AQ_F_0200088_20180402_PRMT_Permit

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
Air Quality 7��T TT A L 7 A A 7� 777 T/
ENVIRONMENTAL QUALITY MICHAEL A.ABRACZINSKAS
Director
April 2, 2018
Mr. Wayne Cassidy
Plant Manager
Triumph Insulation Systems, LLC
138 Wittenburg Industrial Drive
Taylorsville,NC 28681
Subject: Air Permit No. 08934R06
Triumph Insulation Systems, LLC
Taylorsville,Alexander County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 0200088
Dear Mr. Cassidy:
In accordance with your completed application received February 14, 2018, we are
forwarding herewith Permit No. 08934R06 to Triumph Insulation Systems, LLC,Taylorsville,
Alexander County,North Carolina for the construction and operation of air emissions sources or air
cleaning devices and appurtenances. Additionally, any emissions activities determined from your air
permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have
been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note
the records retention requirements are contained in General Condition 2 of the General Conditions
and Limitations.
If any parts,requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center,Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
State of North Carolina I Environmental Quality I Air Quality
Mooresville Regional Office 1 610 East Center Avenue,Suite 301 1 Mooresville,NC 28115
704 663 1699 T 1 704 663 7579 F

Wayne Cassidy
April 2, 2018
Page 2
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from April 2, 2018 until March 31,2026, is nontransferable to
future owners and operators,and shall be subject to the conditions and limitations as specified
therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation.The Permittee shall comply with all terms, conditions,requirements, limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
a. The condition for 2D .0958 has been removed from the permit. The rule has been updated to no
longer apply state-wide. Also,Alexander County is not located in the non-attainment area.
Therefore,the facility is no longer subject to the rule.
b. The condition for case-by-case MACT has been removed from the permit. The facility is no longer
considered a major source of HAP. Also,the"once-in-always-in"provision has been overturned
by EPA. Therefore,the facility is no longer subject to the rule.
C. The toxic pollutants of ammonia, ethyl acetate, MEK, and toluene were removed from the condition
for 2D .1100 because they never exceeded the TPER limits. These pollutants are being added to
the condition for 2Q .0711.
d. A condition for synthetic minor has been added to the permit. The facility will be required to perform
inspection and maintenance on the thermal oxidizer to show compliance and to maintain emissions
to less than 10/25 tons per year of HAP.
e. A condition has been added to the permit that requires the facility to submit a compliance
certification for the time period they were still classified as Title V for calendar year 2018.
Should you have any questions concerning this matter,please contact Denise Hayes at 704-663-
1699.
Sincerely,
uce J. IngYe, Regiona Supervisor
Division of Air Quality, NC DEQ
DFH
Enclosures
c: Mooresville Regional Office
https:#ncconnect.sharepoint.conVsi tes/deq/daq_mro/Counties/ALEY,ANDER/00088/R06_PERMIT.docx

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 08934R06
Issue Date: April 2, 2018 Effective Date: April 2,2018
Expiration Date: March 31, 2026 Replaces Permit: 08934T05
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 2 1 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Triumph Insulation Systems, LLC
138 Wittenburg Industrial Drive
Taylorsville, Alexander County,North Carolina
Permit Class: Synthetic.Minor
Facility ID# 0200088
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
_ Source ID_ Description System ID j Description
ES01,ES02 propane-fired laminator(ID CDO 1 propane-fired regenerative
o.ESO1;4.8 million Btu thermal oxidizer(3.0 million
per our maximum heat Btu per hour heat input rate)
input rate)and mixing room
(ID No.ES02)
in accordance with the completed application 0200088.18A received February 14, 2018 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environmental Quality, Division of Air Quality (DAQ)and are incorporated
as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:

Permit No. 08934R06
Page 2
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0516, 2D .0521,2D .0535,2D .0540, 2D .0605,2D .1806, 2Q .0315 and 2Q
.0711.
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 in accordance with 15A NCAC 2Q .0304(d) and(0.Pursuant to 15A NCAC 2Q
.0203(i),no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request(with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit,the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65, The report shall be submitted to the Regional Supervisor,DAQ
and shall document air pollutants emitted for the 2024 calendar year.
3. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from
propane-fired laminator(ID No. ES01) shall not exceed 2.3 pounds per million Btu heat
input.
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, except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with a visible emissions standard in 15A
NCAC 2D .0524 "New Source Performance Standards" or.1110 "National Emission
Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521
visible emissions standard.
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:
a. 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 and
describe:
is the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,

Permit No. 08934R06
Page 3
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
6. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the.Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints are received 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).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile working,plant parking lots,
and plant roads (including access roads and haul roads).
7. COMPLIANCE CERTIFICATION - Pursuant to 15A NCAC 2D .0605:
Within 45 days of the issuance date of permit 08934R06,the Permittee shall submit a
compliance certification to the DAQ and to the EPA (Air and EPCRA Enforcement Branch,
EPA,Region 4, 62 Forsyth Street SW, Atlanta, GA 30303). The compliance certification
shall encompass the current calendar year from January 1st through the effective date of this
permit and be certified by a responsible official with all federally-enforceable terms and
conditions in the Title V permit, including emissions limitations, standards or work practices
as described in the Title V permit in accordance with 15 A NCAC 2Q .0508(m). The
compliance certification shall comply with additional requirements as may be specified
under Sections 114(a)(3) or 504(b) of the Federal Clean Air Act.
The compliance certification shall specify:
a. the identification of each term or condition of the TitleV permit that is the basis of
the certification;
b. the compliance status;
c. whether compliance was continuous or intermittent; and
d. the method(s)used for determining the compliance status of the source, currently and
over the reporting period.

Permit No. 08934R06
Page 4
8. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
9. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee, facility-wide
emissions shall be less than the following:
Pollutant Emission Limit
Tons er consecutive 12-month period)
Individual HAPs 10
Total HAPs 25
a. Inspection and Maintenance Requirements -
i. Thermal Oxidizer Requirements -Emissions shall be controlled as described
in the permitted equipment list. To comply with the provisions of this permit
and ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform periodic inspections and maintenance (I&M) as recommended
by the manufacturer.As a minimum,the Permittee shall perform an annual
(for each 12 month period following the initial inspection)internal inspection
of each primary heat exchanger and associated inlet/outlet valves to ensure
structural integrity.
b. Monitoring Requirements -
i. Thermal Oxidizer Requirements - The Permittee shall ensure the proper
performance of each thermal oxidizer by monitoring the following
operational parameters:
A. The Permittee shall continuously record the temperature measured
inside the second half of the oxidizer(away from the flame zone)with
a minimum temperature of 1600 degrees Fahrenheit.
B. The Permittee shall record the flow rate to the oxidizer(maximum
flow rate of 15,000 scfin) once per week.
c. Recordkeeping Requirements
i. A log book (in written or electronic format) shall be kept on site for thermal
oxidizer(ID No. CDO 1) and made available to Division of Air Quality
personnel upon request. The Permittee shall record all inspection,
maintenance and monitoring requirements listed above in the log book. Any
variance from the manufacturer's recommendations shall be investigated with
corrections made and date of actions recorded in the log book.

Permit No. 08934R06
Page 5
10. 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).
a. A permit to emit any of the below listed TAPs shall be required for this facility if
actual emissions from all sources will become greater than the corresponding
TPERs.
b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible
for obtaining a permit to emit TAPs and for demonstrating compliance with the
requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".
c. In accordance with the approved application,the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the
TPERs as listed below: .
Carcinogens Chronic Acute Systemic Acute
Pollutant (cinog Toxicants Toxicants Irritants
(lb/day) (lb/hr)_ (lb/hr)
Aminonia as NH3 7664-41-7 —�' 0 68
Ethyl acetate (141-78-6) 36
MEK(methyl ethyl ketone, 2- 78 I 22.4
butanone) (78-93-3)
Toluene (108-88-3) —� 98 � J���� 144_j
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville,NC 28115
704-663-1699
For identification purposes, each submittal should include the facility name as listed on the
permit,the facility identification number,and the permit number.

Permit No. 08934R06
Page 6
2. RECORDS RETENTION REQUIREMENT- In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years,unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ.Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted,new,or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit,no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1),this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.

Permit No. 08934R06
Page 7
10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such,
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to,process weight rates, firing rates,hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2),no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials,nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State,or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act(RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request,the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r)REQUIREMENTS-Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act,then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants -Prevention of
Accidental Releases -Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces,processes, handles,or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 21) .2600 and follow all DAQ
procedures including protocol approval,regional notification, report submittal, and test
results approval. Additionally, in accordance with 15A NCAC 2D .0605,the permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.

Permit No. 08934R06
Page 8
Permit issued this the 2nd of April, 2018.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Bruce J. Ingle `'
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 08934R06

ATTACHMENT to Permit No. 08934R06,April 2,2018
Insignificant!Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
IES-1 -propane-fired space heater 2Q .0102 No Yes
(65,000 Btu per hour heat input)_ (g)(5)(A)
IES-2 -propane-fired space heater 2Q .0102 No Yes
(65,000 Btu per hour heat input) (g)(5)(A)
IES-3 -propane-fired space heater 2Q .0102
(65,000 Btu per hour heat input) (g)(5)(A) i No Yes
IES-4 -propane-fired space heater 2Q .0102 _ No Yes
(45,000 Btu per hour heat input) (g)(5)(A)
IES-5 -propane-fired space heater 2Q .0102 No Yes
(45,000 Btu per hour heat input) (g)(5)(A)
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here:
hgps://deg.nc.gov/about/divi sions/air-quality/air-quality-permits/specific-permit-conditions-
re ug latory-guide