Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6001 / STAFF REPORT / MI-ROP-B6001-2014a
Herman Miller, Inc.
SRN: B6001
Located at
855 East Main Avenue, Zeeland, Ottawa County, Michigan 49464
Permit Number: MI-ROP-B6001-2014a
Staff Report Date: April 7, 2014
Amended Date: February 23, 2015
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).
TABLE OF CONTENTS
April 7, 2014 STAFF REPORT 3
May 12, 2014 STAFF REPORT ADDENDUM 9
February 23, 2015 STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION 10
April 10, 2015 STAFF REPORT ADDENDUM FOR RULE216(2) MINOR MODIFICATION 11
Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B6001 /
April 7, 2014 STAFF REPORT
/ MI-ROP-B6001-2014Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.
General Information
Stationary Source Mailing Address: / Herman Miller, Inc.855 East Main Avenue
P.O. Box 302
Zeeland, Michigan 49464
Source Registration Number (SRN): / B6001
North American Industry Classification System (NAICS) Code: / 337211
Number of Stationary Source Sections: / 2
Is Application for a Renewal or Initial Issuance? / Renewal
Application Number: / 201300155
Responsible Official Section 1: / Peter Pallas, Director, Production Operations
616-654-3300
Responsible Official Section 2: / Ray Muscat, Sr. V.P. Operations Engineering
616-654-3300
AQD Contact: / Denise Plafcan, Senior Environmental Quality Analyst
616-356-0259
Date Permit Application Received: / September 25, 2013
Date Application Was Administratively Complete: / September 25, 2013
Is Application Shield In Effect? / Yes
Date Public Comment Begins: / April 7, 2014
Deadline for Public Comment: / May 7, 2014
Source Description
Herman Miller, Inc. manufactures wood office furniture and is located in the center of an industrial district in the city of Zeeland in Ottawa County. This ROP is divided into two sections, the office furniture manufacturing plant and the wood waste boiler. Section 1 of the ROP is the manufacturing plant. The manufacturing operation is composed of wood finishing lines, adhesive application stations, woodworking equipment and maintenance parts washers. The wood finishing lines are made up of various coating booths and ovens. The coating operations includes an ultraviolet finish line and the Rhodes Line3, which are used to apply stains, topcoats and sealers. The ultraviolet finish line and the remaining Cefla stain booth were permitted under two separate General Permits. As a result of the changes, and the conditions in the General Permit, the company has a more stringent source-wide VOC limit of 30 tons per year for all coating lines. The woodworking equipment consists of carving, cutting, routing, turning, drilling, sawing, sanding, planing, and buffing wood components. Exhaust from the woodworking machinery is directed to one of seven dust collection systems. Depending upon weather conditions, the exhaust from the dust collectors can either be internally or externally vented. Section 2 of the ROP contains Boiler No. 3, facility-wide emergency/back-up generators and a maintenance parts washer. Boiler No. 3 is required to burn a minimum of 75% wood waste and in 2007 a baghouse with sodium bicarbonate treatment for hydrochloric acid was added. Since 2007, there have been changes to the sodium bicarbonate system to allow for the use of different hydrochloric acid sorbents.
Opt-out Permit to Install (PTI) No. 162-13, requesting HAPS opt-out limits and for changes to the overall design of the boiler system, was applied for and issued after the ROP application submittal. The company is now a synthetic minor source for HAPS and has subsequently amended the ROP application. The company’s original application submittal also requested an opt-out limit for particulate matter but during the review of PTI No. 162-13, decided the potential did not warrant a particulate matter synthetic minor condition in the PTI or in the ROP. Equipment changes included in PTI No. 162-13 are for a new sealed auger system in lieu of the fuel ram system (more stable and efficient combustion), a new biofuel chipping operation and biofuel storage area, new combustion controls, and replacement of the steam turbine used to produce electricity. The company anticipates the changes will not be complete until a couple of months after the final ROP is issued. To address all of the issues involved with the changes, two emission units were created. EUBOILER3 contains conditions for the existing boiler system design and EUBOILER3162 contains the conditions from PTI No. 162-13. Herman Miller, Inc. will submit an ROP modification application to remove EUBOILER3 upon installation and operation of EUBOILER3162.
The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System in the 2013 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant / Tons per Year /Carbon Monoxide (CO) / 0
Lead (Pb) / 0.0005
Nitrogen Oxides (NOx) / 29
Particulate Matter (PM) / 2
Sulfur Dioxide (SO2) / 16.5
Volatile Organic Compounds (VOCs) / 5
Individual Hazardous Air Pollutants (HAPs) **
Hydrochloric Acid / <1
All Finishing HAPs Combined
Total Hazardous Air Pollutants (HAPs) / <1
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of CO2e is less than 100,000 tons. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory non-applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP.
The stationary source is located in Ottawa County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the facility is subject to National Emission Standard for Hazardous Air Pollutants for Wood Furniture Manufacturing promulgated in 40 CFR, Part 63, Subparts A and JJ. 40 CFR, Part 63, Subpart A requires that once a source is subject they are always subject to 40 CFR, Part 63, Subparts A and JJ and 40 CFR, Part 70. With the issuance of PTI No. 162-13, the stationary source is considered to be a “synthetic minor” source of HAP emissions because the stationary source accepted a legally enforceable permit condition limiting the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, to less than 10 tons per year and the potential to emit of all HAPs combined to less than 25 tons per year.
No emissions units at the stationary source are currently subject to the Prevention of Significant Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act 451, because at the time of New Source Review permitting the potential to emit of each criteria pollutant was less than 250 tons per year.
FGNESHAPJJ at the stationary source is subject to the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Wood Furniture Manufacturing promulgated in 40 CFR, Part 63, Subparts A and JJ. Changes were made to the information in the application to include the most recent requirements from the 2011 published NESHAP update.
FGDIESELFIRED was added to include fuel usage requirements for all diesel-fired equipment at the facility. Rule 336.1402(1) states, in part; “At a fuel burning source other than a power plant it is unlawful for a person to cause or allow the emission of sulfur dioxide from the combustion of any coal or oil fuel in excess of 1.7 pounds per million Btu of heat input for oil fuel.” Only diesel fuel is allowed to be burned in in this equipment. By definition, diesel fuel is Number 2 distillate oil. In order to be classified as distillate oil under the American Society for Testing and Materials (ASTM) Method D 396, the oil must have a sulfur content that is less than or equal to 0.5 weight percent. By definition, diesel fuel calculates to 0.28 pounds of sulfur dioxide per million Btu's of heat input and therefore subsumes the requirements of Rule 402(1) which is 1.7 pounds of sulfur dioxide per million Btu's of heat input.
FGEMERGENCYRICE covers all compression ignition and spark ignition emergency/back-up equipment used for electrical generation and fire suppression subject to the National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated in 40 CFR, Part 63, Subparts A and ZZZZ (the area source RICE MACT). The ROP contains special conditions for the applicable requirements in 40 CFR, Part 63, Subparts A and ZZZZ that were provided by Herman Miller Inc. The AQD is not delegated regulatory authority for this area source RICE MACT, therefore the special conditions for the MACT contained in FGEMERGENCYRICE were not reviewed by the AQD.
In March 2014, EUBOILER3 and EUBOILER3162 are subject to the National Emissions Standards for Hazardous Air Pollutants for Boilers promulgated in 40 CFR, Part 63, Subparts A and JJJJJJ (Area Source Boiler MACT). These emission units contain special conditions for the applicable requirements in 40 CFR, Part 63, Subparts A and JJJJJJ that were provided by Herman Miller, Inc. The EUBOILER3 and EUBOILER3162, Special Conditions X.1, 2, 3, 4, 5, 6 for the MACT were not reviewed by the AQD.
FGDUSTCOLLECTORS-CAM at the stationary source is subject to the federal Compliance Assurance Monitoring (CAM) rule under Title 40 CFR, Part 64. This flexible group consists of seven dust collector emission units that are subject to CAM. Each emission unit has a control device and potential pre-control emissions of particulate matter greater than the major source threshold level. The monitoring for each dust collector control device is the use of a broken bag detector system.
FGBOILER3-CAM at the stationary source is subject to the federal CAM rule under Title 40CFR, Part64. This emission unit is a wood-fired boiler with reburn tunnels, an acid gas sorbent injection system and a baghouse to control hydrochloric acid and particulate. FGBOILER3-CAM has a control device and potential pre-control emissions of particulate matter greater than the major source threshold level. The monitoring for FGBOILER3-CAM baghouse control device are daily non-certified visible emission checks conducted during routine maximum operating conditions.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals."
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-B6001-2009 are identified in Appendix 6 of the ROP.
PTI Number /264-85B / 926-84 / 500-86A / 676-92
347-80 / 471-81 / 82-89 / 359-94
291-07
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.
ExemptEmission Unit ID / Description of
Exempt Emission Unit / Rule 212(4)
Exemption / Rule 201
Exemption /
EU-RTU-F1 / COMBO COOLING/HEATING UNIT RTU1 (0.250 MMBtu) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-F1 / COMBO COOLING/HEATING UNIT
(0.350 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-G5 / COMBO, COOLING/HEATING UNIT
(0.120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-STOREROOM / COMBO, COOLING/HEATING UNIT
(0.040 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-BG4 / COMBO, COOLING/HEATING UNIT
(0.250 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-BG7 / COMBO, COOLING/HEATING UNIT
(0120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-BG6 / COMBO, COOLING/HEATING UNIT
(0.120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-BG1 / COMBO, COOLING/HEATING UNIT
(0.250 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-CAF3/AHU3 / COMBO, COOLING/HEATING UNIT
(0.250 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-RTU-BGS3 EAST / COMBO, COOLING/(HEATING) UNIT VAV W/RH / Rule 212(4)(b) / Rule 282(b)(i)
EU-RTU-BGS2WEST / COMBO, COOLING/(HEATING) UNIT VAV W/RH / Rule 212(4)(b) / Rule 282(b)(i)
EU-HTR-01 / UNIT HEATER
(0.200 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-MUA2WEST / DIRECT GAS/AIR UNIT
(0.155 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-MUA2EAST / DIRECT GAS/AIR UNIT
(0.290 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D-SE / COMBO COOLING/HEATING UNIT (0.075 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-FORMCOAT / COMBO COOLING/HEATING UNIT
(0.360 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-FORMCOAT / COMBO COOLING/HEATING UNIT
(0.360 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D12 / COMBO COOLING/HEATING UNIT
(0.120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D11 / COMBO COOLING/HEATING UNIT
(0.250 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D10 / COMBO COOLING/HEATING UNIT
(0.120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D7 / COMBO COOLING/HEATING UNIT
(0.120 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D8 / COMBO COOLING/HEATING UNIT
(0.150 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-D9 / COMBO COOLING/HEATING UNIT
(0.150 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-MAU-DS / DIRECT GAS FIRED HEATER
(4.400 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-AHU-ENE / COMBO COOLING/HEATING
(0.135 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-WHTR-ENMEZZ / GAS FIRED WATER HEATER
(0.076 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-WHTR-BG / GAS FIRED WATER HEATER
(0.040 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EU-HWBLR-BG / GAS FIRED HOT WATER BOILER
(0.300 MMBtu/hr) / Rule 212(4)(b) / Rule 282(b)(i)
EUCAFETERIA / MISC. CAFETERIA EQUIPMENT / Rule 212(4)(b) / Rule 282(e)
EU-JBLR-01 / JOHNSON BOILER 01 / Rule 212(4)(b) / Rule 282(b)(i)
EU-JBLR-02 / JOHNSON BOILER 02 / Rule 212(4)(b) / Rule 282(b)(i)
Draft ROP Terms/Conditions Not Agreed to by Applicant