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Home My WebLink AboutAQ_F_0800044_20170605_CMPL_MACT-Corr ROY COOPER N,.r, .. Governor MICHAEL S. REGAN Secretary Air Quality MICHAEL A. ABRACZINSKAS ENVIRONMENTAL QUALITY ActingDiredor June 5, 2017 Mr.Brian Conner Environmental Health&Safety Manager PO Box 129 841 Avoca Farm Road Merry Hill,NC 27957 Subject: Approval of MON Alternative Scrubber Operating Parameters Request Avoca, Inc.,Merry Hill, Bertie County, North Carolina Facility ID No. 0800044,Permit No.01819T47 Dear Mr.Conner: The North Carolina Division of Air Quality(NCDAQ)has reviewed your request for an alternative monitoring scenario to comply with certain regulatory requirements. Your letter from Mr.David M. Peele, President of Avoca,Inc.,dated March 14,2017,has been reviewed. After a review of the regulatory requirements,your proposed alternative monitoring approach to complying with the standards,and NCDAQ's authority in considering your request,we are approving your request for alternative monitoring. BACKGROUND The Avoca facility in Merry Hill operates a new affected source(identified as SDE-2)that is subject to National Emission Standards for Hazardous Air Pollutants,40 CFR 63,SubpartFFFF,Miscellaneous Organic NESHAP(MON,MACT Subpart FFFF). The facility emits a n-hexane (a listed HAP)and is required to control to an emission standard or through demonstration of 95%control of emissions. The facility complies with these requirements using a final vent condenser and mineral oil scrubber to capture n-hexane. The monitoring,recordkeeping and reporting requirements for this listed device is found in 40 CFR 63,Subpart SS. Your request includes the following: 1. Waiving the use of specific gravity monitoring since no specific gravity monitor could be located; 2. Monitoring inlet air temperature to the absorber and establishing a maximum of 105°F; 3. Monitoring the inlet oil temperature to the scrubber and establishing the maximum temperature of 105°F; State of North Carolina 1 Environmental Quality : Air Quality 217 W.Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 2 769 9-16 41 919 707 8400 Mr. Brian Conner June 5,2017 Page 2 4. Monitoring the oil flow rate to the scrubber and establishing the minimum oil flow rate of 10 gpm and; 5. Monitoring oil temperature into the stripper and establishing a minimum oil inlet temperature of 200°F. NCDAQ reviewed your request and determined that it meets the elements required for use of an alternative monitoring method under 60 CFR 63.8(f). Under the definition contained in 40 CFR 63.90(a),this request to change to alternative parametric monitoring is an intermediate change in monitoring. NCDAQ is given delegation to consider both minor and intermediate changes to monitoring under 40 CFR 63.2545. Since this change is not classified as a major change (see 40 CFR 63.2545(b)(3)),NCDAQ has the authority to consider and approve your request. These monitoring parameters must be confirmed during the upcoming performance test. CONCLUSION NCDAQ approves your request to use these alternative monitoring parameters. These alternative monitoring requirements will be incorporated into your Title V permit through a permit revision process. If you have any questions concerning this approval or other issues concerning the alternative monitoring process,please contact Gary Saunders at(919) 707-8413 or at g-arv.sanunders@ncdenr.gov. Si ely, onald R.van der Vaart, P.E.J.D Chief,Technical Services Section NC DEQ, Division of Air Quality Cc: Robert Fisher,Washington Regional Office Central Files,Bertie County IBEAM Documents- 0800044 State of North Carolina I Environmental Quality i Air Quality 217 W.Jones Strect 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641 919 7W 8400 ROY COOPER N,.r, .. Governor MICHAEL S. REGAN Secretary Air Quality MICHAEL A. ABRACZINSKAS ENVIRONMENTAL QUALITY ActingDiredor June 5, 2017 Mr.Brian Conner Environmental Health&Safety Manager PO Box 129 841 Avoca Farm Road Merry Hill,NC 27957 Subject: Approval of MON Alternative Scrubber Operating Parameters Request Avoca, Inc.,Merry Hill, Bertie County, North Carolina Facility ID No. 0800044,Permit No.01819T47 Dear Mr.Conner: The North Carolina Division of Air Quality(NCDAQ)has reviewed your request for an alternative monitoring scenario to comply with certain regulatory requirements. Your letter from Mr.David M. Peele, President of Avoca,Inc.,dated March 14,2017,has been reviewed. After a review of the regulatory requirements,your proposed alternative monitoring approach to complying with the standards,and NCDAQ's authority in considering your request,we are approving your request for alternative monitoring. BACKGROUND The Avoca facility in Merry Hill operates a new affected source(identified as SDE-2)that is subject to National Emission Standards for Hazardous Air Pollutants,40 CFR 63,SubpartFFFF,Miscellaneous Organic NESHAP(MON,MACT Subpart FFFF). The facility emits a n-hexane (a listed HAP)and is required to control to an emission standard or through demonstration of 95%control of emissions. The facility complies with these requirements using a final vent condenser and mineral oil scrubber to capture n-hexane. The monitoring,recordkeeping and reporting requirements for this listed device is found in 40 CFR 63,Subpart SS. Your request includes the following: 1. Waiving the use of specific gravity monitoring since no specific gravity monitor could be located; 2. Monitoring inlet air temperature to the absorber and establishing a maximum of 105°F; 3. Monitoring the inlet oil temperature to the scrubber and establishing the maximum temperature of 105°F; State of North Carolina 1 Environmental Quality : Air Quality 217 W.Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 2 769 9-16 41 919 707 8400 Mr. Brian Conner June 5,2017 Page 2 4. Monitoring the oil flow rate to the scrubber and establishing the minimum oil flow rate of 10 gpm and; 5. Monitoring oil temperature into the stripper and establishing a minimum oil inlet temperature of 200°F. NCDAQ reviewed your request and determined that it meets the elements required for use of an alternative monitoring method under 60 CFR 63.8(f). Under the definition contained in 40 CFR 63.90(a),this request to change to alternative parametric monitoring is an intermediate change in monitoring. NCDAQ is given delegation to consider both minor and intermediate changes to monitoring under 40 CFR 63.2545. Since this change is not classified as a major change (see 40 CFR 63.2545(b)(3)),NCDAQ has the authority to consider and approve your request. These monitoring parameters must be confirmed during the upcoming performance test. CONCLUSION NCDAQ approves your request to use these alternative monitoring parameters. These alternative monitoring requirements will be incorporated into your Title V permit through a permit revision process. If you have any questions concerning this approval or other issues concerning the alternative monitoring process,please contact Gary Saunders at(919) 707-8413 or at g-arv.sanunders@ncdenr.gov. Si ely, onald R.van der Vaart, P.E.J.D Chief,Technical Services Section NC DEQ, Division of Air Quality Cc: Robert Fisher,Washington Regional Office Central Files,Bertie County IBEAM Documents- 0800044 State of North Carolina I Environmental Quality i Air Quality 217 W.Jones Strect 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641 919 7W 8400