At their facility in Romeo, Michigan, Romeo RIM manufactures plastic components such as bumpers, fascia, side panels, hoods and engine cowlings for trucks, recreational vehicles, and tractors/heavy equipment, as well as components for other consumer products. Products are made of polyurethane and other materials using reaction injection molding (RIM) equipment. These operations occur in a closed mold (also known as a clamp) where a resin and a catalyst are injected into the mold to react and form a solid plastic component. The facility is an existing Title V major source for both volatile organic compounds (VOCs) and hazardous air pollutants (HAPs), and Macomb County is currently classified as a non-attainment area for ozone.
Romeo RIM planned to decommission three RIM clamps and relocate two remaining RIM clamps to provide space for new production equipment and operations. Barr developed permit to install (PTI) application materials for the decommissioning and evaluated the effects of relocation of the two remaining clamps under Michigan air rules exemptions as a non-meaningful change to a source of toxic air contaminants (TAC). This allowed decommissioning and relocation activities to begin immediately.
When Romeo RIM subsequently planned to install two new RIM clamps to produce exterior body components for delivery trucks, Barr assisted in evaluating the project and determined a PTI application was required. The evaluation included working closely with chemists and production specialists from the resin-package supplier to assess the minimal VOC emissions associated with the reaction and to estimate potential VOC emissions assuming maximum operating levels.
To minimize Romeo RIM’s air permitting and compliance obligations, avoiding those required by non-attainment New Source Review (NSR), Barr developed synthetic minor emission limits and associated operational limits for the PTI application. These proposed permit conditions allowed sufficient flexibility for the planned production levels and allowed for future increase in production levels. Barr evaluated TAC ambient impact levels and best available control technology (BACT) requirements for TAC and VOCs to confirm the operation and associated emissions meet applicable Michigan air rules requirements.
Additionally, we assessed the compliance of project HAP emissions under the National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products (NESHAP PPPP) for the coating of miscellaneous plastic parts and incorporated the equipment and operations into the facility’s existing PPPP compliance program.