance determined at the end of each month.

QUARTER: ___________ YEAR: _____________

Month

Column 1

Column 2

Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total



Conclusion and Recommendation

Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant. An application for the purposes of this review was received on September 3, 2015. The construction and operation of this proposed revision shall be subject to the conditions of the attached proposed FESOP Significant Permit Revision No. 031-36237-00014. The staff recommends to the Commissioner that this FESOP Significant Permit Revision be approved.

IDEM Contact (a) Questions regarding this proposed permit can be directed to (permit writer’s name) at the Indiana

Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) (phone number) or toll free at 1-800-451-6027 extension (extension number).

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/ai/appfiles/idem-caats/

Valeo North America, Inc. Page 24 of 24 Greensburg, Indiana TSD for FESOP SPR No. 031-36237-00014 Permit Reviewer: Doug Logan (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM Permit Guide on the Internet at: http://www.in.gov/idem/5881.htm; and the Citizens' Guide to IDEM on the Internet at: http://www.in.gov/idem/6900.htm.

http://www.in.gov/idem/5881.htm

http://www.in.gov/idem/6900.htm

of 21 TSD App AAppendix A: Emissions Calculations

PTE Summary

Company Name: Valeo North America, Inc.Source Address: 1100 East Barachel Lane, Greensburg, IN 47240

Permit No: 031-29500-00014Significant Permit Revision No.: 031-36237-00014

Reviewer: Doug LoganDate: 11/12/2015

Uncontrolled Potential to Emit (tons/year) Emissions Generating Activity

Category Pollutant

Core Assembly (Fin Mills/Tube

Mills/Turbulators) (Process)

Tube Mill (oil) (Process)

Tube Mill (flux) (Process)

Core Conditioning

Ovens (Combustion)

Spray Fluxers (Process)

Flux Dry-Off Ovens

(Combustion)

Braze Ovens with Cooling

Stations (Process)

Tube Mill (brazing) (Process)

Convection Pre Heat Chamber (Braze Line #8) (Combustion)

Electrostatic Powder Paint

Booth α

(Process)

Paint Bake Ovens

(Combustion)

Paint Hook Burn-Off Oven

(Process)

Paint Hook Burn-Off Oven (Combustion)

Robotic Welders (MIG)

(Process)

Natural Gas-Fired Boiler

(Combustion)

Air Handlers (Combustion)

Abrasive Blasting Booth

(Process)

Molding Treatment

Station (Process)

Injection Molding (IM)

Machines (Process)

TOTAL

Criteria PM 0 0 2.21 0.14 2.11 5.30E-02 24.80 3.31 1.63E-02 1.31 3.67E-02 6.57 3.88E-03 0.44 1.19E-02 0.30 17.52 0 1.43 60.27Pollutants PM10 0 0 2.21 0.58 2.11 0.21 24.80 3.31 6.53E-02 1.31 0.15 6.57 1.55E-02 0.44 4.76E-02 1.20 15.07 0 1.43 59.52

PM2.5 0 0 2.21 0.58 2.11 0.21 24.80 3.31 6.53E-02 1.31 0.15 6.57 1.55E-02 0.44 4.76E-02 1.20 15.07 0 1.43 59.52SO2 0 0 0 4.56E-02 0 1.67E-02 0 0 5.15E-03 0 1.16E-02 0 1.22E-03 0 3.76E-03 9.49E-02 0 0 0 0.18NOx 0 0 0 7.60 0 2.79 0 0 0.86 0 1.93 0 0.20 0 0.63 15.81 0 0 0 29.83VOC 96.47 1.42 19.06 0.42 0 0.15 0 0 4.72E-02 0 0.11 0 1.12E-02 0 3.45E-02 0.87 0 0.29 1.33 120.21CO 0 0 0 6.38 0 2.34 0 0 0.72 0 1.62 0 0.17 0 0.53 13.28 0 0 0 25.05

Hazardous Acetaldehyde 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3.70E-02 3.70E-02Air Acrolein 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6.57E-04 6.57E-04Pollutants Benzene 0 0 0 1.60E-04 0 5.86E-05 0 0 1.80E-05 0 4.06E-05 0 4.28E-06 0 1.32E-05 3.32E-04 0 0 0 6.26E-04

Dichlorobenzene 0 0 0 9.12E-05 0 3.35E-05 0 0 1.03E-05 0 2.32E-05 0 2.45E-06 0 7.52E-06 1.90E-04 0 0 0 3.58E-04Ethylbenzene 2.19 7.05E-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2.19Formaldehyde 0 0 0 5.70E-03 0 2.09E-03 0 0 6.44E-04 0 1.45E-03 0 1.53E-04 0 4.70E-04 1.19E-02 0 0 4.63E-02 6.87E-02

n-Hexane 0 0 0 0.14 0 5.02E-02 0 0 1.55E-02 0 3.48E-02 0 3.67E-03 0 1.13E-02 0.28 0 6.38E-02 0 0.60Propionaldehyde 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6.37E-03 6.37E-03

Toluene 2.19 7.05E-05 0 2.58E-04 0 9.49E-05 0 0 2.92E-05 0 6.57E-05 0 6.94E-06 0 2.13E-05 5.38E-04 0 0 0 2.20Xylenes 2.21 2.82E-04 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2.21

Cadmium 0 0 0 8.36E-05 0 3.07E-05 0 0 9.45E-06 0 2.13E-05 0 2.24E-06 0 6.90E-06 1.74E-04 0 0 0 3.28E-04Chromium 0 0 0 1.06E-04 0 3.91E-05 0 0 1.20E-05 0 2.71E-05 0 2.86E-06 9.71E-03 8.78E-06 2.21E-04 0 0 0 1.01E-02

Lead 0 0 0 3.80E-05 0 1.40E-05 0 0 4.29E-06 0 9.66E-06 0 1.02E-06 0 3.13E-06 7.91E-05 0 0 0 1.49E-04Manganese 0 0 0 2.89E-05 0 1.06E-05 0 0 3.26E-06 0 7.34E-06 0 7.75E-07 6.37E-03 2.38E-06 6.01E-05 0 0 0 6.48E-03

Nickel 0 0 0 1.60E-04 0 5.86E-05 0 0 1.80E-05 0 4.06E-05 0 4.28E-06 2.30E-02 1.32E-05 3.32E-04 0 0 0 2.36E-02Totals 6.60 4.23E-04 0 0.14 0 5.27E-02 0 0 1.62E-02 0 3.65E-02 0 3.85E-03 3.91E-02 1.18E-02 0.30 0 6.38E-02 9.03E-02 7.36

Total emissions based on rated capacity at 8,760 hours/year.α The cartridge filter system serving the Powder Paint Booth is considered "integral" to the powder coating operation. Therefore, the permitting level is is determined after consideration of the control device.

Potential to Emit After Issuance (tons/year) Emissions Generating Activity

Category Pollutant

Core Assembly (Fin Mills/Tube

Mills/Turbulators) (Process)

Tube Mill (oil) (Process)

Tube Mill (flux) (Process)

Core Conditioning

Ovens (Combustion)

Spray Fluxers (Process)

Flux Dry-Off Ovens

(Combustion)

Braze Ovens with Cooling

Stations (Process)

Tube Mill (brazing) (Process)

Convection Pre Heat Chamber (Braze Line #8) (Combustion)

Electrostatic Powder Paint

Booth α

(Process)

Paint Bake Ovens

(Combustion)

Paint Hook Burn-Off Oven

(Process)

Paint Hook Burn-Off Oven (Combustion)

Robotic Welders (MIG)

(Process)

Natural Gas-Fired Boiler

(Combustion)

Air Handlers (Combustion)

Abrasive Blasting Booth

(Process)

Molding Treatment

Station (Process)

Injection Molding (IM)

Machines (Process)

TOTAL

Criteria PM 0 0 2.21 0.14 2.11 5.30E-02 24.80 3.31 1.63E-02 1.31 3.67E-02 6.57 3.88E-03 0.44 1.19E-02 0.30 17.52 0 1.43 60.27Pollutants PM10 0 0 2.21 0.58 2.11 0.21 24.80 3.31 6.53E-02 1.31 0.15 6.57 1.55E-02 0.44 4.76E-02 1.20 15.07 0 1.43 59.52

PM2.5 0 0 2.21 0.58 2.11 0.21 24.80 3.31 6.53E-02 1.31 0.15 6.57 1.55E-02 0.44 4.76E-02 1.20 15.07 0 1.43 59.52SO2 0 0 0 4.56E-02 0 1.67E-02 0 0 5.15E-03 0 1.16E-02 0 1.22E-03 0 3.76E-03 9.49E-02 0 0 0 0.18NOx 0 0 0 7.60 0 2.79 0 0 0.86 0 1.93 0 0.20 0 0.63 15.81 0 0 0 29.83VOC 0.42 0 0.15 0 0 4.72E-02 0 0.11 0 1.12E-02 0 3.45E-02 0.87 0 0.29 1.33 99.07CO 0 0 0 6.38 0 2.34 0 0 0.72 0 1.62 0 0.17 0 0.53 13.28 0 0 0 25.05

Hazardous Acetaldehyde 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3.70E-02 3.70E-02Air Acrolein 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6.57E-04 6.57E-04Pollutants Benzene 0 0 0 1.60E-04 0 5.86E-05 0 0 1.80E-05 0 4.06E-05 0 4.28E-06 0 1.32E-05 3.32E-04 0 0 0 6.26E-04

Dichlorobenzene 0 0 0 9.12E-05 0 3.35E-05 0 0 1.03E-05 0 2.32E-05 0 2.45E-06 0 7.52E-06 1.90E-04 0 0 0 3.58E-04Ethylbenzene 2.19 7.05E-05 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2.19Formaldehyde 0 0 0 5.70E-03 0 2.09E-03 0 0 6.44E-04 0 1.45E-03 0 1.53E-04 0 4.70E-04 1.19E-02 0 0 4.63E-02 6.87E-02

n-Hexane 0 0 0 0.14 0 5.02E-02 0 0 1.55E-02 0 3.48E-02 0 3.67E-03 0 1.13E-02 0.28 0 6.38E-02 0 0.60Propionaldehyde 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6.37E-03 6.37E-03

Toluene 2.19 7.05E-05 0 2.58E-04 0 9.49E-05 0 0 2.92E-05 0 6.57E-05 0 6.94E-06 0 2.13E-05 5.38E-04 0 0 0 2.20Xylenes 2.21 2.82E-04 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2.21

Cadmium 0 0 0 8.36E-05 0 3.07E-05 0 0 9.45E-06 0 2.13E-05 0 2.24E-06 0 6.90E-06 1.74E-04 0 0 0 3.28E-04Chromium 0 0 0 1.06E-04 0 3.91E-05 0 0 1.20E-05 0 2.71E-05 0 2.86E-06 9.71E-03 8.78E-06 2.21E-04 0 0 0 1.01E-02

Lead 0 0 0 3.80E-05 0 1.40E-05 0 0 4.29E-06 0 9.66E-06 0 1.02E-06 0 3.13E-06 7.91E-05 0 0 0 1.49E-04Manganese 0 0 0 2.89E-05 0 1.06E-05 0 0 3.26E-06 0 7.34E-06 0 7.75E-07 6.37E-03 2.38E-06 6.01E-05 0 0 0 6.48E-03

Nickel 0 0 0 1.60E-04 0 5.86E-05 0 0 1.80E-05 0 4.06E-05 0 4.28E-06 2.30E-02 1.32E-05 3.32E-04 0 0 0 2.36E-02Totals 6.60 4.23E-04 0 0.14 0 5.27E-02 0 0 1.62E-02 0 3.65E-02 0 3.85E-03 3.91E-02 1.18E-02 0.30 0 6.38E-02 9.03E-02 7.36

Total emissions based on rated capacity at 8,760 hours/year.(1) Limited PTE based upon annual VOC input limit to comply with 326 8-1-6 BACT.α The cartridge filter system serving the Powder Paint Booth is considered "integral" to the powder coating operation. Therefore, the permitting level is is determined after consideration of the control device.

95.81

of 21 TSD App A

Appendix A: Emissions CalculationsRevision Summary




Uncontrolled Potential to Emit of Modified Units Before this Revision (tons/year)Emission Unit PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Core Assembly1 - - - - - 87.56 - 3.50E-02Tube Mill (oil & flux)2 - - - - - 1.28 - -Powder Paint Booth1 0.50 0.50 0.50 - - - - -

Total 0.50 0.50 0.50 0 0 88.85 0 3.50E-02

Uncontrolled Potential to Emit of Modified Units After this Revision (tons/year)Emission Unit PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Core Assembly - - - - - 96.47 - 6.60Tube Mill (oil & flux)3 - - - - - 1.42 - -Powder Paint Booth 1.31 1.31 1.31 - - - - -

Total 1.31 1.31 1.31 0 0 97.89 0 6.60

Uncontrolled Potential to Emit of New Units (tons/year)Emission Unit PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Stand-alone Spray Fluxer 0.16 0.16 0.16 - - - - -Paint Bake Oven 2 2.45E-02 0.10 0.10 7.73E-03 1.29 7.09E-02 1.08 2.43E-02

Total 0.19 0.26 0.26 7.73E-03 1.29 7.09E-02 1.08 2.43E-02

Uncontrolled Potential to Emit of This Revision (tons/year)PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Increased PTE of the Modified Units4 0.81 0.81 0.81 0 0 9.04 0 6.56PTE of the New Units 0.19 0.26 0.26 7.73E-03 1.29 0.07 1.08 0.02

Total PTE of this Revision 1.00 1.07 1.07 7.73E-03 1.29 9.11 1.08 6.59

Notes:1. Source: TSD App A, AA No. 031-35118-00014, issued December 18, 20142. Source: tab of this name, TSD App A, MPR No. 031-34108-00014, issued March 20, 2014, value is PTE of evaporative oil at this unit.3. Source: tab of this name, value is PTE of evaporative oil at this unit4. Greater of 0 or [PTE After - PTE Before]

of 21 TSD App A

Appendix A: Emissions CalculationsNatural Gas Combustion Only

MM BTU/HR <100Paint Bake Oven 2




HHVHeat Input Capacity mmBtu Potential Throughput

MMBtu/hr mmscf MMCF/yr3.0 1020 25.8

Pollutant PM* PM10* direct PM2.5* SO2 NOx VOC COEmission Factor in lb/MMCF 1.9 7.6 7.6 0.6 100 5.5 84

**see belowPotential Emission in tons/yr 2.45E-02 0.10 0.10 7.73E-03 1.29 7.09E-02 1.08*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.PM2.5 emission factor is filterable and condensable PM2.5 combined.**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

MethodologyAll emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMCF = 1,000,000 Cubic Feet of GasEmission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Hazardous Air Pollutants (HAPs)

Benzene Dichlorobenzene Formaldehyde Hexane Toluene Total - Organics

Emission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emission in tons/yr 2.71E-05 1.55E-05 9.66E-04 2.32E-02 4.38E-05 2.42E-02

Lead Cadmium Chromium Manganese Nickel Total - MetalsEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emission in tons/yr 6.44E-06 1.42E-05 1.80E-05 4.90E-06 2.71E-05 7.06E-05Methodology is the same as above. Total HAPs 2.43E-02The five highest organic and metal HAPs emission factors are provided above. Worst HAP 2.32E-02Additional HAPs emission factors are available in AP-42, Chapter 1.4.

HAPs - Organics

HAPs - Metals

of 21 TSD App A

Appendix A: Emission CalculationsProcess Emissions from the Core Assembly



Reviewer: Doug Logan Date: 11/12/2015

Emission Unit # of mills in unit

Max. Usage Rate per mill

(gal/hour)

Total Oil Usage (gal/hr)

Fin Mills 23 0.20 4.60Tube Mills 5 0.50 2.50

Fin Mill 1 0.50 0.50Turbulator Mill 1 0.20 0.20

Mitsubishi Fin Mills 0 0.20 0.00Turbulator Mills 1 0.53 0.53

Total 8.33

Volatile Organic Compound (VOC) Emissions

Emission Unit Product ID Density VOC Content Total Oil Usage Uncontrolled PTE Control PTE After Controls(lb/gal) (lbs/gal) (gal/hr) (lbs/hour) (tons/yr) Efficiency (lbs/hour) (tons/yr)

Low VOC oil1 - - 2.40 7.50 17.99 78.81 0% 17.99 78.81

Braze Line 82 Martol LVG 15 CF 6.44 4.84 0.83 4.03 17.66 95% 0.20 0.88

Total 96.47 79.69

Hazardous Air Pollutant (HAP) Emissions

Emission Unit Product ID Density Total Oil Usage Weight % Weight % Weight %(lbs/gal) (gal/hr) Ethylbenzene Toluene Xylenes

CV-200 Premix 8.34 7.50 0.00% 0.00% 0.00%Low VOC oil DL-488A 6.67 7.50 1.00% 1.00% 1.00%

DL-502 6.67 7.50 1.00% 1.00% 1.00%DL-750 6.67 7.50 0.30% 0.30% 0.30%

Braze Line 8Martol LVG 15

CF4 6.44 0.83 0.02% 0.02% 0.08%

Emission Unit Product ID Uncontrolled Emissions (tons/yr) Control Controlled Emissions (tons/yr)Ethylbenzene Toluene Xylenes Efficiency Ethylbenzene Toluene Xylenes

CV-200 Premix 0.00 0.00 0.00 0% 0.00 0.00 0.00Low VOC oil DL-488A 2.19 2.19 2.19 0% 2.19 2.19 2.19

DL-5023 2.19 2.19 2.19 0% 2.19 2.19 2.19DL-750 0.66 0.66 0.66 0% 0.66 0.66 0.66

Braze Line 8 Martol LVG 15 CF 4.70E-03 4.70E-03 1.88E-02 95% 2.35E-04 2.35E-04 9.40E-04

Total 2.19 2.19 2.21 2.19 2.19 2.19Combined HAPs 6.60 6.57

Notes:Worst case alternatives shown in bold type included in the totals for the emissions unit.1. VOC PTE is based on worst-case VOC content for uncontrolled units in BACT determination2. Application stated that the volume of high VOC oil would be 10% of the total3. Applies default organic HAP content for aliphatic blends from Table 4, 40 CFR 63, Subpart MMMM to worst-case 100% CASRN 64741-89-5 named in SDS4. Applies default organic HAP content for aromatic blends from Table 4, 40 CFR 63, Subpart MMMM, to maximum 2% aromatic content given in SDS

METHODOLOGYPTE of VOC per mill (lbs/hour) = Density (lbs/gal) * Max. usage rate per mill (gal/hour) PTE of VOC per unit (lbs/hour) = [# of mills in unit * Density (lbs/gal) * Max. usage rate per mill (gal/hour)]PTE of VOC per unit (tons/year) = Density (lbs/gal) * Max. usage rate (gal/hour) * 8760 hours/year * 1 ton/2000 lbsHAPS emission rate per unit (tons/yr) = [# of mills in unit * Density (lb/gal) * Max. usage rate (gal/hour) * Weight % HAP * 8760 hrs/yr * 1 ton/2000 lbs]

of 21 TSD App A



Reviewer: Doug LoganBraze Line #1 3.2 Date: 11/12/2015Braze Line #3 4.0Braze Line #5 2.5Braze Line #6 4.0Braze Line #8 4.0

Total 17.70

* PM * PM10 PM2.5 SO2 ** NOx VOC COEmission Factor (lb/MMscf) 1.9 7.6 7.6 0.6 100 5.5 84.0

Potential To Emit (tons/year) 0.14 0.58 0.58 0.05 7.60 0.42 6.38

*PM emission factor is filterable PM only. PM10, and PM2.5, emission factors include filterable and condensable fractions combined.**Emission factor for NOx (Uncontrolled) = 100 lb/MMSCF.Emission factors are from AP-42, Chapter 1.4, Tables 1.4-1, and 1.4-2, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03 (July, 1998).All Emission factors are based on normal firing.

Benzene Dichlorobenzene Formaldehyde Hexane TolueneEmission Factor (lb/MMscf) 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03

Potential To Emit (tons/year) 1.6E-04 9.1E-05 5.7E-03 1.4E-01 2.6E-04

Lead Cadmuim Chromium Manganese NickelEmission Factor (lb/MMscf) 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03


The five highest organic and metal HAPs emission factors provided above are from AP-42, Chapter 1.4, Table 1.4-3 and 1.4-4 (July, 1998).Additional HAPs emission factors are available in AP-42, Chapter 1.4.

METHODOLOGYPotential throughput (MMscf/year) = Heat input capacity (MMBtu/hour) * 8760 hours/year * 1 MMscf/1020 MMBtuPTE (tons/year) = Potential throughput (MMscf/year) * Emission factor (lb/MMscf) * 1 ton/2000 lbs

HAPs - Metals

HAPs - Organics

Appendix A: Emission CalculationsNatural Gas Combustion Only (MMBtu/hour < 100)

Six (6) Core Conditioning Ovens

(MMscf/year)152.01

Pollutant

Heat Input Capacity(MMBtu/hour)

Potential Throughput

of 21 TSD App A

Appendix A: Emission CalculationsProcess Emissions from the Spray Fluxers




Emission Unit

Emission Rate of PM/PM10/PM2.5

per unit (lbs/hour)

No. of UnitsPTE of

PM/PM10/PM2.5 (tons/year)

Braze Lines #1, 3, 5 & 6 Spray

Fluxers10.037 4 0.65

Braze Line #8 Spray Fluxer2 0.296 1 1.30

Stand-alone Spray Fluxer3 0.037 1 0.16

Total 2.11

METHODOLOGYPTE of PM/PM10 (tons/year) = Emission rate (lbs/hour) * No. of Units * 8760 hours/year * 1 ton/2000 lbs

NOTES1. The Emission rate for Braze Lines # 1, 3, 5 & 6 spray fluxers comes from a stack test conducted at the source in 1995 on two fluxers.2. The emission rate for the Braze Line #8 spray fluxer (as determined on Page 4 of 5; TSD, Appendix A for revision # F031-28077-00014) = Emission rate for recently removed Braze Line #7 * Lb/hr throughput Line #8 / Lb/hr throughput of recently removed Braze Line #7.3. Stand-alone spray fluxer identical to Line #1, 3, 5, & 6 units

Assume all PM10 and PM2.5 emissions are equal to PM emissions, each.

of 21 TSD App A



Braze Line #1 1.20 Reviewer: Doug LoganBraze Line #3 1.50 Date: 11/12/2015Braze Line #5 1.50Braze Line #6 1.50Braze Line #8 0.80

Total 6.50








The five highest organic and metal HAPs emission factors provided above are from AP-42, Chapter 1.4, Table 1-4.2, 1.4-3 and 1.4-4 (July, 1998).Additional HAPs emission factors are available in AP-42, Chapter 1.4.


55.82

Pollutant

HAPs - Organics

HAPs - Metals


Six (6) Flux Dry Off Ovens

(MMscf/year)

Heat Input Capacity

Potential Throughput

(MMBtu/hour)

of 21 TSD App A

Appendix A: Emission CalculationsProcess Emissions from the Braze Ovens and Cool Down Stations




Emission Unit


per unit (lbs/hour)

No. of Units

Total PTE of PM/PM10/PM2.5

(tons/year)

PTE of PM/PM10/PM2.5

(lbs/hour) for each oven with

cooling station

Ovens for Braze Lines # 1, 3, 5, & 6 0.194 4 3.40 0.19

Ovens for Braze Line #2 0.388 1 1.70 0.39

Cool Down Stations for Braze Lines # 1, 3, 5, & 6

0.561 4 9.8 0.56

Cool Down Stations for Braze Line #2 1.122 1 4.9 1.12

Oven for Braze Line #8 0.291 1 1.27 0.29Cool Down Station for Braze Line #8 0.842 1 3.69 0.84

Total 24.8

*** Assume all PM10 and PM2.5 emissions are equal to PM emissions, each.

METHODOLOGYPTE of PM/PM10 (tons/year) = Emission rate (lbs/hour) * No. of units * 8760 hours/year * 1 ton/2000 lbs

** The emission rate for the Braze Line #8 Oven and Cool Down Station (as determined on Page 5 of 5;TSD, Appendix A for revision # F031-28077-00014) was estimated to be 1.5 * Emission Rate for recentlyremoved Braze Line #7, based on oven size.

The ovens for Braze Lines # 1, 2, 3, 5, 6 & 8 are powered by electricity; therefore, no combustion emissions have been calculated. The braze furnace convection pre-heat chamber for Braze Line #8 is natural gas-fired; therefore, combustion emissions are addressed on the following page of this appendix.

* The emission rates for Braze Lines #1, 2, 3, 5, & 6 Ovens and Cool Down Stations come from a stack test conducted in 1995 at the source.

of 21 TSD App A


One (1) Convection Pre-Heat Chamber for Braze Line #8





Potential To Emit (tons/year) 0.02 0.07 0.07 5.2E-03 0.86 0.05 0.72








Potential Throughput(MMBtu/hour) (MMscf/year)

HAPs - Organics

HAPs - Metals

2.00 17.18

Pollutant

Heat Input Capacity

of 21 TSD App A

Appendix A: Emission CalculationsElectrostatic Powder Paint Booth




Max. Usage Rate Transfer Potential to Emit PM/PM10/PM2.5 Control Potential to Emit PM/PM10/PM2.5Emission Unit of Powder Paint Efficiency Uncontrolled Efficiency After Controls

(lbs/hour) (%) (lbs/hr) (tons/year) (%) (lbs/hr) (tons/year)Paint Booth 2 60.0 50% 30.00 131.40 99% 0.30 1.31

Based on MSDS submitted by the source, there are no VOC or HAPs emissions contained in the powder paint. All of the powder paint is captured via a filter system and recycled for reuse. The cartridge filter system serving the Powder Paint Booth was determined to be "integral" to the powder coating operation in FESOP No. 031-21314-00014, issued April 24, 2006. Therefore, the permitting level is is determined after consideration of the controls.

It is assumed that all of the powder paint applied is equivalent to PM emissions.It is assumed that all PM10 and PM2.5 emissions, each, are equal to PM emissions.

METHODOLOGYPTE of PM/PM10/PM2.5 Uncontrolled (lbs/hr) = Max. usage rate (lbs/hour) * (1 - Transfer efficiency %)PTE of PM/PM10/PM2.5 Uncontrolled (tons/year) = Max. usage rate (lbs/hour) * (1 - Transfer efficiency %) * 8760 hours/year * 1 ton/2000 lbsPTE of PM/PM10 Controlled (prior to the 2nd filter system) (tons/year) = Max. usage rate (lbs/hour) * (1 - Transfer efficiency %) * (1- Control Efficiency (%)) * 8760 hours/year * 1 ton/2000 lbs

of 21 TSD App A

Appendix A: Emissions CalculationsNatural Gas Combustion Only

MM BTU/HR <100Paint Bake Ovens




Includes:Unit Capacity (MMBtu/hr)

Paint Bake Oven 1 1.50Paint Bake Oven 2 3.00Total 4.50

HHVHeat Input Capacity mmBtu Potential Throughput

MMBtu/hr mmscf MMCF/yr4.5 1020 38.6

Pollutant PM* PM10* direct PM2.5* SO2 NOx VOC COEmission Factor in lb/MMCF 1.9 7.6 7.6 0.6 100 5.5 84

**see belowPotential Emission in tons/yr 3.67E-02 0.15 0.15 1.16E-02 1.93 1.06E-01 1.62*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.PM2.5 emission factor is filterable and condensable PM2.5 combined.**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

MethodologyAll emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMCF = 1,000,000 Cubic Feet of GasEmission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Hazardous Air Pollutants (HAPs)

Benzene Dichlorobenzene Formaldehyde Hexane Toluene Total - Organics

Emission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emission in tons/yr 4.06E-05 2.32E-05 1.45E-03 3.48E-02 6.57E-05 3.64E-02

Lead Cadmium Chromium Manganese Nickel Total - MetalsEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emission in tons/yr 9.66E-06 2.13E-05 2.71E-05 7.34E-06 4.06E-05 1.06E-04Methodology is the same as above. Total HAPs 3.65E-02The five highest organic and metal HAPs emission factors are provided above. Worst HAP 3.48E-02Additional HAPs emission factors are available in AP-42, Chapter 1.4.

HAPs - Organics

HAPs - Metals

of 21 TSD App A

Appendix A: Emission CalculationsProcess Emissions from the Paint Hook Burn-Off Oven




Emission Unit Weight of dirty hook (lbs)

Weight of clean hook

(lbs)

No of Carriers/ batch

No of Hooks / batch

Actual No of Batches/ day

Weight burned-off (lbs/ day)

PTE of PM/PM10/PM2.5 (lbs/hour)

PTE of PM/PM10/PM2.5 (tons/year)

Paint Hook Burn-Off Oven 1.405 1.345 NA 200 1.00 12.0 1.50 6.57

METHODOLOGY** Assume all PM10 and PM2.5 emissions, each, are equal to PM emissions.Weight of PM Burned-off (lbs/day) = [Weight of dirty hooks (lbs) - Weight of clean hooks (lbs)] * No. of Hooks/ Batch * Actual no. of batches/dayPTE of PM/PM10 (lbs/hour) = Weight of PM Burned-Off (lbs/day) * 1 day/Hours of operationPTE of PM/PM10 (tons/year) = Weight of PM Burned-Off (lbs/day) * 1 day/Hours of operation * 8760 hours/year * 1 ton/2000 lbs

of 21 TSD App A


One (1) Paint Hook Burn-Off Oven





Potential To Emit (tons/year) 3.9E-03 0.02 0.02 1.2E-03 0.20 0.01 0.17








HAPs - Metals

0.475 4.08

Pollutant

Heat Input Capacity Potential Throughput(MMBtu/hour) (MMscf/year)

HAPs - Organics

of 21 TSD App A

Appendix A: Emission CalculationsTwo (2) Robotic Welders




Number Max. ElectrodeProcess of Consumption

Stations (lbs/hour) PM/PM10/PM2.5 Mn Ni Cr PM/PM10/PM2.5 Mn Ni CrMetal Inert Gas (MIG) Welding 2 2.1 2.41E-02 3.46E-04 1.25E-03 5.28E-04 0.44 6.4E-03 0.02 9.7E-03

* Worst case emission factors were used to estimate emissions from gas metal arc welding [AP-42, Chapter 12.19, SCC 3-09-052, (01/95)]. ** Assume all PM10 and PM2.5 emissions are equal to PM emissions, each.

METHODOLOGYPTE from Welding (tons/year) = Number of Stations * Maximum Electrode Consumption (lbs/hour) * Emission Factor (lbs Pollutant/lbs Electrode) * 8760 hours/year * 1 ton/2000 lbs

Process

Number of

StationsMax. Electrode Consumption

Combined Max. Electrode Consumption

Combined Max.

Electrode Consumption

(lbs/hr) (lbs/hr) (lbs/day)Metal Inert Gas (MIG) Welding 2 2.1 4.20 100.80

MethodologyCombined maximum electrode consumption (lbs/hr) = Number of Stations * Maximum electrode consumption per station (lb/hr)Combined maximum electrode consumption (lbs/day) = Combined maximum electrode consumption (lbs/hr) * 24 hrs/day

Maximum electrode consumption per day

Potential To Emit(tons/year)

* Emission Factors(lb pollutant/lb electrode)

of 21 TSD App A


One (1) Boiler





Potential To Emit (tons/year) 0.01 0.05 0.05 3.8E-03 0.63 0.03 0.53








Heat Input Capacity Potential Throughput(MMBtu/hour) (MMscf/year)

HAPs - Metals

1.46 12.54

Pollutant

HAPs - Organics

of 21 TSD App A


Air Handlers




Air Handler IDMMBtu/hr

(each)No. of Units

MMBtu/hr (total)

#1 through #4 2.475 4 9.9#5 and #6 3.013 2 6.026#7 and #8 2.475 2 4.95

#9 and #10 3.575 2 7.15#11 and #12 3.575 2 7.15 Heat Input Capacity Potential Throughput

#13 1.65 1 1.65 (MMBtu/hour) (MMscf/year)Total 36.826 36.826 316.27










Pollutant

HAPs - Organics

HAPs - Metals

of 21 TSD App A

Appendix A: Emission CalculationsWheelabrator Shot Blaster




Emission Factors for Abrasives (Stappa/Alapco, 1991)

Abrasivelb PM/

lb abrasivelb PM-10/

lb PMSand 0.041 0.7Grit 0.01 0.7

Steel Shot 0.004 0.86Other 0.01

Potential To Emit (tons/yr)

Emission Unit

Total Maximium Blasting

Rate (lbs/hr)

Type of Blasting Media

Uncontrolled PTE of PM

(tons/yr)Uncontrolled PTE of PM10 (tons/yr)

PM/PM10 Collection

Efficiency (%)Controlled PTE of PM (tons/yr)

Controlled PTE of PM10

(tons/yr)Wheelabrator Shot Blaster 1000 Steel Shot 17.52 15.07 99.9% 0.0175 0.0151Methodology:Uncontrolled PTE of PM (ton/yr) = Total Maximum Blasting Rate (lb/hr) * Emission Factor (lb PM/lb abrasive) * (8,760 hr/yr) * (1 ton/2,000 lb)Uncontrolled PTE of PM10 (ton/yr) =Uncontrolled PTE of PM (ton/yr) * (0.86 lb PM10/lb PM)Controlled PTE (ton/yr) = Uncontrolled PTE (ton/yr) * (1 - control efficiency)Emission Factors are from Stappa/Alapco, 1991, Section 3, "Abrasive Blasting"

Compliance with 326 IAC 6-3-2:Allowable Emissions, E = 4.10 * P^0.67 (for weight rates up to 60,000 lb/hr)

where E = emissions in lbs/hrP = process weight in tons/hrP = 1000 lbs/hr

= 0.50 tons/hr

Allowable PM Emissions, E = 2.58 lbs/hr = 61.8 lbs/day = 11.3 tons/yr

The use of the filter ensure compliance with the limit above.

Emission Factor

of 21 TSD App A

Appendix A: Emissions CalculationsProcess Emissions from the Tube Mill with Brazing and Fluxing Stations



Reviewer: Doug Logan Date: 11/12/2015

Material Density (lb/gal)

Weight % Volatile (H20 &

Organics)

Weight % Water

Weight % Organics

Volume % Water

Volume % Non-

Volatiles (solids)

Max Usage Rate1

(gal/hr)

Pounds VOC per gallon of coating

less water

Pounds VOC per gallon of

coating2

Potential VOC

(lbs/hour)

Potential VOC

(lbs/day)

Potential VOC

(tonsyear)

Control Efficiency

VOC PTE After

Controls (tons/yr)

Potential PM/PM10/PM2.5

(lbs/hour)

Potential PM/PM10/PM2.5

(ton/year)

Transfer Efficiency3

Evaporative OilLow VOC oil 7.51 100% 68.76% 31.24% 62% 0% 0.113 6.15 2.345 0.26 6.33 1.16 0% 1.16 0 0 100%

Martol LVG 15 CF 6.44 100% 0% 100% 0% 0% 1.25E-02 6.44 4.84 6.05E-02 1.45 0.26 95% 1.32E-02 0 0 100%Total of oils 0.32 7.78 1.42 1.17 0 0FluxPaint F Flux** 10.01 69% 57% 12% 68% 31% 0.474 3.80 1.20 0.57 13.66 2.49 0.15 0.64 90%AL Flux** 10.01 48% 0% 48% 0% 52% 0.687 4.80 4.80 3.30 79.21 14.46 0.36 1.57 90%Hexylene glycol 7.720 100% 0% 100% 0% 0% 0.06 7.72 7.72 0.48 11.58 2.11 0.00 0.00 100%Total of flux 4.35 104.45 19.06 0.50 2.21

Hazardous Air PollutantsMaterial Density Max Weight Percent Uncontrolled Emissions (tons/yr) Control Controlled Emissions (tons/yr)

Usage Rate

EB4 Toluene Xylenes EB Toluene Xylenes Efficiency EB Toluene Xylenes

(Lb/Gal) (gal/hr)Low VOC oil 7.51 0.113 - - - - - - 0% - - -Martol LVG 15 CF5 6.44 0.013 0.02% 0.02% 0.08% 7.05E-05 7.05E-05 2.82E-04 95% 3.53E-06 3.53E-06 1.41E-05Total 7.05E-05 7.05E-05 2.82E-04 3.53E-06 3.53E-06 1.41E-05Combined HAPs 4.23E-04 2.12E-05

Notes:1. Application stated that the volume of high VOC oil would be 10% of the total2. The VOC content of the Low VOC oil was adjusted to to be consistent with the Method 24-determined value of 281 grams/liter (2.345 pounds/gallon), ref: TSD App A, F031-34108-00014, issued March 20, 2014VOC content of Martol LVG 15 CF fromSDS.3. Fluxing occurs in an enclosure with recirculation of overspray. Therefore, transfer efficiency is conservatively estimated at 90%4. EB - ethylbenzene5. Applies default organic HAP content for aromatic blends from Table 4, 40 CFR 63, Subpart MMMM, to maximum 2% aromatic content given in SDS

MethodologyPounds of VOC per Gallon Coating less Water = (Density (lb/gal) * Weight % Organics) / (1-Volume % water)Pounds of VOC per Gallon Coating = (Density (lb/gal) * Weight % Organics)PTE of PM (lbs/hour) = Density (lbs/gal) * Max. usage rate (gal/hour)] * Solids content (%) * (1 - Transfer efficency%)PTE of VOC (lbs/hour) = Density (lbs/gal) * Max. usage rate (gal/hour)] * VOC content (%)PTE of VOC and PM (tons/year) = Hourly emission rate (lbs/hour) * 8760 hours/year * 1 ton/2000 lbsVolume % Water = Density (lb/gal) x Weight % Water / 8.34 (lb/gal) (density of water)HAPS emission rate (tons/yr) = Density (lb/gal) * Max Usage Rate (gal/hr) * Weight % HAP * 8760 hrs/yr * 1 ton/2000 lbs

of 21 TSD App A

Appendix A: Emission CalculationsProcess Emissions from the Braze Ovens and Cool Down Stations




Emission Unit


per unit (lbs/hour)*

No. of Units

Total PTE of PM/PM10/PM2.5

(tons/year)**

PTE of PM/PM10/PM2.5

(lbs/hour) for each oven with cooling station**

Oven 0.194 1 0.85 0.19Cool Down Station 0.561 1 2.5 0.56

Total 3.31 0.76

** PM10 and PM2.5 emissions assumed equal to PM emissions.

METHODOLOGYPTE of PM/PM10 (tons/year) = Emission rate (lbs/hour) * No. of units * 8760 hours/year * 1 ton/2000 lbs

The oven for the brazing station is powered by electricity; therefore, no combustion emissions have been * The emission rates for the brazing station come from a stack test conducted in 1995 at the source.

of 21 TSD App A

Appendix A: Emission CalculationsMolding Treatment Station




MaterialMaterial Density (lbs/gal)

Maximum Throughput

(gal/day)

Maximum Throughput

(lbs/day)

VOC Content

(weight %)

VOC emissions (lbs/day)

VOC emissions (lbs/year)

VOC emissions (tons/year)

HAP Content

(weight %) hexane

HAP emissions (lbs/day) hexane

HAP emissions (lbs/year) hexane

HAP emissions (tons/year)

hexaneSlide Lecithin Mold Release 43512N* 6.79 0.1 0.68 63% 0.43 156 0.08 0% 0.00 0.00 0.00Slide Mold Shield Rust Preventive* 5.38 0.1 0.54 100% 0.54 196 0.10 65% 0.35 128 0.06Slide Econo-Spray Mold Cleaner 45612* 6.24 0.1 0.62 100% 0.62 228 0.11 0% 0.00 0 0.00TOTAL 0.29 0.06

Methodology*Denotes material dispensed from 12oz aerosol cans. Maximum throughput has been provided by the source: assumed to be one can per day (~0.1 gallons/day). Other information obtained from MSDS.VOC/HAP emissions (ton/yr) = Material density (lb/gal) x max. throughput (gal/day) x VOC/HAP content (%) x 365 days per year / 2,000 lb per ton

of 21 TSD App A

Appendix A: Emission CalculationsInjection Molding Machines




Unit ID ResinMax

Capacity (lbs/hr)

Emission Factor (ppm)

Emission Rate

(lbs/hr)

Emission Rate (tpy)


Emission Rate

(lbs/hr)

Emission Rate (tpy)


Emission Rate

(lbs/hr)

Emission Rate (tpy)


Emission Rate

(lbs/hr)

Emission Rate (tpy)


Emission Rate

(lbs/hr)

Emission Rate (tpy)


Emission Rate

(lbs/hr)

Emission Rate (tpy)

IM1 polypropylene resin 1000 202 0.202 0.885 218 0.218 0.955 0.1 1.00E-04 4.38E-04 5.63 0.006 0.025 7.05 0.007 0.031 0.97 0.001 0.004IM2 polypropylene resin 500 202 0.101 0.442 218 0.109 0.477 0.1 5.00E-05 2.19E-04 5.63 0.003 0.012 7.05 0.004 0.015 0.97 4.85E-04 0.002

TOTAL 1,500 1.33 1.43 0.001 0.037 0.046 0.006TOTAL HAP 0.09

MethodologyEmission Factors for Polypropylene Resin (Reactor grade homopolymer) are from "Development of Emission Factors for Polypropylene Processing" by Barlow, Holdren, Meyer, et al J. Air & Waste Manage. Assoc. 49: 49-56. MSDS for polypropylene resins (Dexflex 992 NH533 BLK and SABIC STAMAX long glass fiber reinforced PP homopolymers) provided by the source as part of the application for Administrative Amendment No. 031-35118-00014Emission Rate (lb/hr) = Max Rate (lb/hr) x [Emission Factor (ppm) / 1,000,000]Emission Rate (ton/yr) = Emission Rate (lb/hr) x 8,760 hours per year / 2,000 lb per ton

Formaldehyde Propionaldehyde Hazardous Air Pollutants (HAPs)

VOC PM Acrolein Acetaldehyde

Appendix B

CONTROL TECHNOLOGY 326 IAC 8-1-6 BACT ANALYSIS

Valeo North America, Inc.

Source Background and Description

Source Name: Valeo North America, Inc. Source Location: 1100 East Barachel Lane, Greensburg, IN 47240 County: Decatur SIC Code: 3714 (Other Motor Vehicle Parts Manufacturing) Significant Permit Revision No.: 031-36237-00014 Permit Renewal No.: F031-29500-00014 Permit Reviewer: Doug Logan

On September 3, 2015, Valeo North America, Inc. (Valeo) submitted an application to the OAQ requesting a Significant Permit Revision to its Federally Enforceable State Operating Permit. The source requested changes to the determination of Best Available Control Technology (BACT) under 326 IAC 8-1-6 because of changes in customer requirements. Currently, BACT for the NOCOLOK radiator, condenser, and charge air cooler manufacturing process at Valeo North America, Inc. is the following:

(a) The VOC input from the evaporating oil usage used in the one (1) NOCOLOK radiator, condenser,

and charge air cooler manufacturing process shall be limited to less than eighty-seven (87) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(b) Use of oils which contain no more than 2.4 pounds of VOC per gallon of oil utilized on all fin mills,

tube mills, and turbulators; and (c) The use of micro-coat application system on all fin mills, tube mills, and turbulators to minimize oil

usage. Because of changes in customer requirements for product design requiring increased folds in the tubulators at the radiator production line (Braze Line #8), the low VOC evaporative oil (2.4 lb VOC/gal) cannot reliably be removed from all cores in the core conditioning ovens. It is not possible to increase removal of the low VOC evaporative oil by operating core conditioning ovens at a higher temperature because cores leaving the oven at a higher temperature degrade the flux applied and cause quality problems in the subsequent brazing operations. The source has not found an alternate forming lubricant that offers satisfactory performance in the changed product lines at the 2.4 lb VOC/gal specification. Valeo has reviewed operations at similar facilities and tested the evaporative oils that are commercially available. Valeo has found that evaporative oil with a VOC content of 4.84 lb/gal is needed to achieve complete removal under the operating conditions of the equipment at the source. Because the evaporative oil containing 4.84.lb VOC/gal is not compliant with the existing BACT determination, a BACT analysis is required for this operating scenario.

Summary of the Best Available Control Technology (BACT) Process

BACT is an emissions limitation based on the maximum degree of pollution reduction of emissions, which is achievable on a case-by-case basis. BACT analysis takes into account the energy, environmental, and economic impacts on the source. These reductions may be determined through the application of available control techniques, process design, work practices, and operational limitations. Such reductions are

Valeo North America, Inc. Page 2 of 11 Greensburg, Indiana SPR No. 031-36237-00014 Permit Reviewer: Doug Logan F031-29500-00014 necessary to demonstrate that the emissions remaining after application of BACT will not cause or contribute significantly to air pollution, thereby protecting public health and the environment. Federal guidance on BACT requires an evaluation that follows a “top down” process. In this approach, the applicant identifies the best-controlled similar source on the basis of controls required by regulation or permit, or controls achieved in practice. The highest level of control is then evaluated for technical feasibility. The five (5) basic steps of a top-down BACT analysis are listed below: Step 1: Identify Potential Control Technologies The first step is to identify potentially “available” control options for each emission unit and for each pollutant under review. Available options should consist of a comprehensive list of those technologies with a potentially practical application to the emissions unit in question. The list should include lowest achievable emission rate (LAER) technologies, innovative technologies, and controls applied to similar source categories. Step 2: Eliminate Technically Infeasible Options The second step is to eliminate technically infeasible options from further consideration. To be considered feasible, a technology must be both available and applicable. It is important in this step that any presentation of a technical argument for eliminating a technology from further consideration be clearly documented based on physical, chemical, engineering, and source-specific factors related to safe and successful use of the controls. Innovative control means a control that has not been demonstrated in a commercial application on similar units. Innovative controls are normally given a waiver from the BACT requirements due to the uncertainty of actual control efficiency. A control technology is considered available when there are sufficient data indicating that the technology results in a reduction in emissions of regulated pollutants. Step 3: Rank the Remaining Control Technologies by Control Effectiveness The third step is to rank the technologies not eliminated in Step 2 in order of descending control effectiveness for each pollutant of concern. The ranked alternatives are reviewed in terms of environmental, energy, and economic impacts specific to the proposed modification. If the analysis determines that the evaluated alternative is not appropriate as BACT due to any of the impacts, then the next most effective is evaluated. This process is repeated until a control alternative is chosen as BACT. If the highest ranked technology is proposed as BACT, it is not necessary to perform any further technical or economic evaluation, except for the environmental analyses. Step 4: Evaluate the Most Effective Controls and Document the Results The fourth step entails an evaluation of energy, environmental, and economic impacts for determining a final level of control. The evaluation begins with the most stringent control option and continues until a technology under consideration cannot be eliminated based on adverse energy, environmental, or economic impacts. For the technologies determined to be feasible, there may be several different limits that have been set as BACT for the same control technology. The permitting agency has to choose the most stringent limit as BACT unless the applicant demonstrates in a convincing manner why that limit is not feasible. BACT must, at a minimum, be no less stringent than the level of control required by any applicable New Source Performance Standard (NSPS) and National Emissions Standard for Hazardous Air Pollutants (NESHAP) or state regulatory standards applicable to the emission units included in the permits.

Valeo North America, Inc. Page 3 of 11 Greensburg, Indiana SPR No. 031-36237-00014 Permit Reviewer: Doug Logan F031-29500-00014 Step 5: Select BACT The Office of Air Quality (OAQ) makes final BACT determinations by following the five steps identified above

Volatile Organic Compounds (VOC) BACT – NOCOLOK Process

Step 1 – Identify Potential Control Options

The volatile organic compounds (VOC) emissions can be controlled by the following emission control systems: (1) Destruction Processes; (2) Reclamation Processes; and/or (3) Combination of Reclamation and Destruction Technologies. (4) Direct Incineration at the existing Braze Line 8 core oven Vorcinerator afterburner. Destruction technologies reduce VOC concentration by high temperature oxidation into carbon dioxide and water vapor. Reclamation is the capture of VOCs for reuse or disposal. A further description of these types of control technologies follows: Destruction Control Methods The destruction of organic compounds usually requires temperatures ranging from 1,200ºF to 2,000ºF for direct thermal incinerators or 600ºF to 1,200ºF for catalytic systems. Combustion temperature depends on the chemical composition and the desired destruction efficiency. Carbon dioxide and water vapor are the typical products of complete combustion. Turbulent mixing and combustion chamber retention times of 0.5 to 1.0 seconds are needed to obtain high destruction efficiencies. Control technologies include direct incineration, recuperative thermal incineration, regenerative thermal incineration, recuperative catalytic incineration, regenerative catalytic incineration, and flares.

Direct Incineration: Direct incineration is the most simple and direct form of incineration. It involves burning the VOC-laden fumes directly in a combustion chamber without reheating or post-combustion heat recover. Direct incineration typically requires supplemental fuel. Concentrated VOC streams with high heat contents obviously require less supplementary fuel than more dilute streams. VOC streams sometimes have a heat content high enough to be self-sustaining, but a supplemental fuel firing rate equal to about 5% of the total incinerator heat input is usually needed to stabilize the burner flame. Natural gas is the most common fuel for VOC incinerators, but fuel oil is an option in some circumstances. VOC destruction efficiencies greater than 98% are achievable under certain operating conditions (EPA-453/R-92-017). However, a VOC destruction efficiency of 95% is considered achievable on a consistent basis for a most operations.

Valeo North America, Inc. Page 4 of 11 Greensburg, Indiana SPR No. 031-36237-00014 Permit Reviewer: Doug Logan F031-29500-00014

Recuperative Thermal Oxidation: Recuperative thermal incinerators are add-on control devices used to control VOC emissions by introducing solvent-laden fumes to the oxidizer. The stream is pre-heated by exiting flue gas from the same system in a heat exchanger or recuperator, a burner then heats the air to the required temperature. The air is then passed through an oxidation chamber where the solvent-laden air is converted to carbon dioxide and water. These are then passed through the heat exchanger where incoming fume is preheated by the heat of the exiting flue gas. Finally the clean flue gas is discharged to the atmosphere. The recuperative thermal oxidizer is appropriate for waste streams with a relatively high solvent content and/or consistent pollutant loading. Variation in pollutant loading will require a longer retention time in the oxidizer in order to properly destroy VOC emissions. VOC destruction efficiencies greater than 98% are achievable under certain operating conditions (EPA-453/R-92-017). However, a VOC destruction efficiency of 95% is considered achievable on a consistent basis for a most operations. Regenerative Thermal Oxidation: Regenerative thermal oxidizers (RTOs) are add-on control devices used to control VOC emissions by simple reaction of the harmful air pollutants with oxygen and heat. An RTO uses a direct contact heat exchanger. These direct contact heat exchangers consist of a bed of porous ceramic packing or other structured, high heat capacity media. These systems can handle variable and low concentration VOC waste streams.

The inlet gas first passes through a hot ceramic bed thereby heating the stream (and cooling the bed) to its ignition temperature. The hot gases then react (releasing energy) in the combustion chamber and while passing through another ceramic bed, thereby heating it to the combustion chamber outlet temperature. The process flows are then switched, now feeding the inlet stream to the hot bed. This cyclic process affords very high energy recovery (up to 95%). The higher capital costs associated with these high performance heat exchangers and combustion chambers may be offset by the increased auxiliary fuel savings to make such a system economical. VOC destruction efficiencies greater than 98% are achievable under certain operating conditions (EPA-453/R-92-017). However, a VOC destruction efficiency of 95% is considered achievable on a consistent basis for a most operations.

Recuperative and Regenerative Catalytic Oxidation: Catalytic incinerators are add-on control devices used to control VOC emissions by using a bed of catalyst that facilitates the oxidation of the combustible gases. The catalyst increases the reaction rate and allows the conversion of VOC at lower temperatures than thermal incinerators. Catalytic oxidation can be used for low-concentration VOC waste streams; however, certain compounds present in waste stream gas may foul the catalyst. It may also be necessary to remove particulate prior to catalytic oxidation as well. VOC destruction efficiencies greater than 98% are achievable under certain operating conditions (EPA-453/R-92-017). However, a VOC destruction efficiency of 95% is considered achievable on a consistent basis for a most operations. Flares: Flaring is used to control VOC emissions by piping VOCs to a remote, usually elevated location and burning them in an open flame in the open air using a specially designed


burner tip, auxiliary fuel, and steam or air to promote mixing for nearly complete (> 98%) VOC destruction. While flares are designed to eliminate waste gas streams, they can cause safety and operational problems and the exhaust stream concentration must be high enough to sustain combustion. In-Situ Incineration: The affected source includes a large number of small forming machines. All of these machines can be moved as the manufacturing operation may change to accommodate new products or production rates. The existing heat source for the last three stages of the four-stage core conditioning oven in Braze Line #8 is an afterburner for vapors drawn from the oven. This afterburner, trade name Vorcinerator, is designed to achieve an operating temperature of 800ºC (1,472ºF), a residence time of 1 second, and a design level of 95% destruction. For the portion of the product that requires use of evaporative oil with a VOC content greater than 2.4 lb/gal and less than 4.84 lb/gal, the Vorcinerator is capable of providing 95% control efficiency of the VOC emissions. The Vorcinerator afterburner is physically limited to Braze Line #8 and the unit is not capable of controlling emissions from other braze lines at the source.

Reclamation Control Methods Organic compounds may be reclaimed by one of three possible methods; adsorption, absorption (scrubbing) or condensation. In general, the organic compounds are separated from the emission stream and reclaimed for reuse or disposal. Depending on the nature of the contaminant and the inlet concentration of the emission stream, recovery technologies can reach efficiencies of 98%.

Scrubbers: There are several types of wet scrubbers that use a variety of techniques to control VOC emissions. The type of scrubber used in a particular application is dependent on the characteristics of the waste gas stream and the pollutants of concern. VOC control scrubbers are designed primarily for creating intimate contact to promote absorption of soluble compounds.

Adsorption: Adsorption is a surface phenomenon where attraction between the carbon and VOC molecules binds the pollutants to the carbon surface. Both carbon and VOC are chemically intact after adsorption. The VOCs may be removed, or desorbed, from the carbon bed reclaimed and destroyed. Adsorption can be used for relatively low VOC exhaust streams. Pollutants present in the gas streams can reduce adsorber efficiency, increase pressure drop and eventually plug the bed. Adsorption processes can be used to capture VOCs in low concentration exhaust; however, it is typically only used for exhaust that is not loaded with other pollutants which can plug the bed.

Absorption: Absorption is a unit operation where components of a gas phase mixture (Pollutants) are selectively transferred to a relatively nonvolatile liquid, usually water. Sometimes, organic liquids, such as mineral oil or nonvolatile hydrocarbons, are suitable absorption solvents. The choice of solvent depends on cost and solubility of the pollutant in the solvent. Absorption is commonly used to recover products or purify gas streams that have high concentrations of organic compounds. Absorption processes are typically used to recover


products or purify gas streams with high concentrations of organic compounds such as in the ethanol production and soybean oil refinery industries. Condensation: Condensation is the separation of VOCs from an emission stream through a phase change, by increasing the system pressure or, more commonly, lowering the system temperature below the dew point of the VOC vapor. When condensers are used for air pollution control, they usually operate at the pressure of the emission stream, and typically require a refrigeration unit to obtain the temperature necessary to condense the VOCs from the emission stream. These systems are frequently used prior to other control devices (e.g., oxidizers or absorbers) to remove components that may be corrosive or damaging to other parts of the system. Refrigerated condensers are used as air pollution control devices for treating emission streams with high VOC concentrations (usually > 5,000 ppmv). Condensers may be used to control VOC emissions with high VOC concentrations (usually greater than 5,000 ppmv). A refrigeration condenser normally provides VOC control efficiency greater than 90%.

Combinations of Reclamation and Destruction Control Methods In some cases, a combination of control technologies offers the most efficient and cost effective VOC control. The combination of carbon adsorption with recuperative thermal incineration is available commercially. This system concentrates the VOC stream by using carbon adsorption to remove low concentration VOCs in an emission stream and then uses a lower volume of hot air, commonly one-tenth the original flow, to desorb the pollutants. A recuperative incinerator for destroying pollutants in the concentrated stream is much smaller and has lower supplemental fuel requirement than an incinerator sized for the full emission stream volume. Absorption systems can also be used to concentrate emission streams to reduce the size of destruction equipment. The concentration effect is not as extreme as with carbon adsorption, a concentrated exhaust stream one quarter the volume of the inlet stream seems to be the practical limit. Absorption concentrators are typically suited for batch processes or to equalize pollutant concentrations in a variable stream. The physical characteristics that drive the absorption of pollutants into a liquid also limit the opportunity to remove those pollutants from the liquid stream. Fume incinerators typically need supplemental fuel. Concentrated VOC streams with high heat contents obviously require less supplementary fuel than more dilute streams. VOC streams sometimes have a heat content high enough to be self-sustaining, but a supplemental fuel firing rate equal to about 5% of the total incinerator heat input is usually needed to stabilize the burner flame. Natural gas is the most common fuel for VOC incinerators, but fuel oil is an option in some circumstances.

Step 2: Eliminate Technically Infeasible Options The test for technical feasibility of any control option is whether it is both available and applicable to reducing VOC emissions from tubulators under the proposed operation scenario. The control technologies listed in the previous section are discussed and evaluated below for their technical feasibility. The use of flares and condensation are not technically feasible options for this source for the following reasons: (a) Under the proposed operating scenario, the use of a flare to control VOC at this source is

not feasible because of the low VOC concentration in the inlet air stream. Operating a flare


for a stream with low VOC content requires excessive supplemental fuel. No further evaluation for this control option will be made.

(b) Based on the volumetric flow, low VOC concentration, high moisture content, and high inlet

temperature of the Valeo core conditioning ovens, a condenser would need to operate at a temperature of 160ºF below zero (-160ºF) to achieve 90% control. Such a low temperature is beyond what can be maintained by a refrigerated condenser system. Therefore, a condenser is not considered a technically feasible option for this operating scenario and no further evaluation for the control option will be made.

Step 3: Rank the Remaining Control Technologies by Control Effectiveness

The remaining control options are in order of descending control effectiveness: (a) Recuperative thermal incineration - 98%, (b) Regenerative thermal incineration - 98%, (c) Recuperative catalytic incineration - 98%, (d) Regenerative catalytic incineration - 98%, (e) Carbon adsorption with catalytic oxidation - 96% (f) In-Situ Incineration at the existing Vorcinerator afterburner - 95% (g) Carbon adsorption - 85%

Step 4 – Evaluate the Most Effective Controls and Document Results IDEM, OAQ and the Permittee searched EPA’s RACT/BACT/LAER Clearinghouse (RBLC) for similar operations. A search for the source codes in the RBLC was conducted to find VOC emission limitations that are applicable to similar operations: (1) 49.999 - Organic Evaporative, Other (none of the specific categories within the organic

evaporative activity code (49) were applicable to Valeo’s operations). (2) 82.999 - Other Nonferrous Metallurgical (none of the specific categories within the

nonferrous metallurgical activity code (82) were applicable to Valeo’s operations). (3) 99.012 - Welding and Grinding. (4) 99.999 – Other Miscellaneous Sources

The results did not yield any operations similar to the source. As a result, there are no RBLC entries which identify limits or control technology which could apply to Valeo North America, Inc.

Valeo North America, Inc. Page 8 of 11 Greensburg, Indiana SPR No. 031-36237-00014 Permit Reviewer: Doug Logan F031-29500-00014 Table 4-1. RBLC Data on Core Conditioning Ovens

Company RBLC ID Source Permit Issuance Date Technology VOC Limit(s)

Proposed BACT for Valeo North America, Inc.

NOCOLOK process Pending

• Low-VOC (≤ 2.4 lb VOC/gal) evaporative oil for lines 1, 2, 3, 5, and 6; and line 8 when not operating under AOS1

• Radiator Production at Braze Line #8 1. Evaporative

oil VOC content ≤4.84 lb/gal

2. VOC emissions ≤0.88 tons per 12 mo. period

3. VOC emissions from Braze Line #8controlled by Vorcinerator afterburner

4. Overall control efficiency of Vorcinerator afterburner ≥95%

• Micro-coat application system

87.00 tons/yr

Existing BACT Determinations

Valeo North America, Inc.

none (permit no. F031-21314-00014)

NOCOLOK process 04/24/2006

• Low-VOC (≤ 2.4 lb VOC/gal) evaporative oil

• Micro-coat

87.00 tons/yr


Company RBLC ID Source Permit Issuance Date Technology VOC Limit(s)

application system

Further evaluation including economic, energy and environmental impacts are required for controlling VOC emissions from the mill emulsion systems and the alcohol quench systems. Annualized costs were determined in accordance with the EPA guidance (EPA’s Office of Air Quality Planning and Standards Control Cost Manual) and economic feasibility was evaluated. Valeo provided IDEM, OAQ with a thorough cost analysis of the technically feasible control options as part of the 2006 BACT analysis (F 031-21314-00014). The 2006 cost analysis (summarized below) was based on a VOC reduction of 96%. Because of inflation, capital and other costs of add-on controls are higher at present. Additionally, the cost of control at the current achievable level of 98% would drive the cost of add-on-controls higher yet. Due to these reasons, the cost analysis submitted in 2006 is considered acceptable for purposes of this BACT.

2006 BACT Cost Analysis

Control Option

Efficiency (%)

Equipment Cost ($)

Total Operating Cost ($/yr)

Total Annualized Costs ($/yr)

Limited VOC (tons/year)

VOC Removed (tons/year)

Cost Effectiveness

($/ton VOC removed)

Recuperative Thermal

Incinerator 96% $1,003,957 $1,094,405 $1,237,349 87.0 83.5 $14,815

Regenerative Thermal

Incinerator 96% $1,813,751 $527,307 $785,549 87.0 83.5 $9,406

Recuperative Catalytic

Incineration 96% $1,442,483 $970,118 $1,175,499 87.0 83.5 $14,074

Regenerative Catalytic

Incineration 96% $3,018,402 $566,471 $996,231 87.0 83.5 $11,928

Carbon Adsorption

with Catalytic Oxidation

96% $2,508,024 $354,998 $712,091 87.0 83.5 $8,526

Carbon Absorption 85 % $1,066,674 $505,015 $656,888 87.0 74.0 $8,883

SPR No. 031-36237-00014 BACT Cost Analysis

Control Option

Efficiency (%)

Equipment Cost ($)





Cost Effectiveness

($/ton VOC removed)

Case 1: All VOC emissions from evaporative oils controlled as follows: Recuperative

Thermal Incinerator

98% $1,003,957 $1,094,405 $1,237,349 87.0 85.3 $14,506

Regenerative Thermal

Incinerator 98% $1,813,751 $527,307 $785,549 87.0 85.3 $8,893

Recuperative Catalytic

Incineration 98% $1,442,483 $970,118 $1,175,499 87.0 85.3 $13,781

Regenerative Catalytic

Incineration 98% $3,018,402 $566,471 $996,231 87.0 85.3 $11,679


SPR No. 031-36237-00014 BACT Cost Analysis

Control Option

Efficiency (%)

Equipment Cost ($)





Cost Effectiveness

($/ton VOC removed)

Carbon Adsorption

with Catalytic Oxidation

98% $2,508,024 $354,998 $712,091 87.0 85.3 $8,348

Carbon Absorption 85 % $1,066,674 $505,015 $656,888 87.0 74.0 $8,877

Case 2: VOC emissions from Braze Line #8 Radiator Production and use of low VOC (< 2.4 lb/gal) evaporative oils for remainder of usage. Braze Line #8 Vorcinerator

Afterburner for VOC lb/gal ≤ 4.84 and >

2.41

95% $0 $0 $0 17.66 2 16.78 $0

Notes: 1. Cost analysis is not applicable to the Vorcinerator afterburner because the unit is already in existence providing

heat for the Braze Line #8 core conditioning oven. 2. Maximum VOC from use of higher VOC oils based on capacity of Braze Line #8. Case 1 :The cost effectiveness for VOC removal (in dollars per ton of VOC removed), using the 2006

capital and operating costs and a control efficiency of 98%, had a negligible decrease (approximately 2%) compared to the analysis with a control efficiency of 96%. Therefore, the add-on-controls are still considered cost prohibitive. For products using evaporative oils containing no more than 2.4 pounds of VOC per gallon, BACT shall continue to be a VOC content limit.

Case 2: For products using evaporative oils containing greater than 2.4 pounds of VOC per gallon and less

than or equal to 4.84 pounds of VOC per gallon, BACT shall be 95% control using the Vorcinerator afterburner in Braze Line #8.

BACT for the entire NOCOLOK process shall continue to be a limit of 87.0 tons of VOC per twelve (12) consecutive month period and the use of micro coat application. Step 5 – Select BACT

The following is the VOC BACT for the NOCOLOK manufacturing process: (a) The VOC emissions from the evaporating oil usage in the one (1) NOCOLOK radiator,

condenser, and charge air cooler manufacturing process shall not exceed eighty-seven (87.0) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.


VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core assembly process is operating in conjunction with Braze Lines #1, #2, #3, #5, and #6.

(c) Unless operating under Alternative Operating Scenario 1 (AOS1), the Permittee shall use



(1) The Permittee shall use oils containing no more than 4.84 pounds of VOC per gallon of oil utilized on all fin mills, tube mills, and turbulator mills when the Core


assembly process is operating in conjunction with Braze Line #8 radiator production.

(2) The VOC emissions from the evaporating oil usage on all fin mills, tube mills, and

turbulator mills when the Core assembly process is operating in conjunction with Braze Line #8 radiator production shall not exceed eighty-eight hundredths (0.88) tons per twelve (12) consecutive month period, with compliance determined at the end of each month.

(3) VOC emissions from Braze Line #8 radiator production shall be controlled by the

Vorcinerator afterburner. (4) The overall efficiency for the Vorcinerator (including the capture efficiency and


(e) The Permittee shall use a micro-coat application system on all fin mills, tube mills, and

turbulator mills to minimize oil usage.



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED TO: Scott Dickerson

Valeo North America, Inc. 1100 East Barachel Lane

Greensburg, IN 47240 DATE: December 28, 2015 FROM: Matt Stuckey, Branch Chief Permits Branch Office of Air Quality SUBJECT: Final Decision Federally Enforceable State Operating Permit (FESOP) Significant Permit Revision 031-36237-00014 Enclosed is the final decision and supporting materials for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents. The final decision is being sent to you because our records indicate that you are the contact person for this application. However, if you are not the appropriate person within your company to receive this document, please forward it to the correct person. A copy of the final decision and supporting materials has also been sent via standard mail to: Vincent Palisson, Site Director Qaiser Baig, Cornerstone Environmentl OAQ Permits Branch Interested Parties List If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you think you have received this document in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at [email protected].

Final Applicant Cover letter.dot 8/27/2015

mailto:[email protected]



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

December 28, 2015 TO: Greensburg-Decatur County Public Library

From: Matthew Stuckey, Branch Chief Permits Branch Office of Air Quality Subject: Important Information for Display Regarding a Final Determination

Applicant Name: Valeo North America, Inc. Permit Number: 031-36237-00014 You previously received information to make available to the public during the public comment period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the same project. Please place the enclosed information along with the information you previously received. To ensure that your patrons have ample opportunity to review the enclosed permit, we ask that you retain this document for at least 60 days. The applicant is responsible for placing a copy of the application in your library. If the permit application is not on file, or if you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, extension 3-0185.

Enclosures Final Library.dot 8/27/2015

FACSIMILIE OF PS Form 3877

Mail Code 61-53

IDEM Staff VHAUN 12/28/2015 Valeo North America, Inc 031-36237-00014 FINAL

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING

Name and address of Sender ►

Indiana Department of Environmental Management Office of Air Quality – Permits Branch 100 N. Senate Indianapolis, IN 46204

Type of Mail:

CERTIFICATE OF MAILING ONLY

Line Article

Number Name, Address, Street and Post Office Address Postage Handing

Charges Act. Value (If Registered)

Insured Value

Due Send if COD

R.R. Fee

S.D. Fee S.H. Fee

Rest. Del. Fee Remarks

1 Scott Dickerson Valeo North America, Inc 1100 E Barachel Lane Greensburg IN 47240 (Source CAATS) VIA CERTIFIED MAIL USPS 2 Vincent Palisson Site Director Valeo North America, Inc 1100 E Barachel Lane Greensburg IN 47240 (RO CAATS) 3 Greensburg Decatur Co Public Library 1110 East Main Greensburg IN 47240 (Library) 4 Decatur County Commissioners 150 Courthouse Square Greensburg IN 47240 (Local Official) 5 Greensburg City Council & Mayors office 314 W Washington Street Greensburg IN 47240 (Local Official) 6 Decatur County Health Department 801 N. Lincoln St Greensburg IN 47240-1397 (Health Department) 7 Mr. Leonard Rohls 8504 North County Road 300 West Batesville IN 47006 (Affected Party) 8 Qaiser Baig Cornerstone Environmental 880 Lennox Ct. Zionsville IN 46077 (Consultant) 9 10 11 12 13 14 15 Total number of pieces Listed by Sender

7 Total number of Pieces Received at Post Office

Postmaster, Per (Name of Receiving employee)

The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstructing insurance is $50,000 per piece subject to a limit of $50, 000 per occurrence. The maximum indemnity payable on Express mil merchandise insurance is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on inured and COD mail. See International Mail Manual for limitations o coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.

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