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HomeMy WebLinkAboutAQ_F_1800365_20190410_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Corning Optical Communications,LLC-HMTC NC Facility ID 1800365 Inspection Report County/FIPS: Catawba/035 Date: 04/10/2019 Facility Data Permit Data Corning Optical Communications,LLC-HMTC Permit 06409/R20 1164 23rd Street SE Issued 2/2/2018 Hickory,NC 28602 Expires 1/31/2026 Lat: 35d42.7074m Long: 81d 17.5590m Class/Status Small SIC: 3357/Nonferrous Wire Drawing/Insulating Permit Status Active NAILS: 335921 /Fiber Optic Cable Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Steve Street Ahmed Koilakh Steve Street Senior EHS Coordinator Plant Manager Senior EHS Coordinator (828)901-6695 (828)901-5699 (828)901-6695 Compliance Data Comments: Inspection Date 04/10/2019 Inspector's Name Donna Cook Inspector's Signature: D a Cook Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: [ ,2� '/ On-Site Inspection Result Compliance Total Actual emissions inIITONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 1.23 --- --- 33.17 --- 1.23 804.50 2012 --- --- --- 30.60 --- --- 1693.05 *Highest HAP Emitted in pojjnds Five Year Violation History:None Date Letter Tyne Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: None Date Test Results Test Method(s) Source(s)Tested Corning Optical Communications,LLC—HMTC April 10, 2019 Page 2 Type Action: X Full Compliance v _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: X Date submitted for initial review 04/16/2019 / _IBEAM WARNING/OB,NOD,NOV,NRE X IBEAM Document X IBEAM Inspection,list date inspected ✓ X IBEAM LAT/LONG,Facility Locked X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG, Coordinates checked--) X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint X IBEAM Planning,Next Inspection Date 04/01/2021 Directions: From Mooresville Regional Office to Hickory,travel via Statesville Avenue;North Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte Highway (Highway 21 North and Highway 115 North); Interstate 77 North; Exit 5 1-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 126-US 70/Hickory/Newton;turn right off exit ramp onto McDonald Parkway SE; and then immediately take the next street to the right onto 23`d Street SE. The driveway for Corning Optical Communications,LLC HMTC is located on the left. The street address of this company is 1164 23`d Street SE. Safety Equipment: The inspector will have to show a driver license at the security entrance in order to gain access to this facility. The inspector will not be allowed to wear lanyards. No photography, recording devices or cell phones are allowed in the facility. This company requires that the inspector wear steel-toed shoes, safety glasses, safety vest and hearing protection at this facility. Safety Issues: The inspector should be cautious of forklifts at this facility. Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated.Facilities" are not accessible on the DAQ web site. The latitude and longitude coordinates of this facility are accurate and locked in IBEAM. Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by Mr. Steve Street, senior ehs coordinator. No changes to the email addresses in IBEAM are needed. 1. The purpose of this site visit was to conduct a routine air quality inspection. This facility manufactures indoor and outdoor fiber optic cable for the telecommunication industry. This company operates 24 hours per day, 7 days per week, 52 weeks per year. Mr. Steve Street, senior ehs coordinator, and Ms.Kimberly Kelley, ehs manager, accompanied me during this inspection. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Street. No changes are needed in IBEAM. 3. Compliance history file review: No problems have been noted in the last five years by DAQ prior to this inspection. The current compliance status is discussed in the following sections. Corning Optical Communications,LLC-HMTC April 10,2019 Page 3 4. Observations of permitted air emission sources and control devices: Emission Emission Source 7Control Control System Source ID Description System ID FDescription P 101, P 102,P 103, P 104, 'painting process 1 consisting 1 P105, P106, P107,P108, of seventy-two (72)painting ' P109,P110, P111, P112, lines (ID Nos. P101 through P113,P114,P115,P116, ;P172) ! P117,P118, P119,P120, j P121,P122, P123, P124, P125, P126,P127,P128, P129, P130,P131, P132, I P133,P134, P135,P136, N/A N/A P137,P138, P139, P140, P141, P142,P143, P144, P145,P146,P147, P148, P149,P150, P151, P152, P153,P154, P155, P156, I P157,P158,P159,P160, P161, P162,P163,P164, 'P165, P166,P167,P168, P169, P170,P171,P172 The compliant coatings are applied in the painting process 1. The routine cleaning applications are also conducted on the painting process 1. Any emissions from isopropyl alcohol (IPA)and acetone are fugitive. However, the emission sources on the painting process 1 have fume hoods that are located above the emission sources and exhaust outside of this facility. Observed. The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 1 were less than the 72 permitted painting lines. No visible emissions were observed by me from the painting process 1. No odors were detected by me from painting process 1. P301,P302, P303, P304, painting process 3 consisting P305,P306, P307, P308, jof eighteen(18)painting P309, P310,P311, P312, Ilines (ID Nos. P301 through .4 N/A N/A P313,P314,P315,P316, IP318) j P317, P318 The compliant coatings are applied in the painting process 3. The maintenance cleaning and repair applications are also conducted on the painting process 3. Any emissions from isopropyl alcohol(IPA), acetone, and methyl ethyl ketone(MEK) are fugitive. However,the emission sources on painting process 3 have fume hoods that are located above the emission sources and exhaust outside of this facility. Observed. The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 3 were less than the 18 permitted painting lines. No visible emissions were observed by me from the painting process 3. 'No odors were detected by me from painting process 3. ` P0322, P0323, P0324, 1painting process 4 consisting .1 N/A F N/A I Corning Optical Communications,LLC-HMTC I April 10, 2019 Page 4 I P0325,P0326,P0327, of twenty(20)painting lines P0328,P0329,P0330, (ID Nos. 0322 through P0331,P0332,P0333, P0341) :P0334,PO335,PO336, 3 JP0337, P0338,P0339, P0340,P0341 The compliant coatings are applied in the painting process 4.i The maintenance cleaning applications are also conducted on the painting process 4. Any emissions from isopropyl alcohol (IPA), acetone, and methyl ethyl ketone(MEK)are fugitive. However,the emission sources on painting process 4 have fume hoods that are located above the emission sources and exhaust outside of this facility. Observed. The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 4 were less than the 20 permitted painting lines. No visible emissions were observed by me from the painting process 4. ` No odors were detected by me from painting process 4. .P701, P702,P703, P704, Ipainting process 7 P705,P706,P707,P708, consisting of forty(40) P709,P710,P711,P712, painting lines(ID Nos. P701 ,P713,P714,P715,P716, through P740) .P717,P718, P719, P720, N/A N/A P721, P722,P723, P724, l P725,P726,P727, P728, P729,P730,P731,P732 P733, P734, P735,P736 P737,P738,P739, P740 The compliant coatings are applied in the painting process 7.i The maintenance cleaning applications are also conducted on the painting process 7. Any emissions from methyl ethyl ketone(MEK) are fugitive. However,the emission sources on painting process 7 have fume hoods that are located above the emissions and exhaust outside of this facility. 1 'Observed. The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 7 were less than the 40 permitted painting lines. No visible emissions were observed by me from the painting process 7. No odors were detected by me from painting process 7. 4 PMO1,PM02,PM03,PM04, Ten(10) spare printers PM05,PM06, PM07,PM08, N/A N/A PM09,PM10 _ - Mr. Street stated that the ten spare printers will minimize downtime on the paint processing lines. The ten inkjet printers will replace the operating printers on the painting process lines 3 and 7 if maintenance is needed on them. The inkjet printers are located in the northwest corner of the manufacturing plant. Any emissions from the cycling of methyl ethyl ketone(MEK)through the ten inkjet printers are fugitive. i Observed. The three inkjet printers were offline but circulating methyl ethyl ketone(MEK)to keep the lines clear at the time of the inspection. C 101, C 102, C 103, C 104, ,cleaning process 1 consisting.] N/A ���� N/A Corning Optical Communications, LLC—HMTC April 10, 2019 Page 5 1105 of five(5)cleaning lines (ID ]Nos. C 101 through C 105) The maintenance cleaning applications for the curing dyes are conducted in the cleaning process 1. Any emissions from isopropyl alcohol (IPA) in bottles and acetone in bath are fugitive. However, one cleaning line and a manual station in the cleaning process 1 have fume hoods that exhaust outside of this facility. Observed. The cleaning applications were operational at the time of the inspection. I observed that the emission sources on the cleaning process 1 were less than the five permitted cleaning lines. No visible emissions were observed by me from the cleaning process 1. No odors were detected by me from cleaning process 1. C601, C602, C603 cleaning process 2 consisting of three(3) cleaning lines N/A N/A (ID Nos. C601 through jC603) I The repair cleaning applications in extrusion area are conducted in the cleaning process 2. Any emissions from isopropyl alcohol(IPA) and methyl ethyl ketone(MEK) are fugitive. Observed. The cleaning applications were operational at the time of the inspection. I observed that the emission sources on the cleaning process 2 were less than the three permitted cleaning lines. No visible emissions were observed by me from the cleaning process 2. No odors were detected by me from cleaning process 2. C301, C302, C303, C304cleaning process 3 consisting pf four(4)cleaning lines (ID N/A F N/A ,jNos. C301 through C304 The cleaning applications for extrusion tooling are conducted in the cleaning process 3. Any emissions from these operations are hydrocarbons, nitrogen oxide(NOx), particulate matter and hydrochloric acid. The particulate emissions are captured by two cyclones that are installed on two electric ovens and two baths. Each stack of the two cyclones is manifolded and exhaust outside of this facility. Observed. The cleaning applications were operational at the time of the inspection. I observed that the emission sources on the cleaning process 3 were less than the four permitted cleaning lines. No visible emissions were observed by me from emission sources or two cyclones on the cleaning process 3. No odors were detected by me from cleaning process 3. C401, C402, C403, C404, cleaning process 4 consisting F C405, C406 of six(6) cleaning lines (ID N/A N/A Nos. C401 through C406) The cleaning and maintenance applications involve the use of parts washers. Any volatile organic compounds (VOC) emissions from the two parts washers are fugitive. Observed. The cleaning and maintenance applications using the parts washers were not in use at , the time of the inspection. I observed that the cleaning lines on cleaning process 4 were less than the six permitted cleaning lines. No visible emissions were observed by me from the parts washers. No odors were detected-by-me from the parts washers. E101,E102, E103, E104, extrusion process 1 N/A N/A i Corning Optical Communications,LLC-HMTC April 10, 2019 Page 6 i E105,E106, E107, E108, consisting of ten(10) E109,El 10 extrusion lines(ID Nos. E101 through El 10) The extrusion of plastics materials is conducted in extrusion process 1. Volatile organic compound(VOC)emissions are emitted from the extrusion process 1. The cleaning with isopropyl alcohol(IPA) is conducted in the extrusion area. The extruders on extrusion process 1 vent to the outdoor atmosphere. Observed. Extrusion process 1 and cleaning applications were operational at the time of the inspection. I observed that the emission sources on extrusion process 1 were less than the ten permitted extrusion lines. No visible emissions were observed by me from extrusion process 1 or j cleaning applications. No odors were detected by me from extrusion process 1 or the cleaning applications. E201,E202,E203,E204, extrusion process 2 E205,E206,E207,E208, consisting of forty(40) E209,E210,E211,E212, extrusion lines(ID Nos. E213,E214,E215,E216, E201 through E240) E217,E218,E219,E220, N/A N/A E221,E222,E223,E224, E225,E226,E227,E228, E229,E230,E231, E232, E233,E234,E235, E236, E237,E238,E239, E240 The extrusion of plastics materials is conducted in extrusion process 2. The volatile organic compound (VOC) emissions are emitted from the extrusion process 2. The extruders on extrusion process 2 vent outside of this facility. j � I Observed. The extrusion process 2 was operational at the time of the inspection. I observed that the emission sources on extrusion process 2 were less than the 40 permitted extrusion lines. No visible emissions were observed by me from extrusion process 2. No odors were detected by me from extrusion process 2. E301,E302,E303, E304, extrusion process 3 I E305, E306,E307, E308, consisting of twelve (12) N/A N/A 'E309,E310,E311, E312 extrusion lines(ID Nos. E301 through E312) Mr. Street stated that extrusion process 3 has been moved from this facility and installed at another Corning facility. i Observed. The extrusion process 3 is no longer at this facility. Mr. Street stated that the extrusion process 3 consisting of twelve(12)extrusion lines�(ID Nos.E301 and E312) should remain on the current air permit forfuture growth. E401,E402,E403,E404, extrusion process 4 E405,E406,E407,E408, consisting of ten(10) N/A N/A E409,E410 extrusion lines (ID Nos. E401 through E410) The extrusion of plastics materials is conducted in extrusion process 4. The volatile organic compound(VOC)emissions are emitted from the extrusion process 4. The extruders on extrusion Corning Optical Communications, LLC—HMTC April 10, 2019 Page 7 process 4 vent outside of this facility. No cleaning is conducted in the extrusion area. Observed. The extrusion process 4 was operational at the time of the inspection. I observed that the emission sources on extrusion process 4 were less than the ten permitted extrusion lines. No visible emissions were observed by me from extrusion process 4. No odors were detected by me from extrusion process 4. ESD Imetar--- 1 machining ^�N/A __. -�-YN/A M The machines lathe metal tools using oil and water-based coolants inside the machine shop of MESD. All of the metal machining sources use volatile organic compounds(VOC)containing materials for the purposes such as cutting, cleaning and lubrication. The six industrial air cleaners(also referenced in insignificant/exempt activities,IAC-industrial air cleaners or also referred to as electrostatic precipitators)are used to attract and capture any fugitive oily mist from the cutting oils of the metal machining operations inside of this shop. The main purpose of six industrial air cleaners is to improve the employee comfort during the metal machining operations. The metal machining operations and the six industrial air cleaners do not exhaust outside of this facility. Observed. The metal machining of tools was being conducted with no visible emissions observed from the metal machining operations-or the six industrial air cleaners at the time of the inspection. AU ;ammonia usage N/A F N/A ---------------------- Mr. Street stated that ammonia is not being used at this facility. Observed. No ammonia use was observed by me at this facility. _ _ PSB1 dry filter-type spray booth, N/A F77 N/A The spray booth equipped with dry filters was installed in August 2015. The spray booth is located in the former battery room of this facility. No manufacturing process is occurring in the spray booth. This company uses aerosol spray cans in the booth-to apply touch-up paint to the maintenance work carts. The spray booth exhausts outside of this facility. Observed. No painting using aerosol cans was being conducted at the time of the inspection. The dry filters were in place in the booth at the time of the inspection. IPW parts washer N/A N/A The Cuda model electrically heated parts washer is located in the machine shop of this facility. The parts washer contained detergent(6.36/o VOC/glycol ether)that is used to clean various metal tooling equipment. The parts washer vents outside of this,facility. Observed. The Cuda model electrically heated parts washer was operational at the time of the t inspection. No visible emissions were observed or any odors detected by me from the parts washer at the time of the inspection. i Corning Optical Communications, LLC—HMTC April 10, 2019 Page 8 I 5. Observations of insignificant air emission sources and control'devices listed on the current permit: • I Source Exemption Source of Source of Title V Regulation TAPS? Pollutants? IC501 —QA and technology lab 2Q .0102 Yes Yes (g)(3)(B) The material evaluation processes are conducted in AQ lab for new raw materials and technology labs for potential raw materials. Acetone,toluene, chloroform, IPA and MEK are used in the material evaluation processes. Various fume hoods and muffle furnaces vent outside of this facility. Observed. The material evaluation processes were operational in the AQ and technology labs at '. the time of the inspection. I observed no visible emissions or detected any odors from the AQ and' technology labs. 2Q .0102 IC504 -cleanin process { I Yes Yes (g)(3)(B) This process uses one EDM to place holes in metal. This process exhausts through a hood to the outside atmosphere. i Observed. The EDM machine was not in operation at the time of the inspection. IMPDE-five(5)MPDE storage silos 12Q .0102 (h)(5) ; No Yes The five MPDE silos are located outside of this facility. The five MPDE silos are used to store plastic materials.- A vacuum system is used to unload the plastic materials from the tanker trucks into the five MPDE silos. Observed. No tanker truck unloading of plastic materials into the five MPDE silos was occurring; at the time of the inspection. The five MPDE storage silos were in use with no visible emissions observed or odors detected by me at the time of the inspection. IFR-flexible resin vacuum system 12Q .0102 (h)(5) j No Yes venting to a fabric filter The flexible resin vacuum system is used to transport the compounding materials to the electric drying operations (ID No.I-DRY) and then to the extruders. Various filter systems are used to capture particulate matter emissions from the flexible resin vacuum system. The filter systems do not exhaust outside of this facility. Since there are multiple particulate filter systems associated with flexible resin vacuum system,then the description should be changed to flexible resin vacuum venting to filter systems during the next permit revision. This process is also discussed in the electric drying operations(ID No. I-DRY). 'Observed. The flexible resin vacuum system with associated filter systems were operational with'. no visible emissions observed or odors detected at the time of the inspection. IAC -industrial air cleaners 2Q .0102 (h)(5) Yes Yes The six industrial air cleaners (also referenced in MESD-metal machining) are used to attract and capture any fugitive oily mist from the cutting oils used in the metal machining operations (ID No. MESD) inside the machine shop of MESD. The main purpose of is to improve the employee comfort during the metal machining operations. The six industrial air cleaners and the metal Corning Optical Communications, LLC—HMTC April 10, 2019 Page 9 machining operations do not exhaust outside of this facility. Observed. The six industrial air cleaners and metal machining processes were in operation with no visible emissions observed at the time of the inspection. IVH-vent hood 12Q .0102 (h)(5) Yes J Yes Observed. Mr. Street stated that the vent hood in the clean room had never been installed at this facility. ISH-four(4) oil evaporation lines I 2Q .0102 (h)(5) ; No F7 Yes each venting to smog hogs The four process lines are used to evaporate oil off of products on the bx lines. The four oil evaporation lines vent to two smog hogs. Both smog hogs have separate exhausts outside of this facility. Observed. The two smog hog and four oil evaporation lines were in operation with no visible emissions observed at the time of the inspection. IE619-research/saleable product j�� extrusion line 2Q .0102 (h)(5) No Yes The extrusion line 619 is used for technology research and development of outdoor cable products. The extrusion line 619 exhausts outside of this facility. The inkjet printing is also occurring on the extrusion line 619. The extrusion line 619 and extrusion lines 975-1 and 975-2 share the same inkjet printer. Observed. The extrusion line 619 was not in operation at the time of the inspection. re.IE -research/saleable product 2Q .0102 (h)(5) NoYes 975 trusion line I� The extrusion lines 975-1 and 975-2 are used for technology research and development of outdoor cable products. The extrusion lines 975-1 and 975-2 exhaust outside of this facility. The inkjet ,'printing is also occurring on the extrusion lines 975-1 and 975-2. The extrusion lines 975-1 and 975-2 and extrusion line 619 share the same inkjet printer. Observed. The extrusion lines 975-1 and 975-2 were not in operation at the time of the inspection. I-SO - soldering operation No No 2Q .0102 1(g)(14)(B) The MESD operations use solder for extrusion tooling equipment. Any emissions from this process is fugitive inside of the machine shop. Observed. No soldering operations were observed by me at the time of the inspection. 12Q .0102 erations (g)(14)( I-DRY -electric drying op No No JB). The compounding materials is transported by the flexible resin vacuum system to the electric drying operations (ID No. I-DRY) and then to the extruders. The electric drying operations(ID No.I-DRY) are comprised of ten electric dryers in the manufacturing area and nine electric dryers in an enclosed room of this facility. These dryers vent outside of this facility to remove heat from the drying process and to provide employee comfort. This process is also described in the IFR- i Corning Optical Communications, LLC—HMTC April 10, 2019 Page 10 ! flexible resin vacuum system venting to filter systems. Observed. The electric drying operations(ID No. I-DRY; 19 electric dryers)were operational with no visible emissions observed or odors detected at the time of the inspection. I-QTCP -quartz tube cleaning process 2Q .0102 (h)(5) No No The quartz tubes are cleaned in this process by using heat from two electric ovens to remove any residue from them. The two electric ovens exhaust outside of this facility. Observed. The quartz tube cleaning process was not in operation at the time of the inspection. 6. Observations of air emission sources and control devices not listed on the current permit: a. This company has various cartridge filter systems installed on extrusion processes that do not exhaust outside of this facility. The filter systems are exempt per 15A NCAC 2D .0102 (g)(14)(J)-equipment not vented to the outdoor!atmosphere and not listed as exempt sources per DAQ policy. I b. This company has natural gas-fired furnaces that are used to provide comfort heat to the employees in the warehouse and manufacturing areas of this facility. Mr. Street stated that there are currently five natural gas-fired furnaces at this facility. However, this company plans to add two additional natural gas-fried furnaces;for a total of seven. The natural gas- fired furnaces are exempt per 15A NCAC 2Q .0102 (g)(5)(A) and not listed as exempt sources per DAQ policy. C. This company has a laser etching process that exhausts to a HEPA filter. The HEPA filter is ,located under the laser etching process on the floor and exhausts inside of the machine shop room. The laser etching process and HEPA filter were not in operation at the time of the inspection. The laser etching process is exempt per 15A NCAC 2D .0102 (g)(14)(J)- equipment not vented to outdoor atmosphere and not 1listed per DAQ policy. d. This company has one carbon dioxide and one nitrogen storage tanks. These storage tanks are exempt from permitting per 15A NCAC 2Q .0102 (g)(14)(A) and not listed as exempt sources per DAQ policy. i e. This company has one dip tank (model, LPS Precision Clean by LPS Laboratory) containing 140 gallons of an alkaline detergent (non-VOC compound). The dip tank is located next to the electrically heated CUDA parts washer in the machine shop of this facility. Mr. Street stated that ferrules are placed in a basket and then dipped into the tank for the purpose of washing off the coolant from the machining process. The dip tank has no exhaust outside of this facility. The dip tank is exempt per 15A NCAC 2Q .0102 (g)(14)(A)• . f. Duke Energy has installed a natural gas-fired Caterpillar(CAT)model emergency generator rated at 100 kilowatts for the purpose of providing power during electrical outages to the information technology(i.t..) system at this facility in April 2019. The owner and operator of the natural gas-fired emergency generator is Duke Energy. Corning Optical Communications,LLC has no access or control over the operations of Corning Optical Communications,LLC—HMTC April 10, 2019 Page 11 the natural gas-fired emergency generator at its facility as indicated by Mr. Street. The natural gas-fired emergency generator is exempt per 15A NCAC 2Q .0102 (h)(5). g. The welding operations are conducted only for maintenance purposes at this facility. The welding operations are not subject to 40 CFR Part 63 Subpart XXXXXX (6X),NESHAP for Nine Fabrication and Finishing Area Source Categories, since the primary SIC code 3357 (nonferrous wire drawing/insulating) and NAICS code 335921 (fiber optic cable manufacturing) of this facility does not match the SIC or NAICS listed in the NESHAP 6X rule. 7. Compliance with specific permit conditions and limitations: a. Condition A. 2. Permit Renewal and Emission Inventory Requirement-The permittee at least 90 days prior to the expiration date of this permit shall request permit renewal by letter with an application form and submit the air pollution emission inventory report with certification sheet for 2024 calendar year to MRO DAQ. Observed. The current air permit will expire on January 31, 2026. The permit renewal process was discussed with Mr. Street and Ms.Kelley. Compliance with this stipulation is indicated. b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes," particulate matter emissions from dry filter-type spray booth(ID No. PSB1) shall not exceed allowable emission rates. Observed. The dry filters are considered adequate control for capturing particulate matter from the spray booth(ID No. PSB1). The allowable emission rate from the dry filter type spray booth (ID No. PSB1) is not being exceeded. Compliance with this stipulation was indicated during the permit application process. C. Condition A. 4. Visible Emissions Control Requirement-As required by 15A NCAC 2D .0521 "Control of Visible Emissions",visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period. Observed. No visible emissions were observed by me from this facility. Compliance with this stipulation is indicated. d. Condition A. 5. Notification Requirement - As required by 15A NCAC 2D .0535, the permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence. Observed. Based on a conversation with Mr. Street, no excess emissions have occurred at the facility. Compliance with this stipulation is indicated. e. Condition A. 6. Fugitive Dust Control Requirement-As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emissions Sources",the permittee shall not cause Corning Optical Communications,LLC—HMTC April 10, 2019 ;. Page 12 I or allow fugitive dust emissions to cause or contribute to the substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are!observed beyond the property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR, Appendix A),the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). Observed. MRO DAQ has not received any fugitive!dust emissions complaints regarding this facility. This company has paved roads at this facility. During the inspection,I observed no fugitive dust or visible emissions from this facility. Compliance with this stipulation is indicated. j f. Condition A. 7.Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit"for each of the below listed toxic air pollutants (TAPS),the permittee has made a demonstration that facility-wide actual emissions,where one or more emission release points;are obstructed or non-vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .0711(a). Chronic Acute Acute Pollutant Carcinogens Toxicants , Systemic Irritants (lb/yr) (lb/day) Toxicants (lb/hr) (lb/hr) Acetic acid 64 19-7 0.96 - acid >_ -: Ammonia as NH3 7664-41-7 0.68 Benzene 71-43-2 8.1 Formaldehyde(50-00-0) _ _ ;... ._ 0.04 MEK(methyl ethyl ketone, 2- 78 22.4 butanone)(78-93-3) MIBK(methyl isobutyl ketone) 52 7.6 .(108-10-1) Methyl chloroform(71-55-6) 250 - 64 - _ . . Methylene chloride(75-09-2) 1600 0.39 FPerchlojroethylene 13000 i(tetrachloroethylene)(127-18-4) ' Phenol(108-95-2) _ _— 6.24 Toluene(108-88 3)... �..._-- 'l 98 14.4 ]Vinyl chloride 75-01-4 26 Ixylene(mixed isomers)(1330 20-7) F1 57 16.4 I F I Corning Optical Communications, LLC—HMTC April 10,2019 Page 13 Observed. The TPER limits of 2Q .0711(a) are applicable since the exhaust stacks are mixed vertical/horizontal and capped/uncapped at this facility. According to the 2016 emissions inventory and air permit review for R20,this facility operated 8760 hours and 365 days and emitted 9049.22 lbs/yr, 24.791bs/day and 1.03 lbs/hr of MEK; 221.74 lbs/yr, 0.61 lbs/day and 0.025 lb/hr of MIBK; 4.80 lbs/yr, 0.013 lbs/day and 0.00055 lbs/hr of methyl chloroform; 47.90 lbs/yr; 0.13 lbs/day and 0.0055 lbs/hr of toluene; and 6.60 lbs/yr, 0.018 lbs/day and 0.00075 lbs/hr of xylene. All the pollutants listed in the above TPER table were below the emission limits. Mr. Street has a spreadsheet along with MSDS information and material usage to calculate the actual emissions of the above referenced pollutants. A review of the spreadsheet data from January 1,2017 to January 31, 2019 indicated that methyl ethyl ketone(MEK), methyl isobutyl ketone(MIBK),phenol (used only in January 2019 and not in 2017 or 2018),toluene and xylene are the only pollutants emitted from this facility. The actual emissions from these pollutants are less than the TPER limits listed in the above referenced table. Compliance with this stipulation is indicated. 8. NSPS/NESHAP Review: The sources at this facility are not subject to NSPS. This company is not subject to EPA rules, CFR Part 63, Subpart HHTEHH(6H),NESHAP: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources and 40 CFR Part 63, Subpart MMMM(4M),NESHAP for Surface Coating of Miscellaneous Metal Parts and Products. EPA 6H rule only applies to spray application of coatings containing compounds of chromium (Cr), lead(Pb), manganese(Mn), nickel(Ni), and cadmium(Cd), collectively referred to as the target HAPs and chemical strippers that contain methylene chloride to removed dried paint from wood, metal, plastic, and other substrates. The spray coating operation does not emit any of the targeted HAPs and no paint stripping with any chemicals is used by this facility. EPA 4M rule only applies to a facility that is a major source of HAPS. This facility does not emit or have the potential to emit equal to or greater than 10 tons per year of any one HAP or 25 tons per year of any combination of HAP. This company has no boilers, fire pump engines, peak shaving generators or gasoline storage tanks at this facility. A natural gas-fired emergency generator rated at 100 kilowatts has been installed by Duke Energy for the purpose of providing power during electrical outages to the information technology(i.t..) system at this facility. The owner and operator of the natural gas-fired emergency generator is Duke Energy. Corning Optical Communications,LLC has no access or control over the operations of the natural gas-fired emergency generator at its facility as indicated by Mr. Street. The welding operations are only for maintenance purposes at this facility. The welding operations are not subject to 40 CFR Part 63 Subpart XXXXXX(6X)GACT,NESHAP for Nine Fabrication and Finishing Area Source Categories, since the primary SIC code 3357 (nonferrous wire drawing/insulating) and NAICS code 335921 (fiber optic cable manufacturing)of this facility does not match the SIC or NAICS listed in the NESHAP 6X rule. i Corning Optical Communications,LLC—HMTC April 10,2019 Page 14 9. Summary of changes needed to the current permit: a. The description of the insignificant/exempt activity, flexible resin vacuum system venting to a fabric filter(ID No. IFR), should be changed to reflect multiple particulate filter systems instead of only one fabric filter. b. The electronic yellowsheet for permit changes needed Las been completed and placed in the facility's electronic file. 10. Compliance assistance offered duringthe he inspection: i None. i i 11. Section 112(r)applicability: I This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r) of the Clean Air Act. i 12. Compliance determination: Based on my observations, this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. DLC:Ihe c: MRO File https://ncconnect.sharepoint.com/sitcs/DAQ-MRO/Counties/CATAWBA/00365/fNSPECT_20190410.docx i I I i I f I i I i I