Flexible Air Permitting and EPA's Proposed Rule—Briefing Sessions for Performance Track Participants

Pilot Flexible Air Permit Profile

Source: Saturn Corporation
Facility Type: Automobile Manufacturer
Location: Spring Hill, Tennessee

The Tennessee Department of Environment and Conservation (TDEC) and EPA worked with Saturn to develop a flexible air permit that enables Saturn to make operational changes in a streamlined manner. By increasing the plant’s ability to rapidly respond to market opportunities and to support continual improvement activities, the flexible permit has enabled Saturn to secure new work, directly creating over 700 jobs. The flexible permit ensures that all applicable regulatory requirements are addressed and creates incentives for pollution prevention.

On June 6, 2000, Saturn Corporation’s Spring Hill, Tennessee, automotive manufacturing facility received a flexible PSD air permit (Permit #952233). The flexible permit contained approved alternate operating scenarios that enabled Saturn to modify and add coating, assembly and machining equipment and process lines in a timely manner, without the 3-4 month application process required by conventional TDEC air permits. The flexible permit ensured that best available pollution control technologies were installed and that total air emissions remained under approved plant-wide limits (PALs).

Tools & Methods Used in the Pilot Permit

Alternative Operating Scenarios (AOS) and Advanced Approvals	Approvals for operational changes to existing emissions sources, such as changes to vehicle assembly, coating, and injection molding equipment and processes, as well as construction of new emissions sources, including a new engine manufacturing facility.
Approved Replicable Methodologies (ARMs)
Plantwide emissions caps	Variable PALs for VOC based on production (1,563 tons/year at 500,000+ vehicles per year; 198.5 tons/month). PALs for NOx, PM, SO, and CO (PALs are hybrids based on actual and allowable source emissions).
Pollution prevention (P2)	Participation in a voluntary P2 program in Tennessee (TP3).
Implementation logs

Environmental Benefits and Pollution Prevention

Reduced allowable and actual air emissions. Saturn’s flexible air permit enforced more stringent, site-wide pollution limits. Emissions of volatile organic compounds (VOCs), including those arising from a doubling of production capacity, were capped in the flexible permit to a level about 50 percent of its previous allowable emissions—from 2,897 tons per year (tpy) of VOCs to 1,563 tpy or less, depending on the production level. Saturn’s actual VOC emissions at the time of the EPA evaluation (2001) were considerably below this rate, at approximately 595 tpy. Allowable emissions of nitrous oxides (NOx) and particulate matter (PM10) were similarly reduced under the flexible PSD permit—from 380 tpy to 190 tpy, and 305 tpy to 205 tpy respectively.
Easier P2 implementation. The flexible permit encourages pollution prevention initiatives, since the facility has strong incentives to maintain emissions levels well below the plant-wide limits to assure compliance and to create room for increased economic growth under the emissions cap. Saturn introduced three energy conservation projects, initiated new methods to decrease hazardous air pollutants, and decreased its use of raw materials. The new permit reduced the delay and complications that sometimes surround the conventional permitting that guides these kinds of efforts.

Economic Competitiveness Benefits

Agile manufacturing. Global competitive pressures have compressed the typical new vehicle development process from 5 years to 18 months. To maximize their competitiveness, Saturn desired to remove potential permitting time delays and more easily predict the regulatory requirements of anticipated operational and equipment changes. Saturn reported that the permit has enabled the facility to make operational and equipment changes that yield both efficiency improvements and pollution prevention with significantly lower administrative costs, improving the plant’s ability to respond to competition.
Job creation. Saturn was chosen to manufacture GM’s L-850 engine, directly creating 700 new jobs, due in large part to the facility’s ability to rapidly construct and modify the new engine production lines. Using a combination of the PAL and advanced approved alternate operating scenarios, the flexible permit enabled Saturn to upgrade the facility with minimal delays to produce several new vehicles, including Saturn’s new fuel-efficient SUV, the Saturn Vue.

Monitoring and Enforceability

Replicable monitoring and routine reporting. Saturn tracked site-wide VOC emissions through replicable, mass-balance calculations and the EPA’s automotive protocol. The additional reporting and monitoring required under the permit assures practical enforceability and results in additional data availability for both the permitting authority and the public.
Increased ease of inspection. TDEC reported that inspection under the flexible permit is easier due to the reduction in the number of unit-specific emissions limits.

Government Efficiency

Paperwork and backlog reduction. According to TDEC, the permit has reduced agency paperwork and time associated with processing individual construction permit applications and permit modifications—as much as 24 to 40 staff hours per change in operations made by Saturn. This time savings allows agency staff to focus on higher environmental priorities.

Public Response

Public support. Two public comments were received during the public comment period for the draft PSD permit. The environmental organization Tennessee Environmental Council and the labor union UAW Local 85 both wrote expressing support for the flexible permit.
No complaints. No public complaints have been received during the permit term (as of 2001), and Saturn has worked proactively to understand and address community concerns since initial construction began on the facility in 1985.