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HomeMy WebLinkAboutAQ_F_1900039_20160520_PRMT_Permit PAT MCCRORY DONALD R. VAN DER VAART t, SHEILA C. HOLMAN Air Quality ENVIRONMENTAL QUALITY May 20, 2016 Bill Kopp Plant Manager Moncure Plywood 306 Corinth Road Moncure,North Carolina 27559 SUBJECT: Air Quality Permit No. 03424T25 Facility ID: 1900039 Moncure Plywood Moncure,North Carolina Chatham County Fee Class: Title V PSD Status: Minor Dear Mr. Kopp: In accordance with your completed Air Quality Permit Application for a Reopen for Cause of your Title V permit received February 2, 2016, we are forwarding herewith Air Quality Permit No. 003424T25 to Moncure Plywood, 306 Corinth Road, Chatham County, Moncure, North Carolina authorizing the construction and operation of the emission source(s) and associated air pollution control device(s) specified herein. Additionally, any emissions activities determined from your Air Quality Permit Application as being insignificant per 15A North Carolina Administrative Code 02Q .0503(8) have been listed for informational purposes as an "ATTACHMENT." Please note the requirements for the annual compliance certification are contained in General Condition P in Section 3. The current owner is responsible for submitting a compliance certification for the entire year regardless of who owned the facility during the year. As the designated responsible official it is your responsibility to review, understand, and abide by all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who operates any emission source and associated air pollution control device subject to any term or condition of the attached permit reviews, understands, and abides by the conditions of the attached permit that are applicable to that particular emission source. If any parts, requirements, or limitations contained in this Air Quality 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. State of North Carolina I Environmental Quality I Air Quality 1641 Mail Service Center 1217 W.Jones Street,Suite 4000 I Raleigh,NC 27609-1641 919 707 8400 T Mr. Kopp May 20, 2016 Page 2 This hearing request must be in the form of a written petition, conforming to NCGS (North Carolina General Statutes) 150B-23, and filed with both the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh,North Carolina 27699-6714 and the Division of Air Quality,Permitting Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing.Unless a request for a hearing is made pursuant to NCGS 150B-23, this Air Quality Permit shall be final and binding 30 days after issuance. You may request modification of your Air Quality Permit through informal means pursuant to NCGS 150B-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 this Air Quality Permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under NCGS 150B-23. The construction of new air pollution emission source(s) and associated air pollution control device(s), or modifications to the emission source(s) and air pollution control device(s) described in this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to construction unless the Permittee has fulfilled the requirements of NCGS 143-215-108A(b) and received written approval from the Director of the Division of Air Quality to commence construction. Failure to receive an Air Quality Permit or written approval prior to commencing construction is a violation of NCGS 143-215.108A and may subject the Permittee to civil or criminal penalties as described in NCGS 143-215.114A and 143-215.114B. Chatham County's minor source baseline for NOx,PMIo,and S02 has been triggered;there are no emissions increases or decreases associated with this modification. This Air Quality Permit shall be effective from May XX, 2016 until December 31, 2019, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. Should you have any questions concerning this matter,please contact Richard R. Simpson, at (919) 707-8476 or Richard.Simpsonnncdenr.gov. Sincerely yours, 6A6 • h)A4 William D. Wlllets,P.E., Chief, Permitting Section Division of Air Quality,NCDEQ Enclosure cc: Heather Ceron - EPA Region IV Patrick Butler, Supervisor, Raleigh Regional Office Central Files Connie Horne (cover letter only) ATTACHMENT I to cover letter of Permit No. 03424T25 Moncure Plywood Insignificant Activities under 15A NCAC 02Q .0503(8) Emission Source ID Emission Source Description I-1 Bark hogging operations with two saws I-2 Tree Core chipping and handling I-3 Green veneer hogging I-4 and I-5 Logo painting and ink marking I-6 Plywood surface patching 1-7 Maintenance parts washers I-8 Veneer diverter exhaust cyclone I-9 and I-10 two green wood veneer stackers No.I and No. 2 I-11 hammer hog truck dump I-12 dry waste truck dump IES-GWS Green wood fuel storage silo IES-19 Diesel-fired water pump (250 Horsepower maximum power output)for Area Source MACT ZZZZ emergency purposes only `IES-23 Diesel-fired fire pump emergency engine (250 Horsepower maximum Area Source MACT ZZZZ power output)for emergency purposes only NSPS Subpart IIII 1. Because an activity is insignificant 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 02D .1100 "Control of Toxic Air Pollutants"or 02Q.0711 "Emission Rates Requiring a Permit". 3. For additional information regarding the applicability of MACT or GACT see the DAQ page titled "Specific Permit Conditions Regulatory Guide." The link to this site is as follows: http://deq.nc.aov/about/divisions/air-quality/air- quality_permits/specific-permit-conditions-re ug latory-guide. ATTACHMENT 2 to cover letter of Permit No. 03424T25 Moncure Plywood The following table lists all modifications associated with this ermit action: Page(s) Section Description of Change(s) Cover and Throughout Updated all tables, dates, and permit revision numbers. throughout Throughout Throughout Corrected the regulatory reference from 02D and 02Q to 02D and 02Q. 2 Section 1 Deleted language no longer associated with the current permit shell. 3-4 Section 1 Updated page numbers. 8-9 Section 2.1.A.5.c. Updated the Indicator No. 1 requirements in the CAM table. This permit was"reopened for cause"to list the differential pressure drop range of multicyclone CD02. The QIP threshold and monitoring frequency was also updated. 9 Section 2.1.A.5.d. The CAM recordkeeping and reporting requirements were updated to the and e. most current version. 9 Section 2.1.A.5.f. Since range of differential pressure drop was established,the permit condition no longer a lies and was deleted. 13-14 Section 2.1.B.3.d. The CAM recordkeeping and reporting requirements were updated to the and e. most current version 17 Section 2.2.A.1.b. This permit is for a reopened for cause. The DAQ updated the methanol emission factor(0.00011 lb/SF)based on most resent 12/10/2014 emission testing. 18 Section This permit is for a reopened for cause. The DAQ revised the language 2.2.A.l.c.i.B. from"...12-month rolling average."to"...12-month rolling total." 22 General Updated to latest version of DAQ shell version 4.0 12/17/15. Conditions State of North Carolina Department of Environmental Quality Division of Air Quality AIR QUALITY PERMIT Permit No. Replaces Permit No.(s) Effective Date Expiration Date 03424T25 03424T24 May 20, 2016 December 31, 2019 This permit shall expire on the earlier of December 31,2019 or the renewal of permit 03424T25 has been issued or denied. Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct and operate the emission source(s)and associated air pollution control device(s)specified herein, in accordance with the terms,conditions, and limitations within this permit. This permit is issued under the provisions of Article 21 B of Chapter 143,General Statutes of North Carolina as amended,and Title 15A North Carolina Administrative Codes(15A NCAC),Subchapters 02D and 02Q,and other applicable Laws. Pursuant to Title 15A NCAC, Subchapter 02Q,the Permittee shall not construct, operate, or modify any emission source(s)or air pollution control device(s) without having first submitted a complete Air Quality Permit Application to the permitting authority and received an Air Quality Permit,except as provided in this permit. Permittee: Moncure Plywood Facility ID: 05/19/00039 Facility Site Location: 306 Corinth Road City, County, State, Zip: Moncure, Chatham County,North Carolina 27559 Mailing Address: Post Office Box 230 City, State, Zip: Moncure,North Carolina 27559 Application Number: 1900039.16A Complete Application Date: February 2,2016 Primary SIC Code: 2436 Division of Air Quality, Raleigh Regional Office Regional Office Address: 3800 Barrett Drive Raleigh,North Carolina 27609 Permit issued this the 201 day of May,2016 William D.Willets, P.E.,Chief, Permitting Section By Authority of the Environmental Management Commission Table of Contents SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS 2.1 - Emission Source(s) Specific Limitations and Conditions (Including specific requirements,testing, monitoring, recordkeeping, and reporting requirements) 2.2 - Multiple Emission Source(s) Specific Limitations and Conditions (Including specific requirements,testing, monitoring, recordkeeping, and reporting requirements) SECTION 3: GENERAL PERMIT CONDITIONS ATTACHMENTS ATTACHMENT I...... List of Acronyms Permit No. 03424T25 Page 3 SECTION I- PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR POLLUTION CONTROL DEVICE(S) AND APPURTENANCES The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances: Emission Control Page(s) Source ID No. Emission Source Description Device Control Device Description ID No. 4 ESO1-A Fluidized bed wood burner with blending CD02 Multicyclone(720 six-inch chamber and dedicated overfire air fan(80.0 diameter tubes) million Btu/hr heat input capacity)' 4 ES01-B Boiler(29.79 million Btu/hr heat input capacity, (NSPS) based on slipstream gas from ID No.ES-01-A) 4 ES09 Direct wood-fired veneer dryer M72' NA NA 4 ES 10 Direct wood-fired veneer dryer M72' NA NA 4 ES20 Vat operations NA NA Woodworking and Layup operations consisting of. 10 ES03-SMS-1,2 Two string machines including saws CD-03- Woodwaste transfer cyclone WWTC, (154 inches in diameter) 10 ES03-CS Core saw(green or dry veneer) CD06 Bagfilter(7,095 square feet of 10 ES03-SS Strip saw filter area) 10 ES03-CC Core composer with saw 10 ES03-PSS Panel sawing system 10 ES 16 Plywood waste hog 10 ES 17 Green wood sizing operations including sizing screens and bins 10 ES22 Tongue and groove saw(plywood finishing) 10 ES14 Rechip blow hog(green wood only) CD18 Cyclone(60 inches in diameter) CD-03- Woodwaste transfer cyclone WWTC, (154 inches in diameter) CD06 Bagfilter(7,095 square feet of filter area) 10 ES04 Wood sander CD05 Bagfilter(6,200 square feet of filter area) CD-03- Woodwaste transfer cyclone WWTC, (154 inches in diameter) CD06 Bagfilter(7,095 square feet of filter area) Permit No. 03424T25 Page 4 Emission Control Page(s) Source ID No. Emission Source Description Device Control Device Description ID No. 10 ES12 Dry wood residual storage silo CD21 Cartridge filter(1,800 square feet of filter area) 10 Glue mixing operations consisting of two resin NA NA ES-13-GMO storage tanks and four mixed glue tanks 10 ES-13-CC Curtain coater NA NA 10 ES-13-PO Paper overlay operation NA NA 10 ES-13-PS Plywood spreader NA NA 10 ES-13-25HP 25 panel hot press NA NA 10 ES-13-40HP 40 panel hot press NA NA 14 ES21 Edge sealer spray booth NA NA ' The wood burner(ID No.ES-01-A)supplies direct heat to the veneer dryers(1D Nos.ES09 and ES 10). Most of the dryer exhaust is ducted and routed as combustion air for the wood burner per 502(b)(10)request dated August 8,2014. SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS 2.1- Emission Source(s) and Control Devices(s) Specific Limitations and Conditions The emission source(s)and associated air pollution control device(s) and appurtenances listed below are subject to the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting requirements as specified herein: A. One fluidized bed wood burner with blending chamber and dedicated overfire air fan(80.0 million Btu/hr heat input capacity) (ID No.ES01-A)supplying heat to: One wood boiler(29.79 million Btu/hr heat input capacity, based on slipstream gas from fluidized bed wood burner) (ID No. ES-01-B): Both controlled by a multicyclone (720 six-inch diameter tubes) (ID No. CD02), with the recombined gas stream supplying direct heat to: Two direct wood-fired veneer dryers,M72 (ID no.ES09)and M72 (ID no.ES10) Vat operations (ID No. ES20) The following table provides a summary of limits and standards for the emission sources described above with exceptions noted): Regulated Limits/Standards Applicable Regulation Pollutant Particulate matter E=4.10P 067 or E= 55.0(P)0-1 -40 15A NCAC 02D .0515 where; E=allowable emission rate in pounds per hour P=process weight in tons per hour Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D .0516 Affected facilities: Fluidized bed wood burner(ID Nos. ES01-A) Permit No. 03424T25 Page 5 Regulated Limits/Standards Applicable Regulation Pollutant Visible emissions 20 percent opacity 15A NCAC 02D .0521 Applicable Affected facility: 15A NCAC 02D .0524 Recordkeeping Boiler(ID No.ESOI-B) (NSPS, Subpart Dc) Particulate matter Compliance Assurance Monitoring 15A NCAC 02D. 0614 (40 CFR 64) HAPs less than 10 tons per year of any individual HAP and 15A NCAC 02Q .0317 for less than 25 tons per year of a combination of HAPs avoidance of 15A NCAC See Section 2.2 A. 02D .1111 Toxic air pollutants State-enforceable only 15A NCAC 02D .1100 See Section 2.2 A.3. - Multiple Emission Sources Toxic air pollutants State-enforceable only 15A NCAC 02Q .0711 See Section 2.2.A.4. -Multiple Emission Sources Odorous emissions State-enforceable only 15A NCAC 02D .1806 See Section 2.2.A.5. - Multiple Emission Sources 1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated by the following equations: E=4.10 x P 0,67 where P is less than or equal than 30 tons per hour or E=55.O(P)0-1 —40 where P is greater than 30 tons per hour Where E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. Testing [15A NCAC 02Q .0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 A. 1.a. above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515. C. Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission limit(s)above by testing the combined emissions of the above sources in accordance with a testing protocol approved by the DAQ. Testing must be performed in this Title V renewal cycle. Details of the emissions testing and reporting requirements can be found in Section 3 -General Condition JJ. Testing shall be completed and the results submitted within 180 days of issuance of permit unless an alternate date is approved by the DAQ. If the results of this test are above the limit given in Section 2.1 A. 1. a. above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515. Permit No. 03424T25 Page 6 Monitorin&aecordkeeuing [15A NCAC 02Q .0508(f)] d. Particulate matter emissions from these sources shall be controlled as described above. To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and ii. an annual (for each 12 month period following the initial inspection) internal inspection of the control device structural integrity. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and control devices are not inspected and maintained. e. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on the control devices;and iv. any variance from manufacturer's recommendations, if any, and corrections made. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not maintained. Renortin [15A NCAC 02Q .0508(f)] f. The Permittee shall submit the results of any maintenance performed on the control devices within 30 days of a written request by the DAQ. g. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from the fluidized bed wood burner(ID No. ESO1-A) shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores,and other substances shall be included when determining compliance with this standard. Testing [15A NCAC 02Q .0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ found in Section 3. If the results of this test are above the limit given in Section 2.1 A.2. a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0516. Monitorina/Recordkeepin [15A NCAC 02Q .0508(f)] C. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the combustion of wood for these sources. 3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the above sources shall not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six- minute average exceed 87 percent opacity. [15A NCAC 02D .0521(d)] Permit No. 03424T25 Page 7 Testin [15A NCAC 02Q .0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 A.3.a. above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521. Monitoring [15A NCAC 02Q .0508(f)] C. To assure compliance, once a day the Permittee shall observe the emission points of this source for any visible emissions above normal. The daily observation must be made for each day of the calendar year period to ensure compliance with this requirement. The Permittee shall be allowed three days of absent observations per semi-annual period. If visible emissions from this source are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below, or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 A.3.a. above. If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521. Recordkeeving [15A NCAC 02Q .0508(f)] d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions; and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not kept. Reporting [15ANCAC 02Q .0508(f)] e. The Permittee shall submit a summary report of the observations on or before January 30 of each calendar year for the preceding six-month period between July and December and on or before July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 4. 15A NCAC 02D .0524: NSPS 40 CFR PART 60 SUBPART Dc a. For source JD No.ES01-B),the Permittee shall comply with all applicable provisions, including the notification,testing, recordkeeping, reporting, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 02D .0524 "New Source Performance Standards"(NSPS) as promulgated in 40 CFR Part 60 Subpart Dc, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units", including Subpart A "General Provisions."[15A NCAC 02D .0524] Permit No. 03424T25 Page 8 Recordkeeping![15A NCAC 02Q .0508(f)] b. In addition to any other recordkeeping required by 40 CFR 60.48c or recordkeeping requirements of the EPA,the Permittee shall record and maintain records of the amounts of wood fuel fired in the source (ID Nos.ESO1-B) during each month. All records shall be maintained by the Permittee for a period of two years following the date of such record. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524 if these records are not maintained. 5. 15A NCAC 02D.0614 COMPLIANCE ASSURANCE MONITORING a. Pursuant to 40 CFR 64 and 15A NCAC 02D .0614, the Permittee shall comply with the conditions below for the following Pollutant Specific Emission Unit(s): Emission Control Source Emission Source Description Device ID No. Control Device Description ID No. ESO1-A Fluidized bed wood burner with blending CD02 Multicyclone(720 six-inch chamber and dedicated overfire air fan diameter tubes) (80.0 million Btu/hr heat input capacity) Emission Limitations/Standards b. The following table presents the regulated pollutants and the associated emission limitations/standards Regulated Applicable Regulation Pollutant Limits/Standards E=4.1 OP 1.67 or E= 55.0(P)°11 -40 Particulate Where: 15A NCAC 02D .0515 matter E=allowable emission rate in pounds per hour P=process weight in tons per hour MonitorinLy Approach [15A NCAC 02Q .0508(f),40 CFR 64.61 C. The key elements of the monitoring approach for particulate matter and visible emissions, including parameters to be monitored,parameter ranges and performance criteria are presented in the following table. Monitoring Elements Indicator No. 1 Measurement Approach When the emission source is in operation,the differential pressure [64.6(c)(1)(i),(ii)] across the multicyclone will be monitored via a differential pressure gauge- Indicator Range If the differential pressure drop across the multicyclone is outside the [64.6(c)(2)] ranges of 4 and 13 inches of water,then an excursion has occurred. Excursions trigger an inspection and corrective action. QIP threshold The QIP threshold is ten excursions in a six-month reporting period. [64.8] Data Representativeness The differential pressure is measured via taps on the multicyclone entry [64.6(c)(1)(iii), 64.3(b)(01 and exit ducts. Permit No. 03424T25 Page 9 Monitoring Elements Indicator No.1 Verification of Operational Monitoring shall be required upon issuance of permit No. 03424T25. Status 64.3(b)(2)] QA/QC Practices and Criteria The differential gauge/system will be operated and maintained per [64.3(b)(3)] manufacturer's recommendations. Monitoring frequency When the emission source is in operation,the pressure drop is [64.3(b)(4)] monitored continuously and the value recorded daily for the associated control device. Data collection procedure The results of the monitoring action will be recorded, including the date 64.3(b)(4) and time. RecordkeeginE Requirements [15A NCAC 02Q .0508(f),40 CFR 64.9] d. The owner or operator shall maintain records of the following: i. Date and time of all monitoring activities; ii. The results of the differential pressure drop monitoring, noting any excursions along with corrective actions taken; The results of any inspections or maintenance performed on the associated control devices/multicyc lone; iv. Any variance from manufacturer's recommendations, if any, and corrections made. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0614 if this monitoring and recordkeeping is not conducted. Reportine Requirements [15A NCAC 02Q .0508(f),40 CFR 64.9] e. The Permittee shall submit a summary report of all monitoring postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations for the requirements of this permit must be clearly identified. The first report is due by July 30, 2016 covering the period from the issuance date of this permit to the end of the semiannual period. At a minimum,the report shall include the following elements: i. Summary information on the number,duration and cause(including unknown cause,if applicable)of excursions or exceedances,as applicable,and the corrective actions taken; ii. Summary information on the number,duration and cause(including unknown cause, if applicable)for monitor(pressure gauge)downtime incidents(other than downtime associated with zero and span or other daily calibration checks, if applicable); and iii. A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR 64.8. Upon completion of a QIP,the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring. Permit No. 03424T25 Page 10 B. Woodworking and Layup operations consisting of the equipment in Table 2.1.B.1 Table 2.1.B.1. Emission Emission Source Control Device Control Device Description Source ID No. Description ID No. ES03-SMS-1, 2 Two string machines CD-03-WWTC Woodwaste transfer cyclone(154 inches in including saws diameter) ES03-CS Core saw(green or dry CD06 Bagfilter(7,095 square feet of filter area) veneer) ES03-SS Strip saw ES03-CC Core composer with saw ES03-PSS Panel sawing system ES16 Plywood waste hog ES 17 Green wood sizing operations including sizing screens and bins ES22 Tongue and groove saw (plywood finishing) ES14 Rechip blow hog(green CD18 Cyclone (60 inches in diameter) wood only) CD-03-WWTC Woodwaste transfer cyclone(154 inches in diameter) CD06 Bagfilter(7,095 square feet of filter area) ESO4 Wood sander CD05 Bagfilter(6,200 square feet of filter area) CD-03-WWTC Woodwaste transfer cyclone(154 inches in diameter) CD06 Bagfilter(7,095 square feet of filter area) ES12 Dry wood residual CD21 Cartridge filter(1,800 square feet of filter area) storage silo Glue mixing operations NA NA ES-13-GMO consisting of two resin storage tanks and four mixed glue tanks ES-13-CC Curtain coater NA NA ES-13-PO Paper overlay operation NA NA ES-13-PS Plywood spreader NA NA ES-13-25HP 25 panel hot press NA NA ES-13-40HP 40 panel hot press NA NA Permit No. 03424T25 Page 11 The followin table provides a summary of limits and standards for the emission sources described above: Regulated Limits/Standards Applicable Regulation Pollutant Particulate matter adequate duct work and properly designed collectors 15A NCAC 02D .0512 Visible emissions 20 percent opacity 15A NCAC 02D .0521 Particulate Compliance Assurance Monitoring 15A NCAC 02D. 0614 Matter,Visible (40 CFR 64) Emissions HAPs less than 10 tons per year of any individual HAP and 15A NCAC 02Q .0317 less than 25 tons per year of a combination of HAPs for avoidance of 15A See Section 2.2 A. NCAC 02D .1 I I I Volatile organic For wood working operations except ID No.ES22 15A NCAC 02D .0958 compounds Work Practices See Section 2.2.A.2.-Multiple Emission Sources Toxic air State-enforceable only 15A NCAC 02D .1100 pollutants See Section 2.2 A.3.-Multiple Emission Sources Toxic air State-enforceable only 15A NCAC 02Q .0711 pollutants See Section 2.2.A.4. - Multiple Emission Sources Odorous State-enforceable only 15A NCAC 02D .1806 emissions See Section 2.2.A.5. -Multiple Emission Sources 1. 15A NCAC 02D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING PLANTS a. The Permittee shall not cause, allow,or permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack, vent, or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and properly designed collectors. In no case shall the ambient air quality standards be exceeded beyond the property line. Monitoring [15A NCAC 02Q .0508(f)] b. Particulate matter emissions from the affected sources shall be controlled as described in Table 2.1.13.1. To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer, if any. As a minimum, the inspection and maintenance program shall include: i. monthly external inspection of the ductwork, cyclones, and/or bagfilters noting the structural integrity; and ii. annual (for each 12 month period following the initial inspection) internal inspection of the bagfilters noting the structural integrity and the condition of the filters. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if the ductwork, cyclones and/or bagfilters and are not inspected and maintained. Recordkeeping [15A NCAC 02Q .0508(f)] C. The results of inspection and maintenance for the cyclones and bagfilters shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; and iii. the results of maintenance performed on any control device. Permit No. 03424T25 Page 12 The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if these records are not maintained. Reporting [15A NCAC 02Q .0508 (f)] d. The Permittee shall submit the results of any maintenance performed on the control devices within 30 days of a written request by the DAQ. e. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the emission sources listed in Table 2.1.B.1 shall not be more than 20 percent opacity when averaged over a six-minute period. However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [I 5A NCAC 02D .0521 (d)] Testing [15A NCAC 02Q .0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 13.2.a.above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521. Monitoring [15A NCAC 02Q .0508(f)] C. To assure compliance, once a week the Permittee shall observe the emission points of this source for any visible emissions above normal. The weekly observation must be made for each week of the calendar year period to ensure compliance with this requirement.If visible emissions from this source are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 02D .0501(c)(8) (Method 9) for 12 minutes is below the limit given in Section 2.1.B.2.a. above. If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521. Recordkeeping [15A NCAC 02Q .0508(f)] d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not maintained. Reporting [15A NCAC 02Q .0508(f)] e. The Permittee shall submit a summary report of the observations on or before January 30 of each calendar year for the preceding six-month period between July and December and on or before July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. Permit No. 03424T25 Page 13 3. 15A NCAC 02D .0614 COMPLIANCE ASSURANCE MONITORING a. Pursuant to 40 CFR 64 and 15A NCAC 02D .0614, the Permittee shall comply with the conditions below for the Pollutant Specific Emission Units listed in Table 2.1.B.1. Emission Limitations/Standards [15A NCAC 02Q .0508(f)] b. The following table presents the regulated pollutants and the associated emission limitations/standards Regulated Applicable Regulation Pollutant Limits/Standards Particulate matter Adequate ductwork and properly designed 15A NCAC 02D .0512 collectors Monitoring Approach [I 5A NCAC 02Q .0508(f), 40 CFR 64.6] C. The key elements of the monitoring approach for particulate matter, and PM,o, including parameters to be monitored,parameter ranges and performance criteria are presented in the following table. Monitoring Indicator Elements Measurement Visible emissions from each bagfilter outlet will be monitored daily using Approach reference Method 22-like procedures. 64.6(c)(1)(i),(ii Indicator Range An excursion is defined as the presence of visible emissions. Excursions 64.6(c)(2) trigger an inspection and corrective action. QIP(Quality The QIP threshold is six excursions in a six-month reporting period. Improvement Plan) threshold 64.8 Data Measurements are being made at the emission points(bagfilter outlet). Representativeness [64.6(c)(1)(iii), 64.3(b)(1)] Verification of Monitoring shall be required upon issuance of permit No. 03424T21. Operational Status [64.3(b)(2) QA/QC Practices and The observer will be familiar with Method 22 and the follow Method 22- Criteria like procedures. 64.3(b)(3) Monitoring frequency One six-minute Method 22-like observation per bagfilter outlet shall be 64.3 b (4) performed daily. Data collection The results of the monitoring action will be recorded, including the date and procedure time. 64.3(b)(4) Recordkeeping Requirements [15A NCAC 02Q .0508(f), 40 CFR 64.9] d. The owner or operator shall maintain records of the following: i. Date and time of all monitoring activities; H. The results of Method 22-like observations, noting any excursions along with corrective actions taken; Permit No. 03424T25 Page 14 iii. The results of any inspections or maintenance performed on the associated control devices/bagfilters; iv. Any variance from manufacturer's recommendations, if any, and corrections made. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0614 if this monitoring and recordkeeping is not conducted. Reportine Requirements [15A NCAC 02Q .0508(f), 40 CFR 64.9] e. The Permittee shall submit a summary report of all monitoring postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations for the requirements of this permit must be clearly identified. At a minimum,the report shall include the following elements: i. Summary information on the number,duration and cause(including unknown cause, if applicable)of excursions or exceedances,as applicable,and the corrective actions taken; ii. Summary information on the number, duration and cause(including unknown cause, if applicable)for monitor(pressure gauge)downtime incidents(other than downtime associated with zero and span or other daily calibration checks, if applicable);and iii. A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR 64.8.Upon completion of a QIP,the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring. C. Edge Sealer Spray Booth(ID No.ES21) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate matter adequate duct work and properly designed 15A NCAC 02D .0512 collectors Visible emissions 20% opacity 15A NCAC 02D .0521 Volatile organic Work Practices 15A NCAC 02D .0958 compounds See Section 2.2.A.2.-Multiple Emission Sources Odorous emissions State-enforceable only 15A NCAC 02D .1806 See Section 2.2.A.5.-Multiple Emission Sources HAPs less than 10 tons per year of any individual HAP 15A NCAC 02Q .0317 for and avoidance of 15A NCAC less than 25 tons per year of a combination of 02D .l 111 HAPs See Section 2.2 A. 1. 15A NCAC 02D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING PLANTS a. The Permittee shall not cause, allow, or permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack, vent, or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and properly designed collectors. In no case shall the ambient air quality standards be exceeded beyond the property line. Permit No. 03424T25 Page 15 Monitoring [15A NCAC 02Q .0508(f)] b. Particulate matter emissions from this emission source shall be controlled by adequate ductwork and properly designed collectors. To assure compliance, the Permittee shall perform inspections and maintenance. As a minimum,the inspection and maintenance program shall include: i. weekly inspection of the spray booths' filters noting the condition; and ii. annual (for each 12 month period following the initial inspection) inspection of the associated ductwork noting structural integrity. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if the filters are not inspected and maintained. Recordkeeping [I 5A NCAC 02Q .0508(f)] C. The results of inspection and maintenance for the spray booths shall be maintained in a logbook (written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; and iii. the results of maintenance performed on any filters. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if these records are not maintained. Reporting [15A NCAC 02Q .0508(Q d. The Permittee shall submit the results of any maintenance performed on the filters or ductwork within 30 days of a written request by the DAQ. e. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from this emission source shall not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six- minute average exceed 87 percent opacity. [15A NCAC 02D .0521 (d)] Testing [15A NCAC 02Q .0508(f)] b. If emissions testing is required,the testing shall be performed in accordance General Condition JJ. If the results of this test are above the limit given in Section 2.1 C. 2. a. above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521. Monitoring [15A NCAC 02Q .0508(f)] C. To assure compliance, once a month the Permittee shall observe the emission points of this source for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. If visible emissions from this source are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 C.2. a. above. Permit No. 03424T25 Page 16 If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521. Recordkeeping [15A NCAC 02Q .0508(f)] d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions; and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not maintained. Reporting [15A NCAC 02Q .0508(f)] e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 2.2- Multiple Emission Source(s) Specific Limitations and Conditions A. Facility-wide: The following table provides a summary of limits and standards for the emission source(s)describe above: Regulated Pollutant Limits/Standards Applicable Regulation HAPs less than 10 tons per year of any individual HAP and 15A NCAC 02Q .0317 for less than 25 tons per year of a combination of HAPs avoidance of 15A NCAC 02D .IIII Volatile organic Work practice standards 15A NCAC 02D .0958 compounds Toxic air pollutants State-enforceable only 15A NCAC 02D .I 100 Allowable emission rates Toxic air pollutants State-enforceable only 15A NCAC 02Q .0711 Toxic Pollutant Permitting Exemption Rates Odorous emissions State-enforceable only 15A NCAC 02D .1806 Odorous emissions must be controlled 1. 15A NCAC 02Q .0317 for avoidance of 15A NCAC 02D .1111 LIMITATION TO AVOID BEING MAJOR FOR HAZARDOUS AIR POLLUTANTS a. In order to remain classified a minor source for hazardous air pollutants the facility wide emissions shall be less than: i. 10 tons per year of each individual hazardous air pollutant, and ii. 25 tons per year of all hazardous air pollutants combined. The Permittee shall be deemed in noncompliance with this condition if the HAP emissions exceed this limit. Permit No. 03424T25 Page 17 Monitoring/Recordkeeping [I 5A NCAC 02Q .0508(f)] b. The Permittee shall maintain monthly HAPs emissions records as follows: The Permittee shall calculate the methanol emissions, using the equations below, on a monthly basis,to ensure compliance with condition 2.2 A. 1. a.,above. Facility Wide methanol emissions(tons/month)= [Eq. 1 +Eq. 2 +Eq. 3] Monthly methanol emissions will be calculated for the dryers/boiler(ESO1-A, ESO1-13, ES-09, and ES-10),the presses(ES-13), and vat operations(ES-20). Equation 1: Methanol emissions from the dryers/boiler(ESO1-A, ESO 1-13, ES-09, and ES-10) — �(0.0000095 lb of ethanol HW SF l+(0.0000361b of methanol)*(SW SF Eq 1: Methanol(tons/month) SF Hardwood 1l J month) SF Softwood J month)J (z,000 Ibs\ ton J Where HW SF=Hardwood production in SF(Square Feet)per month determined on a 3/8 inch basis Emission Factor of Methanol=(0.0000095 lb of methanol/SF Hardwood(square feet of Hardwood) SW SF= Softwood production in SF (Square Feet)per month determined on a 3/8 inch basis Emission Factor of Methanol =(0.000036 lb of methanol/SF Softwood(square feet of Softwood) Equation 2: Methanol emissions from presses(ES-13) — r(O.00o11 !b of methanol\*(HW SF)+(0.00011 lb of methanol)-(SW SF\l Eq2: Methanol (tons/month) IIIL SF Hardwood J month) SF Softwood J month)) (2,000 Ibs\ ton J Where HW SF=Hardwood production in SF (Square Feet)per month determined on a 3/8 inch basis Emission Factor of Methanol=(0.00011 lb of methanol/SF Hardwood(square feet of Hardwood) based on 12/10/2014 emission testing. SW SF=Softwood production in SF(Square Feet)per month determined on a 3/8 inch basis Emission Factor of Methanol=(0.00011 lb of methanol/SF Softwood(square feet of Softwood)based on 12/10/2014 emission testing. Equation 3: Methanol emissions from vat operations(ES-20) — r(0.0000073 lb of me thanol)*(Total SF)� Eq3: Methanol (tons/month) L SF month (z,000 Ibs) ton Where Total SF=Total production in SF(Square Feet)per month determined on a 3/8 inch basis Emission Factor of Methanol=0.0000073 lb of methanol/SF(square feet) The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if these methanol emissions are not monitored and recorded. Reporting Requirements [15A NCAC 02Q .0508(f)] c. Submit to the Regional Supervisor, Division of Air Quality, semiannually, a report summarizing emissions of hazardous air pollutants containing the following: i. Tons of methanol emitted during the previous calendar year, Permit No. 03424T25 Page 18 A. for each month during the semiannual period,and B. for each 12-month period ending on each month during the semiannual period using a 12-month rolling total. The Permittee shall submit this report postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if these methanol emissions are not reported. 2. 15A NCAC 02D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC COMPOUNDS a. Pursuant to 15A NCAC 02D .0958, for all sources that use volatile organic compounds (VOC) as solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that mix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a product of chemical reactions;the Permittee shall: i. store all material, including waste material, containing volatile organic compounds in tanks or in containers covered with a tightly fitting lid that is free of cracks,holes,or other defects,when not in use, ii. clean up spills of volatile organic compounds as soon as possible following proper safety procedures, iii. store wipe rags containing volatile organic compounds in closed containers, iv. not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile organic compounds, V. transfer solvents containing volatile organic compounds used to clean supply lines and other coating equipment into closable containers and close such containers immediately after each use, or transfer such solvents to closed tanks, or to a treatment facility regulated under section 402 of the Clean Water Act, vi. clean mixing, blending, and manufacturing vats and containers containing volatile organic compounds by adding cleaning solvent and close the vat or container before agitating the cleaning solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank or a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 02D .0958(c)] b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall: i. flush parts in the freeboard area, ii. take precautions to reduce the pooling of solvent on and in the parts, iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all dripping has stopped, whichever is longer, iv. not fill cleaning machines above the fill line, v. not agitate solvent to the point of causing splashing. [15A NCAC 02D .0958(d)] Monitoring [15A NCAC 02Q .0508(f)] C. To assure compliance with paragraphs(a) and(b) above,the Permittee shall, at a minimum, perform a visual inspection once per month of all operations and processes utilizing volatile organic compounds.The inspections shall be conducted during normal operations.If the required inspections are not conducted the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0958. Permit No. 03424T25 Page 19 Recordkeepine [15A NCAC 02Q .0508(f)] d. The results of the inspections shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each inspection; and ii. the results of each inspection noting whether or not noncompliant conditions were observed. If the required records are not maintained the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0958. Reporting [15ANCAC 02Q .0508(f)] e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. STATE-ENFORCEABLE ONLY 3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS a. Pursuant to 15A NCAC 02D .1100 and in accordance with the approved application for an air toxic compliance demonstration,the following permit limits shall not be exceeded: Emission Pollutants Emission Limits Averaging Source Period Acrolein 2.4 lb/hr Arsenic 1.48 lb/year Benzene 772.92 lb/year Beryllium 26.41 lb/year Cadmium 35.2 lb/year Veneer Dryer Chlorine 101.13 lb/day (ID No. ES09) 27.02 lb/hr Formaldehyde 3.77 lb/hr Hydrogen Chloride 21.02 lb/hr Manganese 83.6 lb/day Nickel (metal) 16.19 lb/day Phenol 6.74 lb/hr Vinyl Chloride 38,656 lb/year Acrolein 2.4 lb/hr Arsenic 1.48 lb/year Benzene 772.92 lb/year Beryllium 26.41 lb/year Cadmium 35.2 lb/year Veneer Dryer Chlorine 101.13 lb/day (ID No. ES10) 27.02 lb/hr Formaldehyde 3.77 lb/hr Hydrogen Chloride 21.02 lb/hr Manganese 83.6 lb/day Nickel (metal) 16.19 lb/day Phenol 6.74 lb/hr Vinyl Chloride 38,656 lb/year Permit No. 03424T25 Page 20 Emission Pollutants Emission Limits Averaging Source Period Layup Formaldehyde 2.33 lb/hr operations phenol 28.62 lb/hr (ID No. ES13) Monitoring/Recordkeeping/ReportinQ b. Given the large margin of compliance as evidenced in the facility-wide modeling demonstration submitted on March 18, 2009, no monitoring,recordkeeping or reporting is required. STATE-ENFORCEABLE ONLY 4. 15A NCAC 02Q.0711: EMISSION RATES REQUIRING A PERMIT a. Pursuant to 15A NCAC 02Q .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 do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 02Q .0711. 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 02Q .0711. L 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. ii. 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 02D.1100 "Control of Toxic Air Pollutants". iii. 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: Pollutant Carcinogens Chronic Toxicants Acute Systemic Acute Irritants (lb/yr) (lb/day) Toxicants(lb/hr) (lb/hr) Acetaldehyde 6.8 enzo(a)pyrene (Component of 2.2 83329/POMTV & 56553/7PAH) CFC-11 140 (Trichlorofluoromethane) Carbon tetrachloride 460 Chlorobenzene 46 Chloroform 290 Chromium(VI) Soluble Chromate Compounds 0.013 (Component of CRC) EBP(Di(2- ethylhexyl)phthalate) 0.63 Ethylene dichloride(1,2- 260 ichloroethane) exachlorodibenzo-p- 0.0051 Toxin 1,2,3,6,7,8 EK(methyl ethyl 78 22.4 etone,2-butanone) Permit No. 03424T25 Page 21 Pollutant Carcinogens Chronic Toxicants Acute Systemic Acute Irritants (lb/yr) (lb/day) Toxicants(lb/hr) (lb/hr) IBK(methyl isobutyl 52 7.6 ketone) Mercury, vapor Component of HGC) 0.013 Methyl chloroform 250 64 Methylene chloride 1600 0.39 CB(polychlorinated 5.6 iphenyls) entachlorophenol 0.063 0.0064 erchloroethylene 13 000 (tetrachloroethylene) Styrene 2.7 CE(trichloroethylene) 4000 Tetrachlorodibenzo-p- dioxin,2,3,7,8- 0.0002 Component of CLDC & 83329/POMTV) Toluene 98 14.4 ylene (mixed isomers) 57 16.4 STATE-ENFORCEABLE ONLY 5. 02D .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. Permit No. 03424T25 Page 22 SECTION 3 - GENERAL CONDITIONS (version 4.012/17/15) This section describes terms and conditions applicable to this Title V facility. A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)] 1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 02D and 02Q. 2. The terms, conditions,requirements, limitations, and restrictions set forth in this permit are binding and enforceable pursuant to NCGS 143-215.114A and 143-215.114B,including assessment of civil and/or criminal penalties.Any unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement action by the DAQ. 3. This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the facility which are not addressed in this permit. 4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal or plant life,or property caused by the construction or operation of this permitted facility,or from penalties therefore,nor does it allow the Permittee to cause pollution in contravention of state laws or rules, unless specifically authorized by an order from the North Carolina Environmental Management Commission. 5. Except as identified as state-only requirements in this permit,all terms and conditions contained herein shall be enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal Clean Air Act. 6. Any stationary source of air pollution shall not be operated,maintained,or modified without the appropriate and valid permits issued by the DAQ,unless the source is exempted by rule. The DAQ may issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements. A permitted installation may only be operated, maintained,constructed,expanded,or modified in a manner that is consistent with the terms of this permit. B. Permit Availability [15A NCAC 02Q .0507(k)and .0508(i)(9)(B)] The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit term one complete copy of the application and any information submitted in support of the application package. The permit and application shall be made available to an authorized representative of Department of Environmental Quality upon request. C. Severability Clause [15A NCAC 02Q .0508(i)(2)] In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those held to be invalid, shall remain valid and must be complied with. D. Submissions [15A NCAC 02Q .0507(e)and 02Q .0508(i)(16)] Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data, notifications,request for renewal,and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems(CEMS)reports,continuous opacity monitoring systems(COMS) reports,quality assurance(QA)/quality control(QC)reports,acid rain CEM certification reports,and NOx budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall be sent to: Supervisor, Stationary Source Compliance North Carolina Division of Air Quality 1641 Mail Service Center Raleigh,NC 27699-1641 All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit). Permit No. 03424T25 Page 23 E. Duty to Comply[15A NCAC 02Q .0508(i)(3)] The Permittee shall comply with all terms, conditions,requirements, limitations and restrictions set forth in this permit.Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a violation of the Federal Clean Air Act. 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. F. Circumvention- STATE ENFORCEABLE ONLY 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 pollution control device(s)and appurtenances. G. Permit Modifications l. Administrative Permit Amendments [15A NCAC 02Q.0514] The Permittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 02Q .0514. 2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q .0505] The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 02Q.0524 and 02Q .0505. 3. Minor Permit Modifications [I 5A NCAC 02Q .0515] The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 02Q.0515. 4. Significant Permit Modifications [15A NCAC 02Q.0516] The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 02Q .0516. 5. Reopening for Cause [15A NCAC 02Q .0517] The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q .0517. H. Chanues Not Requiring Permit Modifications 1. Reporting Requirements Any of the following that would result in new or increased emissions from the emission source(s)listed in Section 1 must be reported to the Regional Supervisor,DAQ: a. changes in the information submitted in the application; b. changes that modify equipment or processes; 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. 2. Section 502(b)(10)Changes [15A NCAC 02Q.0523(a)] a. "Section 502(b)(10)changes"means changes that contravene an express permit term or condition. Such changes do not include changes that would violate applicable requirements or contravene federally enforceable permit terms and conditions that are monitoring(including test methods), recordkeeping,reporting,or compliance certification requirements. b. The Permittee may make Section 502(b)(10)changes without having the permit revised if: i. the changes are not a modification under Title I of the Federal Clean Air Act; ii. the changes do not cause the allowable emissions under the permit to be exceeded; iii. the Permittee notifies the Director and EPA with written notification at least seven days before the change is made; and Permit No. 03424T25 Page 24 iv. the Permittee shall attach the notice to the relevant permit. c. The written notification shall include: i. a description of the change; ii. the date on which the change will occur; iii. any change in emissions;and iv. any permit term or condition that is no longer applicable as a result of the change. d. Section 502(b)(10)changes shall be made in the permit the next time that the permit is revised or renewed,whichever comes first. 3. Off Permit Changes [15A NCAC 02Q .0523(b)] The Permittee may make changes in the operation or emissions without revising the permit if: a. the change affects only insignificant activities and the activities remain insignificant after the change; or b. the change is not covered under any applicable requirement. 4. Emissions Trading[15A NCAC 02Q .0523(c)] To the extent that emissions trading is allowed under 15A NCAC 02D,including subsequently adopted maximum achievable control technology standards,emissions trading shall be allowed without permit revision pursuant to 15A NCAC 02Q .0523(c). I.A.Reporting Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D.0535(f)and 02Q.0508(f)(2)] "Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard allowed by any rule in Sections .0500, .0900, .1200, or.1400 of Subchapter 02D; or by a permit condition; or that exceeds an emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note:Definitions of excess emissions under 02D.1110 and 02D.1111 shall apply where defined by rule) "Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and conditions of this permit including those attributable to upset conditions as well as excess emissions as defined above lasting less than four hours. Excess Emissions 1. If a source is required to report excess emissions under NSPS(15A NCAC 02D.0524),NESHAPS(15A NCAC 02D .1110 or.1111), or the operating permit provides for periodic(e.g.,quarterly)reporting of excess emissions,reporting shall be performed as prescribed therein. 2. If the source is not subject to NSPS (15A NCAC 02D .0524),NESHAPS(15A NCAC 02D .I 110 or .1111),or these rules do NOT define "excess emissions,"the Permittee shall report excess emissions in accordance with 15A NCAC 02D.0535 as follows: a. Pursuant to 15A NCAC 02D .0535, if excess emissions last for more than four hours resulting from a malfunction,a breakdown of process or control equipment,or any other abnormal condition,the owner or operator shall: i. notify the Regional Supervisor or Director 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 provide: • name and location of the facility; • nature and cause of the malfunction or breakdown; • time when the malfunction or breakdown is first observed; • expected duration;and • estimated rate of emissions; ii. notify the Regional Supervisor or Director immediately when corrective measures have been accomplished; and iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC 02D.0535(f)(3). Permit No. 03424T25 Page 25 Permit Deviations 3. Pursuant to 15A NCAC 02Q .0508(f)(2),the Permittee shall report deviations from permit requirements (terms and conditions)as follows: a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of such deviation and any corrective actions or preventative actions taken. The responsible official shall certify all deviations from permit requirements. I.B.Other Requirements under 15A NCAC 02D .0535 The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D .0535, including 15A NCAC 02D.0535(c)as follows: 1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the appropriate rule unless the owner or operator of the sources demonstrates to the Director,that the excess emissions are a result of a malfunction. The Director shall consider,along with any other pertinent information,the criteria contained in 15A NCAC 02D .0535(c)(1)through(7). 2. 15A NCAC 02D.0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable. J. Emereency Provisions[40 CFR 70.6(g)] The Permittee shall be subject to the following provisions with respect to emergencies: 1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the facility, including acts of God,which situation requires immediate corrective action to restore normal operation,and that causes the facility to exceed a technology-based emission limitation under the permit,due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation,or operator error. 2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based emission limitations if the conditions specified in 3.below are met. 3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or other relevant evidence that include information as follows: a. an emergency occurred and the Permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that exceeded the standards or other requirements in the permit;and d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, steps taken to mitigate emissions,and corrective actions taken. 4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the burden of proof. 5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified elsewhere herein. K. Permit Renewal [15A NCAC 02Q .0508(e)and 02Q.0513(b)] This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q .0500 renewal application is submitted at least nine months before the date of permit expiration. If the Permittee or applicant has complied with 15A NCAC 02Q .0512(b)(1),this 15A NCAC 02Q .0500 permit shall not expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC 02Q .0400 terminates the facility's right to operate unless a complete 15A NCAC 02Q .0400 renewal application is submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q .0400 requirements. In either of these events, all terms and conditions of these permits shall remain in effect until the renewal permits have been issued or denied. Permit No. 03424T25 Page 26 L. Need to Halt or Reduce Activity Not a Defense[15A NCAC 02Q.0508(i)(4)] It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. M. Duty to Provide Information(submittal of information) [15A NCAC 02Q .0508(i)(9)] 1. The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director may request in writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to determine compliance with the permit. 2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are requested by the Director.For information claimed to be confidential,the Permittee may furnish such records directly to the EPA upon request along with a claim of confidentiality. N. Duty to Supplement[15A NCAC 02Q.0507(f)] The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the permit application,shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee shall also provide additional information as necessary to address any requirement that becomes applicable to the facility after the date a complete permit application was submitted but prior to the release of the draft permit. O. Retention of Records [15A NCAC 02Q.0508(f)and 02Q.0508(1)] The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five years from the date of the monitoring sample,measurement,report,or application. Supporting information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring information,and copies of all reports required by the permit. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. Any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. P. Compliance Certification [15A NCAC 02Q .0508(n)] The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4, 61 Forsyth Street SW,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the permit, including emissions limitations, standards,or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the entire year regardless of who owned the facility during the year. The compliance certification shall comply with additional requirements as may be specified under Sections l 14(a)(3)or 504(b)of the Federal Clean Air Act. The compliance certification shall specify: l. the identification of each term or condition of the permit that is the basis of the certification; 2. the compliance status(with the terms and conditions of the permit for the period covered by the certification); 3. whether compliance was continuous or intermittent;and 4. the method(s)used for determining the compliance status of the source during the certification period. Q. Certification by Responsible Official [15A NCAC 02Q .0520] A responsible official shall certify the truth,accuracy,and completeness of any application form, report,or compliance certification required by this permit. All certifications shall state that based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate, and complete. R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512] 1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,where such applicable requirements are included and specifically identified in the permit as of the date of permit issuance. Permit No. 03424T25 Page 27 2. A permit shield shall not alter or affect: a. the power of the Commission, Secretary of the Department,or Governor under NCGS 143- 215.3(a)(12), or EPA under Section 303 of the Federal Clean Air Act; b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective date of the permit or at the time of permit issuance; c. the applicable requirements under Title IV;or d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to determine compliance of the facility with its permit. 3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made under 15A NCAC 02Q .0523. 4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515. S. Termination,Modification,and Revocation of the Permit[15A NCAC 02Q .0519] The Director may terminate,modify,or revoke and reissue this permit if: 1. the information contained in the application or presented in support thereof is determined to be incorrect; 2. the conditions under which the permit or permit renewal was granted have changed; 3. violations of conditions contained in the permit have occurred; 4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or 5. the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to carry out the purpose of NCGS Chapter 143,Article 21B. T. Insiunificant Activities [15A NCAC 02Q .0503] Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from any applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. The Permittee shall have available at the facility at all times and made available to an authorized representative upon request,documentation, including calculations, if necessary,to demonstrate that an emission source or activity is insignificant. U. Property Rights [15A NCAC 02Q .0508(i)(8)] This permit does not convey any property rights in either real or personal property or any exclusive privileges. V. Inspection and Entry [15A NCAC 02Q .0508(1)and NCGS 143-215.3(a)(2)] 1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow the DAQ, or an authorized representative,to perform the following: a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is conducted,or where records are kept under the conditions of the permit; b. have access to and copy,at reasonable times, any records that are required to be kept under the conditions of the permit; c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring and air pollution control equipment),practices,or operations regulated or required under the permit;and d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose of assuring compliance with the permit or applicable requirements at reasonable times. Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under Section 114 or other provisions of the Federal Clean Air Act. 2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for purposes of inspection, and who presents appropriate credentials,nor shall any person obstruct, hamper,or interfere with any such authorized 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. W. Annual Fee Payment[15A NCAC 02Q .0508(i)(10)] 1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q .0200. 2. Payment of fees may be by check or money order made payable to the N.C.Department of Permit No. 03424T25 Page 28 Environmental Quality. Annual permit fee payments shall refer to the permit number. 3. If, within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate action to terminate the permit under 15A NCAC 02Q .0519. X. Annual Emission Inventory Requirements [15A NCAC 02Q.0207] The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 02Q.0207(a)from each emission source within the facility during the previous calendar year. The report shall be in or on such form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the facility. Y. Confidential Information [15A NCAC 02Q.0107 and 02Q. 0508(i)(9)] Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q .0107,the Permittee may also submit a copy of all such information and claim directly to the EPA upon request. All requests for confidentiality must be in accordance with 15A NCAC 02Q.0107. Z. Construction and Operation Permits [15A NCAC 02Q .0100 and .0300] A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or emission source which is not exempted from having a permit prior to the beginning of construction or modification, in accordance with all applicable provisions of 15A NCAC 02Q .0100 and .0300. AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and .0507] The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 02Q .0505 and .0507. BB.Financial Responsibility and Compliance History [15A NCAC 02Q.0507(d)(4)] The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial compliance history. CC. Refrigerant Requirements(Stratospheric Ozone and Climate Protection) [15A NCAC 02Q.0501(e)] 1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment,which use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair, and maintain such equipment according to the work practices,personnel certification requirements,and certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F. 2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the environment during the repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82 Subpart F. 3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR - 82.166. Reports shall be submitted to the EPA or its designee as required. DD. Prevention of Accidental Releases-Section 112(r) [15A NCAC 02Q.0508(h)] If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r)of the Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part 68. EE. Prevention of Accidental Releases General Duty Clause- Section 112(r)(1)- FEDERALLY-ENFORCEABLE ONLY 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. Permit No. 03424T25 Page 30 (2) Prescribe alternate test procedures on an individual basis when he finds that the alternative method is necessary to secure more reliable test data. (3) Prescribe or approve methods on an individual basis for sources or pollutants for which no test method is specified in this Section if the methods can be demonstrated to determine compliance of permitted emission sources or pollutants. b. The Director may authorize the Division of Air Quality to conduct independent tests of any source subject to a rule in this Subchapter to determine the compliance status of that source or to verify any test data submitted relating to that source. Any test conducted by the Division of Air Quality using the appropriate testing procedures described in Section 02D .2600 has precedence over all other tests. KK. Reopenine for Cause [15A NCAC 02Q .0517] 1. A permit shall be reopened and revised under the following circumstances: a. additional applicable requirements become applicable to a facility with remaining permit term of three or more years; b. additional requirements(including excess emission requirements)become applicable to a source covered by Title IV; c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;or d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the applicable requirements. 2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q .0513(c). 3. Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 02Q .0507, .0521,or.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the permit is reopened,the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall affect only those parts of the permit for which cause to reopen exists. 4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,except in cases of imminent threat to public health or safety the notification period may be less than 60 days. 5. Within 90 days,or 180 days if the EPA extends the response period, after receiving notification from the EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the EPA a proposed determination of termination,modification,or revocation and reissuance,as appropriate. LL.Reporting Requirements for Non-Operating Equipment [15A NCAC 02Q .0508(i)(16)] The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from and placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the permit shall be implemented within the monitoring period. MM. Fugitive Dust Control Requirement [15A NCAC 02D .0540] - STATE ENFORCEABLE ONLY As required by 15A NCAC 02D .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 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 02D .0540(f). "Fugitive dust emissions"means particulate matter from process operations 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). Permit No. 03424T25 Page 29 FF. Title IV Allowances [15A NCAC 02Q .0508(i)(1)] This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not use allowances as a defense to noncompliance with any other applicable requirement. The Permittee's emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act. GG. Air Pollution Emergency Episode[15A NCAC 02D .0300] Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to operate in accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of an approved plan,with the appropriate requirements specified in 15A NCAC 02D .0300. HH. Registration of Air Pollution Sources [15A NCAC 02D .0202] The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to register a source of air pollution,this registration and required information will be in accordance with 15A NCAC 02D .0202(b). H. Ambient Air Ouality Standards [15A NCAC 02D .0501(c)] In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any source of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on which the source is located. When controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of the ambient air quality standards or are required to create an offset,the permit shall contain a condition requiring these controls. JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q.0508(i)(16)] Emission compliance testing shall be by the procedures of Section .2600, except as may be otherwise required in Rules .0524, .0912, .1110, .1111, or .1415 of Subchapter 02D. If emissions testing is required by this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 02D.2600 and follow the procedures outlined below: 1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the Director prior to air pollution testing. Testing protocols are not required to be pre-approved by the Director prior to air pollution testing. The Director shall review air emission testing protocols for pre- approval prior to testing if requested by the owner or operator at least 45 days before conducting the test. 2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard shall notify the Director at least 15 days before beginning the test so that the Director may at his option observe the test. 3. The owner or operator of the source shall arrange for controlling and measuring the production rates during the period of air testing. The owner or operator of the source shall ensure that the equipment or process being tested is operated at the production rate that best fulfills the purpose of the test. The individual conducting the emission test shall describe the procedures used to obtain accurate process data and include in the test report the average production rates determined during each testing period. 4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after sample collection unless otherwise specified in the specific conditions. The owner or operator may request an extension to submit the final test report. The Director shall approve an extension request if he finds that the extension request is a result of actions beyond the control of the owner or operator. a. The Director shall make the final determination regarding any testing procedure deviation and the validity of the compliance test.The Director may: (1) Allow deviations from a method specified under a rule in this Section if the owner or operator of the source being tested demonstrates to the satisfaction of the Director that the specified method is inappropriate for the source being tested. Permit No. 03424T25 Page 31 NN. Specific Permit Modifications[15A NCAC 02Q.0501 and.0523] 1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2),the Permittee shall file a Title V Air Quality Permit Application for the air emission source(s)and associated air pollution control device(s) on or before 12 months after commencing operation. 2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2),the Permittee shall not begin operation of the air emission source(s)and associated air pollution control device(s)until a Title V Air Quality Permit Application is filed and a construction and operation permit following the procedures of Section .0500 (except for Rule .0504 of this Section) is obtained. 3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 02Q .0523(a)(1)(C),the Permittee shall notify the Director and EPA(EPA-Air Planning Branch, 61 Forsyth St. SW,Atlanta, GA 30303)in writing at least seven days before the change is made. The written notification shall include: a. a description of the change at the facility; b. the date on which the change will occur; C. any change in emissions; and d. any permit term or condition that is no longer applicable as a result of the change. In addition to this notification requirement, with the next significant modification or Air Quality Permit renewal,the Permittee shall submit a page "E5" of the application forms signed by the responsible official verifying that the application for the 502(b)(10)change/modification, is true, accurate,and complete. Further note that modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstruction requirements. 00. Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and .0525(7)] For permits modifications subject to 45-day review by the federal Environmental Protection Agency (EPA), EPA's decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party petition,the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit. The time period available to submit a public petition pursuant to 15A NCAC 02Q .0518 begins at the end of the 45-day EPA review period. Permit No. 03424T25 Page 32 ATTACHMENT List of Acronyms AOS Alternate Operating Scenario BACT Best Available Control Technology Btu British thermal unit CAA Clean Air Act CAIR Clean Air Interstate Rule CEM Continuous Emission Monitor CFR Code of Federal Regulations DAQ Division of Air Quality DEQ Department of Environmental Quality EMC Environmental Management Commission EPA Environmental Protection Agency FR Federal Register GACT Generally Available Control Technology HAP Hazardous Air Pollutant MACT Maximum Achievable Control Technology NAA Non-Attainment Area NCAC North Carolina Administrative Code NCGS North Carolina General Statutes NESHAPS National Emission Standards for Hazardous Air Pollutants NOx Nitrogen Oxides NSPS New Source Performance Standard OAH Office of Administrative Hearings PM Particulate Matter PMI0 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less POS Primary Operating Scenario PSD Prevention of Significant Deterioration RACT Reasonably Available Control Technology SIC Standard Industrial Classification SIP State Implementation Plan S02 Sulfur Dioxide tpy Tons Per Year VOC Volatile Organic Compound