HomeMy WebLinkAboutAQ_F_1800419_20150727_PRMT_Permit .A
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
July 27,2015
Mr. Steve Linden
Plant Manager
Prysmian Cable and Systems USA, LLC
2512 Penny Rd
Claremont NC, 28610
Dear Mr. Linden,
SUBJECT: Air Quality Permit No. 07334T27
Facility ID: 1800419
Prysmian Cable and Systems USA,LLC
Claremont,Catawba County
Fee Class: Title V
PSD Status: Major
In accordance with your completed Air Quality Permit Application for a minor modification of a
Title V permit received December 30, 2014, we are forwarding herewith Air Quality Permit No. 07334T27
to Prysmian Cable and Systems USA, LLC, at 2512 B Penny Road in Claremont, 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 2Q .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.
The changes to the control systems affecting emission sources (ID Nos. ES-11 and ES-18) and
control devices (ID Nos. ES-1WS, ES-2WS and ES-3WS) are listed as a minor modification per 15A
NCAC 2Q .0515. The compliance certification as described in General Condition P is required. Unless
otherwise notified by NC DAQ, the affected terms of this permit (excluding the permit shield as described
General Condition R)for this source shall become final on September 20,2015. Until this date,the affected
permit terms herein reflect the proposed operating language that the Permittee shall operate this source
under pursuant to 15A NCAC 2Q .0515(f).
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 condition(s)of the attached
permit that are applicable to that particular emission source. If any parts, requirements,or limitations
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
Phone:919-707-8400 I Internet www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer—Made in part with Recycled Paper
Mr. Steve Linden
July 27, 2015
Page 2
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. This hearing request must be in the form of a written petition,conforming to NCGS(North
Carolina General Statutes) 15013-23,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 15013-23,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 15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that 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 15013-23.
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.
The PSD minor source baseline date is triggered for Catawba County for the emissions of PM10.
There is no increment consumed or generated by this permit action.
This Air Quality Permit shall be effective from July 27, 2015 until February 28, 2019, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations as
specified therein.
The changes made to the permit are summarized in the attachment to this letter. Should you have
any questions concerning this matter,please contact please contact Mr.Charles F.Yirka,at(919)707-8728.
Sincerely yours,
t V A�
William D.Willets,P.E.,Chief,Permitting Section
Division of Air Quality,NCDENR
Enclosure
c: Shannon Vogel—SSCB
Connie Horne—Permitting Section/Increment Tracking
Heather Ceron,EPA Region 4-permit only
Mooresville Regional Office
Central Files
Air Quality Permit No. 07334T27
Prysmian Cable and Systems USA,LLC
Claremont Facility
Insignificant Activities under 15A NCAC 2 .0503(8)
Emission Source I.D. Emission Source Description
I-AHU Multiple roof top air handling units
I-boilerl, I-boiler2,I-
boiler3, Four natural gas-fired boilers (two 8.0 million Btu/hr and two
8.76 million Btu/hr units)
I-boiler4
I-ES-15 Collapse process hoods
I-ES-S Prep hoods
I-ES-13 and I-ES-13a Two central vacuum systems
I-ES-10 Glass saw hoods
I-SD-1 Waste water sludge dryer
I-ES-7 Draw towers
I-Clean Machine cleaning stations with 10 eight-gallon capacity
acetone baths
I-BEL Sixteen Buffering extruder lines
I-JEL Eleven Jacketing extruder lines
I-JM Jacket Melters
I-FH Eight flame heaters for the jacket extruder lines(0.044 million
Btu/hr each)
I-PL Sixteen printing lines
I-RL Six ribbon lines
I-FBW Fluid
I-PW Parts washer
I-T-1, I-T-2 Two natural gas fired storage tank heaters(0.129 million Btu/hr
each)
I-WB-1, I-WB-2 Two hot water boilers (0.75 million Btu/hr each)
I-WH-1 and I-WH-2 Two domestic water heaters(0.75 million Btu/hr each)
I-ANNEAL Annealing Furnace
I-CORRAL One natural gas-fired corral lathe(0.10 million Btu/hr)
I-FP Diesel-fired fire pump 105 HP
MACT ZZZZ
I-EmGen
MACT ZZZZ Diesel-fired emergency generator 150 HP
ATTACHMENT
Air Quality Permit No. 07334T27
Prysmian Cable and Systems USA,LLC-Claremont Facility
The following changes were made to the Prysmian Cables and Systems USA, LLC,Air Permit No.
07334T26:
Page(s) Section Descri tion of Change(s)
Cover letter NA Update permit revision number and issue date,
revise insignificant activity list to include
emergency engine and fire pump.
Permit cover NA Update permit revision number and issue date,
a lication number
3-4 Section 1 Modified table to reflect proposed rerouting of
emissions from sources and changes to control
device associations
5 Section 2.1 A Updated emissions sources and control devices
7 Section 2.1 A.La -Change description and insert PM testing
requirements for 2D .0515
-Change monitoring requirements for 3WS and
remove scrubbers 1WS and 2WS
9 Section 2.1 A.2.a.ii Require establishing normal after control system
modified for 2D .0521
11 removal Section 2.1 C. Remove and transfer to the insignificant activities
(T26) list the MACT affected sources according to DAQ
guidance moving these sources to the insignificant
list since emissions that are<5 TPY of a criteria
and< 1,000 lb/yr for HAPs.
12 Section 2.2 A.Lb Require testing for HAPs due to reconfiguration of
scrubber system for 2Q .0317 MACT avoidance
13 Section 2.2 A.Ld Changed description of control devices; eliminate
1WS and 2WS
15 Section 2.2 B.l.g Revise requirement for test protocol to simply refer
to General Condition JJ
18 Section 2.2 C.Lf Revise requirement for test protocol to simply refer
to General Condition JJ
18 Section 2.2 C.Lh Add NOx sources previously left off the permit
19 Section 2.2 D Revise description of sources
20 Section 2.2 D.1 Revise table description of sources
20 Section 2.2 D.La -Revise description of sources and controls
Section 2.2 D.1 c -Insert reference to stack testing required under the
2Q .0317 avoidance condition to establish new
emissions factors for tracking emissions
22 Section 2.3 A.Lb. Insert reference to stack testing required under the
2Q .0317 avoidance condition to establish new
emissions factors for tracking emissions
23 Section 2.3 A.Ld-e Updated CAM recordkeeping and reporting
requirements to the latest Permitting Section's SOP.
24 Section 2.3 B.l.d-e Updated CAM recordkeeping and reporting
requirements to the latest Permitting Section's SOP.
26 Section 2.3 C.Ld-e Updated CAM recordkeeping and reporting
requirements to the latest Permitting Section's SOP.
27-37 Section 3 Insert latest version of General Conditions-Version
3.6 01/31/12 11
f North Carolina,
•State o o aro a, •
Department of Environment, -�.•�..r
IL
and Natural Resources �
NCDENR
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
07334T27 07334T26 July 27, 2015 February 28, 2019
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 2D and 2Q, and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, 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: Prysmian Cables and Systems USA, LLC
Facility ID: 1800419
Facility Site Location: 2512 B Penny Road
City, County, State, Zip: Claremont, Catawba County, NC 28610
Mailing Address: P.O. Box 400
City, State, Zip: Claremont, Catawba County, NC 28610
Application Number: 1800419.14A
Complete Application Date: January 9, 2015
Primary SIC Code: 3229
Division of Air Quality, Mooresville
Regional Office Address: 610 East Center Avenue, Suite 301
Mooresville, NC 28115
Permit issued this the 271h of July, 2015.
William b. 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
ATTACHMENT
List of Acronyms
Permit 07334T27
Page 3
SECTION 1- 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 Control Device
Page Source Emission Source Description Device
No. ID No. ID No. Description
ES-1, Chemical vapor deposition units -
6, 12, CAM Cells 5, 6, and 7 Wet scrubber(13,000
19, 22 acfin) consisting of a
variable throat venturi
ES-4-3WS Gas cabinets-cells 5, 6, and 7 3WS scrubber(10 to 15 inches
water pressure drop)with
greater than 90 gallons per
ES-14 Collapse furnaces-cells 5, 6, and minute caustic solution
7 injection(pH 8 or higher as
determined from source
testing)
ES-11 Chemical Room
ES-18 SiC14 Storage Room
6, 10,
14 ES-2 Chemical vapor deposition N/A N/A
process hoods
Fabric filter with hydrated
lime injection(30 dry
pounds per hour lime
6, 8, 10, injection or higher as
14, 17, 1DS determined by testing;
19, 23 9,800 square feet of filter
area or greater)
Or
ES-9 Over-cladding Units—Cell 4,and Ammonia injected catalytic
CAM four Cell 5 units NOX reduction system
1SCR (space velocity 11,214 hr-')
with natural gas-fired flue
gas re-heater(10 million
Btu/hr heat input)and
natural gas-fired ammonia
injector dilution air heater
(one million Btu/hr heat
input) install on 1DS
Permit 07334T27
Page 4
Emission Control
Page Source Emission Source Description Device Control Device
No. ID No. ID No. Description
Fabric filter with hydrated
lime injection(ID No.
2DS; 30 dry pounds per
hour lime injection or
6, 10, 2DS higher as determined by
16 testing; 9,800 square feet of
filter area or greater)
Or
ES-9a Over-cladding Units-Cell 6, 7, Ammonia injected catalytic
CAM and remaining Cell 5 units NO,,reduction system(ID
No. 2SCR; space velocity
2SCR 11,214 hr-')with natural
gas-fired flue gas re-heater
(10 million Btu/hr heat
input)and natural gas-fired
ammonia injector dilution
air heater(one million
Btu/hr heat input)installed
on 2DS
Permit 07334T27
Page 6
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. Chemical Vapor Deposition Units (ID No.ES-1) consisting of.-
Cells 5, 6, and 7 with Wet Scrubber(ID No.3WS); and,
Chemical Vapor Deposition Process Hoods(ID No. ES-2);
Over-cladding Units (ID No. ES-9)consisting of:
Cells 4, and four cell 5 units venting to Hydrated Lime Injection Dry Scrubber Fabric
Filter System (ID No. IDS), which vents to Selective Catalytic NOx Reduction System
(ID No. 1SCR)
Over-cladding Units (ID No.ES-9a) consisting of:
Cells 6, 7, and remaining cell 5 units venting to Hydrated Lime Injection Dry
Scrubber Fabric Filter System (ID No. 2DS), which vents to Selective Catalytic NOx
Reduction System(ID No.2SCR); and,
SiC14 Bulk Storage Room(ID No.ES-18) that vents to a Wet Scrubber(ID No.3WS)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
For process rates less than 30 tons per hour:
E=4.10 P0.61
Particulate Matter Where, 15A NCAC 2D .0515
E is the allowable emission rate in pounds per
hour, and
P is the process weight rate in tons per hour
Visible Emissions 20 percent opacity 15A NCAC 2D .0521
15A NCAC 2Q .0317
Hazardous Air Pollutants See Section 2.2 A.Multiple Emissions Sources MACT Avoidance
Condition
Particulate Matter,
Nitrogen Oxides, Affected Sources—ES-1,ES-9,and ES-9a
Hazardous Air Compliance Assurance Monitoring(CAM) 15A NCAC 2D .0614
Pollutants See Section 2.3
(HCL,C12,and HF)
Affected Sources- Cell 5, 6, 7,Equipment 15A NCAC 2Q.0317
Nitrogen Oxides See Section 2.2 C.Multiple Emissions Sources (15A NCAC 2D .0530)
PSD Avoidance Condition
Permit 07334T27
Page 7
Regulated Limits/Standards Applicable Regulation
Pollutant
Toxic Air Clz, HCI, HF,NH3 15A NCAC 2D .1100
Pollutants See Section 2.2 E. Multiple Emissions Sources
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Emissions of particulate matter from (ID No. ES-1) shall not exceed an allowable emission rate as
calculated by the following equation: [15A NCAC 2D .0515(a)]
E=4.10xP067
Where; E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
a. Chemical Vapor Deposition Units(ID No.ES-1)and SiC14 Bulk Storage Room(ID No.ES-18)
Testing Requirements [15A NCAC 2Q .0508(f)]
i. Reconfigured Scrubber System 3WS
(A)Controlled emissions from the chemical vapor deposition units and SiCL4 bulk storage room (ID
Nos. ES-1 and ES-18) shall be tested for PM within 180 days of commencement of operation of
the reconfigured scrubber system (ID No. 3WS) to determine compliance with the calculated
emission limit based on the process weight throughput monitored during the stack test.
(B) The test results must be submitted to the Regional Supervisor within 60 days of completion of on-
site testing.
If the results of this test are above the limit given in Section 2.1 A. 1. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0515.
ii. General
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. 1. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515.
Monitoring[15A NCAC 2Q .0508(f)]
iii. Particulate matter emissions from the chemical vapor deposition units (ID No. ES-1) shall be
controlled by the wet scrubber system (ID No. 3WS). To comply with the provisions of this Permit
and ensure that optimum control efficiency is maintained, the Permittee shall establish an inspection
and maintenance schedule/checklist based on manufacturer's recommendations. Additionally, a
quarterly internal inspection shall be conducted on the wet scrubbers—by the Permittee to insure
structural integrity such that optimum control efficiency is achieved. As a minimum, the inspection
and maintenance program shall include inspection of spray nozzles, packing material, chemical feed
system,and the cleaning/calibration of all associated instrumentation.
iv. The Permittee shall ensure the proper performance of the scrubber by monitoring the following
operational parameters each shift:
ID No.3WS
(A) Recycle liquid flow rates(greater than 90 gallons per minute),
(B) Liquid make-up flow rates(greater than 1 gallon per minute),
Permit 07334T27
Page 8
(C) pH of recirculation tank scrubbing solution(pH 8 or higher as determined from source testing),and
(D)Pressure drop across the scrubber(10 to 15 inches of water).
v. The Permittee shall ensure that the process equipment in cell 4 is shutdown and the block valve is in
place when bulk SiC14 bulk storage (H) No. ES-18) emission are vented to the scrubber (H) No.
3WS).
vi. The Permittee shall be deemed in non-compliance with 2D .0515 if records of the monitoring results
are not maintained.
Recordkeeping[15A NCAC 2Q .0508(f)]
vii. 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 each shift:
(A)The date and time of each recorded action,
(B) The results of each inspection,
(C) The results of any maintenance performed on the scrubber system,
(D) Any variance from manufacturer's recommendations, if any, and corrections made,
(E) The recycle liquid flow rates,
(F) Liquid make-up flow rates,
(G)pH of the scrubber solutions,and
(H)The pressure drop across the scrubber.
viii.Documentation sufficient to demonstrate that the process equipment in cell 4 was shutdown and the
block valve was in place during periods when SiCl4 bulk storage emissions(ID No.ES-1 8)were being
vented to the scrubber(ID No.3WS). If the records are not maintained as per the above,the Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0515.
Reporting [15A NCAC 2Q .0508(f)]
ix. The Permittee shall submit the results of any inspection, maintenance, or monitoring performed for
each control device within 30 days of a written request by the DAQ.
x. 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.
b. Chemical Vapor Deposition Process Hoods (H)No.ES-2)
Testing,Monitoring,Recordkeeping,and Reporting [15A NCAC 2Q .0508(f)]
No testing,monitoring,recordkeeping, or reporting is required for this source group.
c. Over-cladding Units(ID Nos.ES-9 and ES-9a)
Testing [15A NCAC 2Q .0508(f)]
i. 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. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
ii. The Permittee shall ensure the proper performance of the lime injection/fabric filter system (H) Nos.
1DS and 2DS)by monitoring and recording the following operating parameters at least once per shift:
(A) Lime injection rate(minimum 30 dry pounds per hour)and
(B) Pressure drop across the fabric filter(0.1 to 9 inches of water).
Permit 07334T27
Page 9
The above records shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The Permittee shall be deemed in non-
compliance with 2.1 A.1. if records of the operating parameters are not maintained.
iii. The Permittee shall perform inspections and maintenance of the fabric filters (ID Nos. IDS and 2DS)
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:
(A) A monthly visual inspection of the system ductwork and material collection unit for leaks; and
(B) An annual (for each 12 month period following the initial inspection) internal inspection of the
bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and
bagfilters are not inspected and maintained.
iv. 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:
(A) The date and time of each recorded action;
(13) The results of each inspection;
(C) The results of any maintenance performed on the bagfilters; and
(D) Any variance from manufacturer's recommendations,if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
v. The Permittee shall submit the results of any inspection, maintenance, and monitoring performed on
the fabric filter and hydrated lime injection system within 30 days of a written request by the DAQ.
vi. 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 2D.0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these source groups 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 2D .0521 (d)]
a. Chemical Vapor Deposition Units(ID No.ES-1)and Over-cladding Units (ID No.ES-9& ES 9a)
Testing [15A NCAC 2Q .0508(f)]
i. 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. 2. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
ii. The Permittee shall observe the emissions points to reestablish normal within 30 days of permit
issuance(Permit No. 07334T27)or start-up of the reconfigured control system(ID No.3WS).
iii. 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:
Permit 07334T27
Page 10
(A) Take appropriate action to correct the above-normal emissions within the monitoring period and
record the action taken as provided in the recordkeeping requirements below,or
(B) Demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 21) .2610 (Method 9) for 12 minutes is below the limit given in
Section 2.1 A.2.above.
If the above-normal emissions are not corrected per (A) above or if the demonstration in (B) above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
iv. 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:
(A)The date and time of each recorded action;
(B) 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
(C) The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
v. The Permittee shall submit a summary report of the observations by 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, for each day of operation. The summary
report shall consist of the following.
(A) Instances when visible emissions exceeded normal operating conditions and an explanation of each
instance. The explanation should include any corrective actions taken to reduce visible emissions
to normal.
(B) A statement that the required monitoring was or was not performed each day of operation. If
required monitoring was not performed each day of operation,the summary report shall specify the
dates and an explanation why the monitoring was not performed.
b. Chemical Vapor Deposition Process Hoods Units(ID No.ES-2)
Monitoring,Recordkeeping,and Reporting [15A NCAC 2Q .0508(f)]
No monitoring,recordkeeping,or reporting is required for this source group.
B. Chemical Vapor Deposition Process Hoods(I )No. ES-2), and
Over-cladding Units(ID No. ES-9)consisting of:
Cells 4, and some cell 5 units venting to Hydrated Lime Injection Dry Scrubber Fabric
Filter System(ID No. 1DS),which vents to Selective Catalytic NOx Reduction System (ID
No. 1SCR)
Over-cladding Units (ID No.ES-9a)consisting of:
Cells 6, 7, and remaining cell 5 units venting to Hydrated Lime Injection Dry Scrubber
Fabric Filter System (ID No. 2DS), which vents to Selective Catalytic NOx Reduction
System(ID No. 2SCR)
The following table provides a summary of limits and standards for the emission source described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Permit 07334T27
Page 11
=ulftirioxide 2.3 pounds per million Btu heat input 15A NCAC 213 .0516
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these source groups 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. [15A NCAC 2D .0516]
Testing [15A NCAC 2Q .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 B. 1. a. above,the
Permittee shall be deemed in noncompliance with 15A NCAC 213 .0516.
Monitoring,Recordkeeping,and Reporting Requirements
c. No monitoring,recordkeeping or reporting is required for these sources.
Permit 07334T27
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2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. All Emission Sources
1. 15A NCAC 2Q .0317: MACT AVOIDANCE CONDITIONS — LIMITATION TO AVOID BEING
MAJOR FOR HAZARDOUS AIR POLLUTANTS
a. In order to remain classified a minor source for hazardous air pollutants and avoid applicability of this
regulation, facility-wide emissions, including those emissions from the cable manufacturing
facility, shall be less than:
i. 10 tons per consecutive 12-month period of each hazardous air pollutant,and
ii. 25 tons per consecutive 12-month period of all hazardous air pollutants combined.
The Permittee shall be deemed in noncompliance with this condition and 2D .1111 if the HAP
emissions exceed this limit.
Testing Requirements [15A NCAC 2Q .0508(f)]
b. Reconfigured Scrubber System 3WS
i. Controlled emissions from the cells 5, 6, and 7 chemical vapor deposition units, gas cabinets
collapse furnaces (ID Nos. ES-1, ES4-3WS, and ES-14), chemical room (ID No. ES-11) and
SiCL4 bulk storage room (ID No. ES-18) shall be tested for the following HAPs; Hydrochloric
acid, Chlorine, and Hydrofluoric acid within 180 days of commencement of operation of the
reconfigured scrubber system (ID No. 3WS) in order to determine emissions factors for
monitoring,recordkeeping and reporting purposes.
ii. The test results must be submitted to the Regional Supervisor within 60 days of completion of on-
site testing.
The results of this test are intended for establishing emissions factors as per the monitoring and
recordkeeping requirements below.
ES-1, Chemical vapor deposition units -
CAM Cells 5, 6, and 7 Wet scrubber(13,000 acfm)
consisting of a variable throat
venturi scrubber(10 to 15
ES-4-3WS Gas cabinets-cells 5, 6, and 7 3WS inches water pressure drop)
with greater than 90 gallons
per minute caustic solution
ES-14 Collapse furnaces -cells 5, 6, and 7 injection(pH 8 or higher as
determined from source
testing)
ES-11 Chemical Room
ES-18 SiC14 Storage Room
c. General
Emissions testing is required to establish emissions factors and control parameters. The testing shall be
performed in accordance with General Condition JJ found in Section 3.
Control Requirements
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d. Gaseous emissions from the chemical vapor deposition (CVD) process lathes (ID No. ES-1), gas
cabinets (ID No. ES-4), chemical room (ID No. ES-11), collapse process furnaces (ID No. ES-14),
and the SiCla bulk storage room(ID No.ES-18) shall be controlled by the wet scrubber(ID No.3WS).
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if hazardous air
pollutants from the emission sources are not controlled as provided above.
e. Emissions from the over-cladding processes (ID Nos. ES-9 and ES-9a) shall be controlled by three
fabric filter systems with hydrated lime injection (ID Nos. MS and 2DS). The Permittee shall be
deemed in non-compliance with 15A NCAC 2D .1111 if hazardous air pollutants from the emission
sources are not controlled as provided above.
Monitoring and Recordkeeping Requirements [15A NCAC 2Q .0508(f)]
f. Process throughput and actual material usage shall be recorded monthly. The Permittee shall be
deemed in non-compliance with 15A NCAC 2D.1111 if these records are not created and maintained.
g. Each month, the Permittee shall calculate individual and combined HAP emissions (facility-wide) for
the previous calendar month and the previous consecutive 12-month period using actual production
data, as recorded above, and assumed or tested emission rates and/or control efficiencies, as
appropriate. The Permittee shall be deemed in non compliance with 15A NCAC 2D .1111 if these
calculations are not maintained on record or if the 12-month rolling emissions totals exceed the limits
in Section 2.2 A.1.of this permit.
Reporting Requirements[15A NCAC 2Q .0508(f)]
h. Submit a semiannual summary report,acceptable to the Regional Air Quality Supervisor,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. The report shall contain the following:
i. Individual and total,combined HAP emissions for each of the previous 17 calendar months; and,
ii. Individual and total, combined HAP emissions for each consecutive 12-month period ending in the
previous six months.
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Page 14
B. Chemical Vapor Deposition Process Hoods (ID No. ES-2); and,
Over-cladding Units (ID No. ES-9, excluding cell 5 units).
Two 8.76 million Btu per hour heat input natural gas-fired boilers (insignificant sources)
Insignificant Sources (0.75 million Btu per hour hot water boilers, sludge dryer, emergency
fire pump, emergency generator, parts washer, two 0.129 million Btu per hour boilers and
air handling units)
The following provides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Nitrogen Oxides Total emissions of nitrogen oxides shall be less 15A NCAC 2Q .0317
than 250 tons per consecutive 12-month period. PSD Avoidance
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D. 0530: PREVENTION OF
SIGNIFICANT DETERIORATION
a. Total emissions of nitrogen oxides from equipment in Cells 1, 2, 3, and 4 and two boilers shall be less than
250 tons per consecutive 12-month period. The Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0530 if NOx emissions exceed this limit.
Control Requirements
b. To ensure compliance with the above emissions limits, nitrogen oxides from Over-cladding Units contained
in Cells 4(ID No.ES-9,excluding cell 5 units) shall be controlled by:
i. A fabric filter with hydrated lime injection (ID No. IDS),or
ii. A fabric filter with hydrated lime injection (ID No. IDS) in series with a selective catalytic NOx
reduction system(ID No. 1SCR).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions from these
sources are not controlled as provided above.
Testing Requirements [15A NCAC 2Q .0508(f)]
c. Chemical Vapor Deposition Process Hoods
i. Uncontrolled NOx emissions from an individual chemical vapor deposition hood (ID No. ES 2) shall
be tested to determine an emission rate in pounds of NOx per unit-hour to be used in demonstrating
compliance with the PSD avoidance conditions for the existing and modified facility (2.2 B.1. and 2.2
C.1.).
ii. Uncontrolled CVD process hood emission rates must be revalidated annually by May 30 of each
calendar year.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if uncontrolled NOx
emissions from these sources are not tested and validated as provided above.
d. Over-cladding Units
i. Uncontrolled NOx emissions from individual small and large torch Over-cladding Units (Cells 4; ID
No. ES-9) shall be tested to determine emission rates in pounds of NOx per unit-hour to be used in
demonstrating compliance with the PSD avoidance condition.
ii. Uncontrolled over-cladding emission rates must be revalidated annually by May 30 of each calendar
year.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if uncontrolled NOx
emissions from these sources are not tested and validated as provided above.
e. Dry Scrubber System(Lime Injection and Fabric Filter)
Permit 07334T27
Page 15
i. NOx emissions from Over-cladding Units (Cells 4; ID No.ES-9) shall be tested prior to and after the
dry scrubber control (ID No. 1DS) to determine the dry scrubber control efficiency used in
demonstrating compliance with the PSD avoidance condition.
ii. Control efficiency of the dry scrubber system (lime injection and fabric filter) must be revalidated
annually and each time the type of filter material is changed unless the Permittee assumes no fabric
filter control for the purposes of compliance demonstration until further DAQ approved testing is
conducted.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions from
these sources are not tested and validated as provided above.
f. SCR System
i. NOx emissions from Over-cladding Units (Cells 4; ID No. ES-9) shall be tested prior to and after the
SCR control (ID No. 1SCR) to validate the data generated by the continuous NO and NO2 emission
analyzers. The control efficiency calculated from the test and the analyzers at the time of the test shall
be within 5%to validate the analyzers.
ii. Initial validation test results for SCR control efficiency must be submitted to the Regional Supervisor,
DAQ, within 120 days(or alternate date approved by DAQ)of SCR(ID No. 1 SCR)startup.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions from
these sources are not tested as provided above.
g. General
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 2.2 B.La above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530.
Monitoring and Recordkeeping Reguirements[15A NCAC 2Q .0508(f)]
h. Continuous NO and NO2 emission analyzers shall be installed upstream and downstream of the SCR (ID
No. 1SCR) to monitor emissions from the Over-cladding Units (ID No. ES-9) venting to and from the
selective catalytic NOx reduction system(ID No. 1SCR).
i. Analyzers shall be calibrated daily.
ii. Measurements of NO and NO2 shall be recorded after calibration at the inlet and outlet monitors.
iii. NO and NO2 concentrations at the inlet shall be summed and NO and NO2 concentrations at the outlet
shall be summed for the determination of a daily control efficiency.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions are not
monitored as provided above.
i. Calculation of monthly NOx emissions shall be made at the end of each month. Facility-wide NOx
emissions shall be determined by adding emissions from the insignificant sources using AP-42 emission
factors, the chemical vapor deposition process hoods in Cells 4 (ID No. ES-2), and the Over-cladding
Units in Cells 4 (ID No. ES 9) including dry scrubber NOx control efficiency, if applicable, and the SCR
control efficiency for periods when the SCR system was used. Calculation of NOx emissions using test
data from the latter two source groups(ID Nos.ES-2 and ES 9)shall be performed as follows:
i. NOx emission from CVD process hoods shall be determined by multiplying operating hours for CVD
units during the month by the pounds of NOx per unit-hour determined from source testing.
Calculations shall be performed using the highest of the following values:
(A) 0.41 pounds of NOx per unit-hour; or,
(B) Any higher emission rate demonstrated by a stack test.
ii. NOx emissions from Over-cladding Units in Cells 4 (ID No. ES-9) shall be determined by multiplying
operating hours for each over-cladding unit group type by the pounds of NOx per unit-hour determined
from source testing. The number of operating hours for small and large torch groups shall be a separate
record. Emissions of NOx shall be calculated using the uncontrolled emission rate demonstrated in the
most recent stack test,as provided in Section 2.2 B.1 d.
iii. Inclusion of Dry Scrubber Emissions Reductions
Permit 07334T27
Page 16
(A) Calculation of NOx emissions may include Dry Scrubber emissions reductions using the control
efficiency of the fabric filter measured during source testing for the type of filter employed at the
time of testing.
(B) The control efficiency for the dry scrubber determined by DAQ-approved testing is valid if:
1. The NOx uncontrolled loading rate to the fabric filter which occurred during the test increases
by no more than 25 percent, and
2. The lime injection rate is at or above the injection rate measured and recorded during the
performance test.
iv. Inclusion of SCR Emissions Reductions
(A) Calculation of NOx emissions may include SCR emissions reductions during SCR operating
periods. The daily control efficiency determined in accordance with 2.2 B.1.c.i.C. shall be used to
reduce the amount of uncontrolled emissions calculated per 2.2 B.1.c.ii.B. on a daily basis.
1. If a daily measurement is not available during a period that the SCR is operational, the last
available measurement shall be used in place of the missing data provided that the missing data
does not exceed more than 25%of the data for any one-month period.
2. If a daily measurement is not available during a period that the SCR is operational, and the
missing data exceeds more than 25% of the data for any one-month period, no control
efficiency shall be assumed for that day.
3. Inspection and Maintenance Requirements -To comply with the provisions of this permit and
ensure that emissions do not exceed the regulatory limits, the Permittee shall establish an
inspection and maintenance (I&M) schedule/checklist for the SCR based on manufacturer's
recommendations. As a minimum, the I&M program will include an annual inspection of the
burners,catalyst,the catalyst housing,and associated ducting to ensure structural integrity.
Operating hours for the SCR, Over-cladding Units, SCR control efficiency calculations, NOx
emission calculations, inspection/calibration/maintenance of the NOx analyzers, inspection and
maintenance of the SCR, and the total monthly amount of NOx emissions must be recorded in an
emissions log. The Permittee shall make the log available to officials of the DAQ upon request. The
emissions log must be kept on file for a minimum of five years. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D.0530 if records are not maintained.
Renortin2 Reguirements[15A NCAC 2Q .0508(f)]
j. Submit a semiannual summary report, acceptable to the Regional Air Quality Supervisor, 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. The report shall contain the following:
i. Monthly NOx emissions for each of the previous 17 calendar months; and,
ii. 12-month rolling NOx emissions for each consecutive 12-month period ending in the previous six
months.
C. Cells 5, 6, and 7 Equipment consisting of:
Chemical Vapor Deposition Process Hoods (ID No. ES-2); and,
Over-cladding Units (ID No.ES-9a and cell 5 units in ES-9).
Two 8.0 million Btu per hour heat input natural gas-fired boilers;
Two 10.0 million Btu per hour SCR flue gas re-heaters; and,
Two 1.0 million Btu per hour SCR ammonia injector dilution air heaters.
The following provides a summary of limits and/or standards for the emission sources described above.
11 Regulated Pollutant Limits/Standards I Applicable Regulation
Permit 07334T27
Page 17
Nitrogen Oxides Total emissions of nitrogen oxides shall be less 15A NCAC 2Q .0317
than 250 tons per consecutive 12-month period. PSD Avoidance
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D. 0530: PREVENTION OF
SIGNIFICANT DETERIORATION
a. The nitrogen oxides emissions increase due to equipment operation shall be less than 250 tons per
consecutive 12-month period. The Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530 if NOx emissions exceed this limit.
Control Requirements
b. To ensure compliance with the above emissions limits, nitrogen oxides from Over-cladding Units
contained in Cells 5, 6,and 7 shall be controlled by:
i. A fabric filter with hydrated lime injection(ID No.2DS),or
ii. A fabric filter with hydrated lime injection (ID No. 2DS) in series with a selective catalytic NOx
reduction system(ID No.2SCR).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions are not
controlled as provided above.
Testing Requirements [15A NCAC 2Q .0508(f)]
c. New Technology Over-cladding Units
i. NOx uncontrolled emissions from individual new technology torch Over-cladding Units (Cells 5,
6, and 7,ES-9a) shall be tested to determine emission rates in pounds of NOx per unit-hour to be
used in demonstrating compliance with the PSD avoidance condition.
ii. The test results must be submitted to the Regional Supervisor within 120 days (or alternate date
approved by DAQ)from the commencement of operation of the Over-cladding Unit(ID No.9a).
iii. Uncontrolled over-cladding emission rates must be revalidated annually.
The Permittee shall be deemed in noncompliance with 15A NCAC 21) .0530 if NOx emissions from
these sources are not tested and validated as provided above.
d. Dry Scrubber System Lime Injection and Fabric Filter)
i. NOx emissions from Over-cladding Units (Cells 5, 6, 7; ID No. ES-9a) prior to and after the dry
scrubber control (ID Nos. 2DS) shall be tested to determine dry scrubber control efficiency to be
used in demonstrating compliance with the PSD avoidance condition.
ii. The test results must be submitted to the Regional Supervisor within 120 days (or alternate date
approved by DAQ)from the commencement of operation of the Over-cladding Unit(ID No.9a).
ill. Control efficiency of the dry scrubber system (lime injection and fabric filter) must be revalidated
annually and each time the type of filter material is changed unless the Permittee assumes no fabric
filter control for the purposes of compliance demonstration until further DAQ approved testing is
conducted.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions from
these sources are not tested and validated as provided above.
e. SCR System
i. NOx emissions from Over-cladding Units(Cells 5, 6,7; ID No.ES-9a)shall be tested prior to and
after the SCR controls (ID Nos. 2SCR) to validate the data generated by the continuous NO and
NO2 emission analyzers. The control efficiency calculated from the test and the analyzers at the
time of the test shall be within 5%to validate the analyzers.
ii. Initial validation test results for SCR control efficiency must be submitted to the Regional
Supervisor, within 120 days(or alternate date approved by DAQ)of SCR(ID Nos.2SCR)startup.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions from
these sources are not tested as provided above.
Permit 07334T27
Page 18
f. General
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 C. La above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring and Recordkeeping Requirements
g. Continuous NO and NO2 emission analyzers shall be installed upstream and downstream of each SCR
(ID Nos. 2SCR) to monitor emissions from the Over-cladding Units (ID No. ES-9a) venting to and
from each selective catalytic NOx reduction system(ID Nos.2SCR).
i. Analyzers shall be calibrated daily.
ii. Measurements of NO and NO2 shall be recorded after calibration at the inlet and outlet monitors.
iii. NO and NO2 concentrations at the inlet shall be summed and NO and NO2 concentrations at the
outlet shall be summed for the determination of a daily control efficiency.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if NOx emissions are not
monitored as provided above.
h. Calculation of monthly NOx emissions shall be made at the end of each month. Monthly NOx
emissions shall be determined by adding calculated emissions from the chemical vapor deposition
process hoods (ID No. ES-2), the Over-cladding Units (ID No. ES-9a) in Cells 5, 6, and 7 including
dry scrubber NOx control efficiency,if applicable,and the SCR control efficiency for periods when the
selective catalytic NOx reduction system was used, four boilers (two at 8.0 million Btu per hour heat
input and two 8.76 million Btu per hour heat input),two SCR flue gas re-heaters(each 10.0 million Btu
per hour heat input), and two SCR ammonia injector dilution air heaters(each 1.0 million Btu per hour
heat input)as follows:
i. NOx emission from CVD process hoods ( ID No. ES 2) shall be determined by multiplying
operating hours for CVD units during the month by the pounds of NOx per unit-hour determined
from source testing required by 2.2 B.Lb.
ii. NOx emissions from boilers and SCR heaters shall be determined using current EPA AP-42
emissions factors and actual heat input rates.
iii. Uncontrolled NOx emission from Over-cladding Units (ID No. ES 9a) shall be determined by
multiplying operating hours for Over-cladding Units by the uncontrolled pounds of NOx per unit-
hour determined from source testing.
iv. Inclusion of Dry Scrubber Emissions Reductions
(A) Calculation of NOx emissions may include dry scrubber emissions reductions using the control
efficiency measured during source testing for the type of filter employed at the time of testing.
(B) The control efficiency for the dry scrubber determined by DAQ approved testing is valid:
1. If the NOx uncontrolled loading rate to the fabric filter which occurred during the testing
required by 2.2.C.Lb is exceeded by no more than 25 percent, and
2. The lime injection rate is at or above the injection rate measured and recorded during the
performance testing required by 2.2.C.1.b.
v. Inclusion of SCR Emissions Reductions
(A) Calculation of NOx emissions may include SCR emissions reductions during SCR operating
periods. The daily control efficiency determined in accordance with 2.2 C.l.c.i.(C) shall be
used to reduce the amount of uncontrolled emissions calculated per 2.2 C.l.c.ii.(C) on a daily
basis.
1. If a daily measurement is not available during a period that the SCR is operational,the last
available measurement shall be used in place of the missing data provided that the missing
data does not exceed more than 25%of the data for any one-month period.
2. If a daily measurement is not available during a period that the SCR is operational,and the
missing data exceeds more than 25% of the data for any one-month period, no control
efficiency shall be assumed for that day.
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Page 19
vi. Inspection and Maintenance Requirements - To comply with the provisions of this permit and
ensure that emissions do not exceed the regulatory limits, the Permittee shall establish an
inspection and maintenance (I&M) schedule/checklist for the SCRs based on manufacturer's
recommendations. As a minimum, the I&M program will include an annual inspection of the
burners,catalyst,the catalyst housing,and associated ducting to ensure structural integrity.
Operating hours for the SCR, Over-cladding Units, SCR control efficiency calculations,NOx emission
calculations, inspection/calibration/maintenance of the NOx analyzers, inspection and maintenance of
the SCRs, and the total monthly amount of NOx emissions must be recorded in an emissions log. The
Permittee shall make the log available to officials of the DAQ upon request. The emissions log must
be kept on file for a minimum of five years. The Permittee shall be deemed in non-compliance with
15A NCAC 2D .0530 if records are not maintained.
Reporting Requirements
i. Submit a semiannual summary report,acceptable to the Regional Air Quality Supervisor,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. The report shall contain the following:
i. Monthly NOx emissions for each of the previous 17 calendar months; and,
ii. 12-month rolling NOx emissions for each consecutive 12-month period ending in the previous six
months.
D. Chemical Vapor Deposition Units (ID No. ES-1),
Gas Cabinets (ID No. ES-4), and Collapse Furnaces (ID No. ES-14) consisting of.
Cells 5,6, and 7 with Wet Scrubber(ID No.3WS); and,
Over-cladding Units (ID No. ES-9) consisting of:
Cells 4, and some cell 5 units venting to Hydrated Lime Injection Dry Scrubber Fabric
Filter System (ID No. IDS) that vents to a Selective Catalytic NOx Reduction System(ID
No. 1 SCR).
Over-cladding Units (ID No. ES-9a) consisting of:
Cells 6, 7, and remaining cell 5 units venting to Hydrated Lime Injection Dry Scrubber
Fabric Filter System (ID No. 2DS) that vents to a Selective Catalytic NOx Reduction
System(ID No.2SCR); and,
Chemical Room(ID No. ES-11)with Wet Scrubber System(ID No. 3WS); and,
SiC14 Storage Room(ID No. 18)with Wet Scrubber System(ID No. 3WS).
The following provides a summary of limits and/or standards for the emission sources described above.
Regulated
Pollutant Limits/Standards Applicable Regulation
STATE-ONLY REOUIREMENT
Emissions of HC1,C12,HF,and NH3 must be emitted
at or below the emission rates tabulated in the next
table in order to comply with the following
Toxic Air acceptable ambient levels.
Pollutants 15A NCAC 2D.1100
HCI: 0.7 milligrams/cubic meter- lhr
C12: 0.9 milligrams/cubic meter- 1 hr and
0.0375 milligrams/cubic meter-24 hr
HF: 0.25 milligrams/cubic meter- lhr
Permit 07334T27
Page 20
Regulated
Pollutant Limits/Standards Applicable Regulation
0.03 milligrams/cubic meter-24 hr
NH3: 2.7 milligrams/cubic meter- lhr
STATE-ONLY REQUIREMENT
1. 2D.1100"CONTROL OF TOXIC AIR POLLUTANTS"
Emission Limits and Control Requirements
Affected Sources Pollutant Emission Limit
EP-11: Wet Scrubber#1 (ID No.3WS)
Envirocare#1 Hydrogen Chloride 9.063 lb/hr
Includes emission from:
Cells 5, 6, and 7 CVD (ID Nos. ES-1) Chlorine 5.582 lb/hr; and, 133.97 lb/day
Cells 5, 6, and 7 GC(ID No.ES-4),
Cells 5, 6 and 7 CF (ID No. ES-14) Chlorine 1.192 lb/hr; and, 28.61 lb/day
Chemical Room(ID No.ES-11)
SiC14 Storage Room(ID No.ES-18)
EP-18: dry scrubber(ID No. 1DS) or
EP-21: SCR(ID No. 1SCR) Hydrogen Fluoride 4.483 lb/hr; and, 107.59 lb/day
Cells 4, and some cell 5 OC units(ID No.
ES-9)
EP-19: dry scrubber#1 (ID No.2DS)or
EP-21: SCR(ID No.2SCR) Hydrogen Fluoride 3.202 lb/hr; and, 76.85 lb/day
Cells 6, 7, and remaining cell 5 OC units
(ID No. ES-9a)
EP-21 combined stack for SCRs Ammonia 1.584 lb/hr per SCR
a. Emissions from the CVD processes will be controlled by the scrubber(ID No.3WS).
b. Emissions from the Over-cladding Units (ID Nos. ES-9 and ES-9a) shall be controlled by two fabric
filters each with hydrated lime injection(ID Nos. 1DS and 2DS).
Testin
c. A stack test is required for Hydrogen Chloride, Chlorine,Hydrofluoric Acid as per condition 2.2 A.Lb
above acid in order to determine emissions factors for monitoring, recordkeeping and reporting
purposes. If the results of this test are above the limit given in Section 2.1 D. 1 above, the Permittee
shall be deemed in noncompliance with 15A NCAC 2D.1100.
Monitoring,Recordkeeping and Reporting [15A NCAC 2Q .0508(f)]
d. Monitoring, recordkeeping,and reporting pertain to inspection and maintenance of control devices and
parametric monitoring to ensure control efficiencies. These are addressed above in 2.1 A.l.a.ii-ix. and
2.1 A.l.c.ii-vi.
e. Continuous emission analyzers for ammonia emissions from the selective catalytic NOx reduction
systems (ID Nos. 1SCR and 2SCR) shall be inspected and maintained in accordance with the
Permit 07334T27
Page 21
manufacturer's recommendations. As a minimum,the instruments shall be calibrated daily. Records of
calibrations, inspections, and maintenance shall be kept in a logbook and maintained on site. Records
shall be made available to the DAQ personnel upon request. All required records on file for a
minimum of two years.
Permit 07334T27
Page 22
2.3 - Compliance Assurance Monitoring (CAM; 40 CFR Part 64)
A. One Venturi Scrubber(ID No.3WS)
1. 15A NCAC 2D.0614: Continuous Assurance Monitoring for venturi scrubber(ID No.3WS)
a. The Permittee shall ensure that S02 and HF emitted from the chemical vapor deposition units(ID No.
ES-1) is controlled by venturi scrubber (ID No. 3WS) by monitoring the following operating
parameters:
i. Pressure drop across the scrubber,and
ii. Scrubber water flow rate.
Testing
b. A stack test is required for hydrofluoric acid (HF) as per condition 2.2 A.l.b above in order to
determine emissions factors for monitoring,recordkeeping and reporting purposes.
Monitoring Approach -The key elements of the monitoring approach are presented in the following
table.
c. Pressure drop across the scrubber and water flow rate.
Indicator#1 Indicator#2
Pressure drop across the scrubber. Scrubber water flow rate.
pH of scrubber water.
Measurement Pressure drop across the scrubber will Amount of caustic solution will be
Approach be monitored with a differential monitored as well as pH of caustic
pressure gauge. solution.
An excursion is defined as an hourly An excursion is defined as a flow rate
average differential pressure (DP) less reading less than 90 gallons per minute
Indicator Range than 10 inches of water pressure drop (GPM) or pH of less than 8 (or as
or more than 15 inches of water
determined by future test data)
pressure drop.
The QIP threshold is an excursion The QIP threshold is an excursion
occurring at any time if the total occurring at any time if the total
duration of the excursions is greater duration of the excursions is greater
QIP Threshold than 5% of the total scrubber operating than 5% of the total scrubber operating
time during the reporting period. An time during the reporting period. An
excursion triggers an inspection, excursion triggers an inspection,
corrective action, and a reporting corrective action, and a reporting
requirement. requirement.
Performance Differential pressure taps are located The flow meter can be installed at any
Criteria: at the scrubber's inlet and outlet at the point on the water line since the flow
Data venturi section of the scrubber. will be consistent throughout this line.
Representativeness
Verification of Pressure drop within the Indicator Flow rate above the Indicator Range
Operational Status Range indicates normal operation of indicates normal operation of the
the scrubber. scrubber.
Daily zero checks to verify gauge
QA/QC Practices operability. The pressure gauge is The flow meter is calibrated annually
and Criteria calibrated monthly using a second based on manufacturer's instructions.
gauge and the gauge is replaced when
the difference exceeds 5%.
Permit 07334T27
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Monitoring Measured every 24-hour period.
Frequency Measured every 24 hour period pH measured continuously and
recorded manually.
Data Collection Manually, once per day. Manually, once per day.
Procedure
Averaging Period 24 hour 24 hour
Recordkeeping [15A NCAC 2Q .0508(f), 40 CFR 64.9]
d. The Permittee must maintain the following records on a monthly basis in accordance with the
requirements of 40 CFR 64:
i. Records specified in 40 CFR 64 of all measurements of operating parameters including:
(a) Date and time of any corrective action taken.
Reporting [15A NCAC 2Q .0508(f), 40 CFR 64.9]
e. The Permittee shall submit a summary report of all monitoring 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.
The report shall also include the following information, as applicable:
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 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.
B. One Fabric Filter with Hydrated Lime Injection (ID No. IDS)
1. 15A NCAC 2D .0614: Continuous Assurance Monitoring for fabric filter with hydrated lime
injection(ID No. IDS)
a. The Permittee shall ensure that PM and HF emitted from the Over-cladding Units (ID No. ES-9) is
controlled by a fabric filter(ID No. 1DS)by monitoring the following operating parameters:
i. Pressure drop across the fabric filter,and
ii. Lime injection rate.
Testing
b. None.
Monitoring Approach -The key elements of the monitoring approach are presented in the following
table.
c. Pressure drop across the scrubber and water flow rate.
Indicator#1 Indicator#2
Pressure drop across the fabric filter. Lime injection rate.
Measurement Pressure drop across the fabric filter will Amount of lime will be monitored
Approach be monitored with a differential pressure using batch hopper.
Permit 07334T27
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gauge.
An excursion is defined as an hourly
average differential pressure (DP) less An excursion is defined as an
Indicator Range than 0.1 inches of water pressure drop or injection rate reading less than 30
more than 9 inches of water pressure pounds per hour.
drop.
The QIP threshold is an excursion The QIP threshold is an excursion
occurring at any time if the total duration occurring at any time if the total
of the excursions is greater than 5% of duration of the excursions is greater
QIP Threshold the total fabric filter operating time than 5% of the total scrubber
during the reporting period. An operating time during the reporting
excursion triggers an inspection, period. An excursion triggers an
corrective action, and a reporting inspection, corrective action, and a
requirement. reporting requirement.
Performance The injection rate can be is set to
Criteria: Differential pressure taps are located at feed 30 dry pounds per hour and is
Data the fabric filter inlet and outlet.
verified once per 24-hour period.
Representativeness
Verification of Pressure drop within the Indicator Range Flow rate above the Indicator Range
Operational Status indicates normal operation of the fabric indicates normal operation of the
filter. lime injection system.
Daily zero checks to verify gauge
QA/QC Practices operability. The pressure gauge is The flow meter is calibrated
and Criteria calibrated monthly using a second gauge annually based on manufacturer's
and the gauge is replaced when the instructions.
difference exceeds 5%.
Monitoring Continuous Measured every 24 hour period
Frequency
Data Collection Manually, once per day. Manually, once per day.
Procedure
Averaging Period I N/A 1 24 hour
Recordkeeping [15A NCAC 2Q .0508(f),40 CFR 64.9]
d. The Permittee must maintain the following records on a monthly basis in accordance with the
requirements of 40 CFR 64:
i. Records specified in 40 CFR 64 of all measurements of operating parameters including:
(a) Date and time of any corrective action taken.
Reporting [15A NCAC 2Q .0508(f), 40 CFR 64.9]
e. The Permittee shall submit a summary report of all monitoring 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.
The report shall also include the following information, as applicable:
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 downtime incidents(other than downtime associated with zero and span or
other daily calibration checks,if applicable); and
Permit 07334T27
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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. One Fabric Filter With Hydrated Lime Injection (ID No. 2DS)
1. 15A NCAC 2D .0614: Continuous Assurance Monitoring for fabric filter with hydrated lime
injection
(ID No.2DS)
a. The Permittee shall ensure that PM and BF emitted from the Over-cladding Units (ID No. ES-9a) is
controlled by a fabric filter(ID No.2DS)by monitoring the following operating parameters:
i Pressure drop across the fabric filter,and
ii. Lime injection rate.
Testing
b. None.
Monitoring Approach - The key elements of the monitoring approach are presented in the following
table.
c. Pressure drop across the scrubber and water flow rate.
Indicator#1 Indicator#2
Pressure drop across the fabric filter. Lime injection rate.
Measurement Pressure drop across the fabric filter will Amount of lime will be monitored
Approach be monitored with a differential pressure using batch hopper.
gaug
An excursion is defined as an hourly An excursion is defined as an
Indicator Range average differential pressure (DP) less injection rate reading less than 30
than 0.1 inches of water pressure drop or
more than 9 inches of water pressure dro Pounds per hour.
The QIP threshold is an excursion
The QIP threshold is an excursion occurring at any time if the total
occurring at any time if the total duration duration of the excursions is
of the excursions is greater than 5% of the greater than 5% of the total
QIP Threshold total scrubber operating time during the scrubber operating time during the
reporting period. An excursion triggers an reporting period. An excursion
inspection, corrective action, and a triggers an inspection, corrective
reporting requirement. action, and a reporting
requirement.
Performance The injection rate can be is set to
Criteria: Differential pressure taps are located at feed 30 dry pounds per hour and is
Data the fabric filter inlet and outlet. verified once per 24-hour period.
Representativeness
Verification of Pressure drop within the Indicator Range Flow rate above the Indicator
Operational Status indicates normal operation of the fabric Range indicates normal operation
filter. of the lime injection system.
Daily zero checks to verify gauge The flow meter is calibrated
and Criteria Practices operability. The pressure gauge is annually based on manufacturer's
and Cr calibrated monthly using a second gauge instructions.
Permit 07334T27
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and the gauge is replaced when the
difference exceeds 5%.
Monitoring Continuous. Measured every 24-hour period.
Frequency
Data Collection Manually, once per day. Manually, once per day.
Procedure
Averaging Period N/A 24 hour
Recordkeeping [15A NCAC 2Q .0508(f), 40 CFR 64.9]
d. The Permittee must maintain the following records on a monthly basis in accordance with the
requirements of 40 CFR 64:
i. Records specified in 40 CFR 64 of all measurements of operating parameters including:
(a) Date and time of any corrective action taken.
Reporting [15A NCAC 2Q .0508(f), 40 CFR 64.9]
c. The Permittee shall submit a summary report of all monitoring 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.
The report shall also include the following information, as applicable:
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 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.
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SECTION 3 - GENERAL CONDITIONS (version 3.6 01/31/12)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in
15A NCAC 2D and 2Q.
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 2Q .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 Environment and Natural Resources upon request.
C. Severability Clause [15A NCAC 2Q .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 2Q .0507(e) and 2Q .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
Permit 07334T27
Page 28
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this
permit).
E. Duty to Comply [15A NCAC 2Q .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
1. Administrative Permit Amendments[15A NCAC 2Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with
15A NCAC 2Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q
.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC
2Q.0524 and 2Q .0505.
3. Minor Permit Modifications [I 5A NCAC 2Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A
NCAC 2Q .0515.
4. Significant Permit Modifications [15A NCAC 2Q .0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A
NCAC 2Q .0516.
5. Reopening for Cause [15A NCAC 2Q .0517]
The Pennittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q
.0517.
H. Changes 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 I 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 2Q.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
Permit 07334T27
Page 29
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
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 2Q .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 2Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently adopted
maximum achievable control technology standards,emissions trading shall be allowed without permit
revision pursuant to 15A NCAC 2Q .0523(c).
I.A.Revortim Requirements for Excess Emissions and Permit Deviations
[15A NCAC 2D .0535(f)and 2Q .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 21);or by a permit condition;
or that exceeds an emission limit established in a permit issued under 15A NCAC 2Q .0700. (Note.-
Definitions of excess emissions under 2D.1110 and 2D.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 2D.0524),NESHAPS
(15A NCAC 2D .1110 or.I 111),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 2D .0524),NESHAPS (15A NCAC 2D .1110 or
.1111), or these rules do NOT define"excess emissions,"the Permittee shall report excess emissions in
accordance with 15A NCAC 2D .0535 as follows:
a. Pursuant to 15A NCAC 2D .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
Permit 07334T27
Page 30
• 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 2D .0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 2Q .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 2D.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 2D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535,
including 15A NCAC 2D .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 2D.0535(c)(1)through(7).
2. 15A NCAC 2D .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. Emergency 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 2Q .0508(e)and 2Q.0513(b)]
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This 15A NCAC 2Q .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
2Q .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 2Q .0512(b)(1), this 15A NCAC 2Q .0500 permit
shall not expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC
2Q .0400 terminates the facility's right to operate unless a complete 15A NCAC 2Q .0400 renewal
application is submitted at least six months before the date of permit expiration for facilities subject to 15A
NCAC 2Q .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.
L. Need to Halt or Reduce Activity Not a Defense[15A NCAC 2Q .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 2Q .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 2Q .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 2Q .0508(f)and 2Q .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 2Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region
4, 61 Forsyth Street,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 114(a)(3) or 504(b)of the Federal Clean Air Act. The compliance certification
shall specify:
1. 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
Permit 07334T27
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4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 2Q .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 2Q .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.
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 2Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515.
S. Termination,Modification,and Revocation of the Permit [15A NCAC 2Q .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. Insignificant Activities [15A NCAC 2Q .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 2Q .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 2Q .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;
Permit 07334T27
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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 2Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C.Department of
Environment and Natural Resources. 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 2Q .0519.
X. Annual Emission Inventory Requirements [15A NCAC 2Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A
NCAC 2Q .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 2Q .0107 and 2Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q
.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 2Q .0107.
Z. Construction and Operation Permits [15A NCAC 2Q .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 2Q.0100 and
.0300.
AA.Standard Application Form and Required Information [15A NCAC 2Q .0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A
NCAC 2Q .0505 and .0507.
BB. Financial Responsibility and Compliance History [15A NCAC 2Q .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 2Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment,including air conditioning equipment,which
use Class I or H 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,
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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 2Q .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.
FF. Title IV Allowances [15A NCAC 2Q .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 2D .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 2D .0300.
HH.Registration of Air Pollution Sources [15A NCAC 2D .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 2D .0202(b).
11. Ambient Air Quality Standards [15A NCAC 2D .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 21) .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 2Q .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 2D. 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 2D.2600 and follow
the procedures outlined below:
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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.
(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 2D .2600 has precedence
over all other tests.
KK.Reopening for Cause [I 5A NCAC 2Q .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 N;
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 2Q .0513(c).
3. Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 2Q
.0507, .0521,or.0522 shall be followed to reissue the permit. If the State-enforceable only portion of
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the permit is reopened,the procedures in 15A NCAC 2Q .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 2Q .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 2D .0540] -STATE ENFORCEABLE ONLY
As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources,"the Permittee
shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust
emissions from the facility are observed beyond the property boundaries for six minutes in any one hour
(using Reference Method 22 in 40 CFR,Appendix A),the owner or operator may be required to submit a
fugitive dust plan as described in 2D.0540(f).
"Fugitive dust emissions"means particulate matter 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).
NN. Specific Permit Modifications [15A NCAC 2Q.0501 and .0523]
1. For modifications made pursuant to 15A NCAC 2Q .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 2Q .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 2Q .0523(a)(1)(C),
the Permittee shall notify the Director and EPA(EPA-Air Planning Branch, 61 Forsyth St.,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.
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00. Third Party Participation and EPA Review [15A NCAC 2Q.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 2Q .0518 begins at the end of the 45-day EPA review period.
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ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CAA Clean Air Act
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
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
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
SIC Standard Industrial Classification
SIP State Implementation Plan
SOz Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound.