RESPON. May 9, 2014 PERMIT. P.O. Box 30260

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1 RESPON SE TO COMMENTS DOCUMENT PERMIT No C Rick Snyder, Governor Air Quality Division Michigan Departmentt of Environmental Quality INTERNET: G. Vinsonn Hellwig, Chief Air Quality Division Constitution Hall, 2 nd Floor, South Tower 525 West Allegan Street P.O. Box Lansing, Michigan Phone: Fax: (517)

2 Page 1 of 6 Table of Contents Section Page Public Participation Process... 2 II. Summary of s Resulting in Changes to the Permit... 2 Summary of Significant s... 3 Public Health and Environment Concerns... 3 Permit Review... 4 Public Participation Process... 5 Air Monitoring Station... 5 IV. Summary of s Received in Support... 6

3 Page 2 of 6 I. PUBLIC PARTICIPATION PROCESS Permit to Install (PTI) application No C, for Universal Coating, Inc. (Universal Coating), is to increase facility-wide federally enforceable permit limits for hazardous air pollutants (HAPs) to greater than 90 percent of the major source threshold, and to install a new spindle conveyor adhesive coating line at the facility located at 5204 Energy Drive, Flint, Michigan. The public participation process involved providing information for public review including a fact sheet, proposed permit terms and conditions, a public comment period, an informational meeting, a public hearing, and the receipt of verbal comments on staff s analysis of the application and the proposed permit. On March 13, 2014, copies of the Notice of Air Pollution Period and Public Hearing, the Fact Sheet and the draft terms and conditions were placed on the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD) Home Page ( Also, the AQD mailed 110 letters to persons who had previously expressed interest and had provided a complete address. In addition, a notice announcing the Public Period, Public Informational Session, and Public Hearing was placed in the Flint Journal. The notice provided pertinent information regarding the proposed action; the locations of available information; a telephone number to request additional information; the date, time, and location of the Public Informational Session and Public Hearing; the closing date of the Public Period; and the address where written comments were being received. The Informational Session was held on April 17, 2014, at the Carpenter Road Elementary School. This location was selected due to its proximity to the facility and the size of the room. Approximately 20 people attended the Informational Meeting. A panel of representatives from the AQD was available to answer questions regarding the proposed project. The meeting began at 6:00 p.m. and concluded at approximately 7:00 p.m. with a short break prior to the start of the Public Hearing. The Public Hearing was also held on April 17, 2014, at the Carpenter Road Elementary School, 6901 Webster Road, Flint, Michigan. The hearing began shortly after 7:00 p.m. with Ms. Barb Rosenbaum as the Hearings Officer and Ms. Lynn Fiedler, sitting in for Mr. G. Vinson Hellwig, the Decision Maker. In addition, the AQD staff was available outside the hearing room to answer questions. Approximately 20 people were in attendance at the Public Hearing with 9 providing verbal comments. The Public Hearing concluded at approximately 8:00 p.m. The remainder of this document is a listing of the significant comments received during the public comment period and hearing regarding the proposed permit and the MDEQ s response. II. SUMMARY OF COMMENTS RESULTING IN CHANGES TO THE PERMIT No changes were made to the draft permit conditions based on comments received.

4 Page 3 of 6 III. SUMMARY OF SIGNIFICANT COMMENTS A. Public Health and Environment Concerns The air quality in this area, including the impacts of the emissions from this facility, may harm the public health. There is concern for asthma and other respiratory diseases, and other possible health effects. What are the local asthma rates? There are two ways that the MDEQ can evaluate the local air quality: monitoring and modeling. Monitoring information comes from the nearest MDEQ air monitoring station, at Whaley Park in Flint. This is located about 2 miles south of the facility, or about 1 1/2 mile south of the residents living south of Carpenter Road and south of the facility. At this monitoring station, the MDEQ measures ozone and fine particulate matter less than 2.5 microns in diameter (PM2.5). The levels of ozone and PM2.5 meet the National Ambient Air Quality Standards (NAAQS) which are set at levels that protect the public health. Sulfur dioxide and coarse particulate matter were also monitored until 2007; those were also at levels that met the NAAQS. Monitoring for manganese and other metals at this location has also found levels to be relatively low and not a public health concern. Modeling for air toxics levels is also useful, particularly for areas where there is no nearby air monitor. The United States Environmental Protection Agency (USEPA) provides that modeling information as part of the National scale Air Toxics Assessment (NATA). For the local census blocks (where the facility is located, and where the Carpenter Road School is located), the USEPA estimates that the air toxics levels are low and would not be expected to cause health effects in the community. The total lifetime cancer risk level associated with the air toxics is a risk of about 1 in 10,000. Facility emissions, including Universal Coating and other facilities, are estimated to have much less impact on air pollution levels than vehicle emissions in this area. Finally, the proposed air pollutant emissions from Universal Coating were evaluated by the MDEQ. These emissions were not found to pose a health risk. The ambient air impacts of the proposed emissions meet all state and federal requirements that are designed to help ensure public health protection. Therefore, the proposed facility emissions are not reasonably anticipated to be harmful to the public health, including sensitive individuals such as asthmatics or people with other respiratory diseases. Asthma rates for each county are available from the Michigan Department of Community Health at: For Genesee County, the rate of hospitalization due to asthma during , for all ages, was 17.3 per 10,000 people. This is slightly higher than the state-wide rate of 16.6 hospitalizations due to asthma per 10,000 people in Michigan. Further details and statistics are available at this website. Unfortunately, the data are not available for more localized areas within counties, or for a more recent time period. The proposed facility emissions are not anticipated to aggravate asthma in the community.

5 Page 4 of 6 The air pollution in this area may be harmful to wildlife. Besides the public health protective standards discussed above, the USEPA has also established secondary air quality standards for five criteria pollutants. The secondary air quality standards provide protection of wildlife as well as vegetation, crops, buildings, soil, water, public welfare and the environment. The secondary standards are not more stringent than the public health protective standards, indicating that wildlife would also be protected by the standards that were designed for human health protection. Genesee County is attaining the secondary standards as well as the public health protective standards. The MDEQ uses health protective screening levels to evaluate if proposed facility air toxics emissions may pose a threat to the public health. The MDEQ does not have screening levels that were specifically set for the protection of wildlife. However, the toxicity studies that were evaluated and that formed the basis for the health protective screening levels included animal toxicity studies as well as human studies. Generally, toxicity to wildlife would not be expected if levels are lower than the screening levels. The MDEQ evaluated the proposed facility s air toxics emissions and found that the air impacts are lower than the health protective screening levels. Therefore, no wildlife adverse effects are anticipated from air toxics or the criteria pollutant emissions. B. Permit Review With Universal Coating being an existing facility, was it exempt or grandfathered from new rules and regulations? The proposed project at Universal Coating was not exempt or grandfathered from new rules or regulations. The current project to increase facility-wide emission limits for hazardous air pollutants to greater than 90% of the major source thresholds, and to install a new spindle conveyor adhesive coating line, is subject to state and federal air quality rules and regulations. This required a Best Available Control Technology (BACT) review for volatile organic compounds and a demonstration that emissions of air toxics were below health protective standards. The proposed project at Universal Coating met both requirements.

6 Page 5 of 6 C. Public Participation Process There was insufficient advertisement for the public comment period and hearing. Pursuant to federal regulations found in 40 CFR , the USEPA requires that there must be a notice of at least 30 days for the public comment period and public hearing. On March 13, 2014, copies of the Notice of Air Pollution Period and Public Hearing, the Fact Sheet, and the draft terms and conditions were placed on the AQD Internet Home Page at: as well as at the Lansing District Office, the Genesee County Clerk, and the City of Flint. In addition, the Notice of Air Pollution Period and Public Hearing was placed in the Flint Journal, and contained the phone numbers to call for additional information on the project. Also on that date, the AQD mailed 110 letters to persons who had previously expressed interest and had provided a complete address. The notice provided pertinent information regarding the proposed action; the locations of available information; a telephone number to request additional information; the date, time, and location of the Public Hearing; the closing date of the Public Period; and the address where written comments were being received. D. Air Monitoring Stations Why does the MDEQ have an air monitoring station at Whaley Park? The MDEQ had several ambient air monitoring stations in Flint dating back to the 1970 s. In 1992, since the stations were showing attainment with the NAAQS, all but one station was shut down. The remaining station at the City Market was moved to 3610 Iowa Street (Whaley Park) in June Monitoring locations must meet the USEPA criteria for siting. This criteria includes being in an open area, away from trees and other obstructions. The site must have power available, be accessible year-round, and the MDEQ must obtain permission from the land owner. The location at Whaley Park was downwind from the Buick City, General Motors plant, near a school, and in a residential neighborhood. When possible, the MDEQ prefers to site monitors near schools and residential neighborhoods so that the public has access to air quality measurements where they live and where children attend school.

7 Page 6 of 6 Can the MDEQ make Universal Coating install and operate an air monitoring station? No, the MDEQ does not have the regulatory authority to require a facility, such as Universal Coating, to conduct ambient air monitoring. If the company chooses to do this on their own, the MDEQ would be glad to provide technical guidance for conducting an ambient air monitoring program. IV. SUMMARY OF COMMENTS RECEIVED IN SUPPORT No comments were received in support of the modifications to the permit. Prepared by: Vrajesh Patel, MDEQ-AQD Susan Kilmer, MDEQ-AQD Robert Sills, MDEQ-AQD