HomeMy WebLinkAboutAQ_F_0800044_20141219_PRMT_Permit A
hNCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarfa, ill
Governor Secretary
December 19, 2014
Dr. David M. Peele,Ph.D.
President
Avoca Incorporated
P.O. Box 129
Merry Hill, North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T43
Facility ID: 0800044
Avoca Incorporated
Merry Hill, Bettie County,North Carolina
Fee Class: Title V
Dear Dr. Pecle:
In accordance with your completed Air Quality Permit Application for a 17li..nor tnodil"ication to your Title
V permit under 15A NCAC 02D .05I5 received September 22, 2014, we are forwarding herewith Air Quality
Perntit No. 01819T43 to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, 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 cerrtification 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.
These emission sources (Ill Nos. ES-M-125A and 125B, E104, and ES-TIC-PNE-1) 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 February 19, 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).
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q .0504 for
the SFG operations on or before 12 months after commencing operation.
The Permittee shall notify the Director and EPA with written notification at least seven days before the
"change is made" pursuant to 15A NCAC 2Q .0523(a)(1)(C) for the air emission source(s) (ID No. ES-MSDU-
1024).
As the designated responsible official it is your responsibility to review, understand, and abide by all of the
terms and conditions of the attached pennit. It is also your responsibility to ensure that any person who operates
any emission source and associated air pollution control device subject to any tern or condition of the attached
permit reviews, understands, and abides by the condition(s) of the attached pen-nit that are applicable to that
particular emission source.
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
Phone:919-707-8400l Internet:www.ncdenr.gov
An Equal 4ppartunil 1 Affirmative Action Employer—Made in part with recycled paper
Mr.David M. Peele, Ph.D.
December 19, 2014
Page 2
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you, you
have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit,identifying
the specific issues to be contested. 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 fonn 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 regnest 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
150E-22. This request must be submitted in writing to the Director and must identify the speeific provisions or
issues for which the modification is sought. Please note that this Air Quality Permit will become final and
binding regardless of a request for informal modification unless a request for a hearing is also made under
NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control device(s), or
modifications to the emission source(s) and air pollution control device(s) described in this permit must be
covered under an Air Quality Permit issued by the Division of Air Quality prior to construction unless the
Pennittee has fulfilled the requirements of GS 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 GS 143-215.108A and may subject the
Penmittee to civil or criminal penalties as described in GS 143-215.114A and 143-215.114B.
This Air Quality Permit shall be effective from December 19, 2014 until July 31, 2015, is nontransferable
to future owners and operators, and shall be subject to the conditions and limitations as specified therein.
Should you have any questions concerning this matter,please contact Kevin Godwin at(919) 707-8480.
Sincerely yours,
William D.Willets,P.L.,Chief,Permitting Section
Division of Air Quality,NCDF.NR
Enclosure
c; Rob Fisher, Supervisor,Washington Regional Office
Heather Ceron, EPA Region 4
Central Files
Insignificant Activities under 15A NCAC 2Q.0503(8)
Emission Control Device Control Device
Source I No. Emission Source Description ID No. Dencri tion
IWWTP-ET] Wastewater treatment plant equalization tank NIA NIA
No. 1 (65,500 gallon capacity)
IW WTP-ET2 Wastewater treatment plant equalization tank NIA NIA
No.2 65,500 gallon capacity)
Wastewater treatment plant aeration tank No.2
IW WTP-AT2 (63,500 Ion capacity)
NIA NIA
Wastewater treatment plant aeration tank No. 3
IWWTP-AT3 (63,500 gallon capacity)
MIA NIA
IWWTP CLR Wastewater treatment plant clarifier(1,310 NIA NIA
gallon capacity)
rFK9238 No. 2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
ITKIO2 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
ITK103 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
ITKFP No.2 fuel oil storage tank(270 gallon NIA N/A
capacity)
One water spray fume
CD-Z-92I 5 scrubber(0.5 gallons
per minute minimum
water injection rate)
tECS ECS process:batch preparation of venting to
ethylenediaminel copper sulfate solution CD-Z-9216
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
IES-PV Propane vaporizer NIA NIA
I-Briquette Sage Briquetting Machine N/A NIA
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable
requirement or that the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in
determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100
"Control of Toxic Air Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and MACT ZZZZ see the NC DAQ
web site: littp:IId aq.st ate.n c.us,,toxi e slarea s ource sl.
The following table 2anjdcs a summmy of the changes in Permit No. 01 M 9T43.
Page No. Condition Description of Change(s)
Included language pertaining to minor modification under I5A NCA.0
NIA Cover letter 02Q .0515 for tanks (ID Nos.ES-M-125A and 125B,and ES-TK-PNE-
1}.
Global Global Updated permit number.permit format, and dates.
Table of - ljpdated'tank size to 19,500 gallons-capacity each for ES-M-i 25A
3 Emission and 125B,
Sources - Removed NSPS Kb designation for these tanks,
- Included one chilled water condenser "ID No,C-D 30023
QId page 2 1 C.2. Removal condition pertaining to l5A NCAC 0524 NSPS Subpart Kb
No. 15 for new tanks.
State of North Carolina, 4 so
Department of Environment, �►.•��
and Natural Resources NCDENR
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T43 01819T42 December 19, 2014 July 31, 2015
Until .such time as this permit expires or is modified or revoked, the below named Permittee is authorized to
construct and operate the emission source(s) and associated air pollution eontrol device(s) specified herein, in
accordance with the terms, conditions, and limitations within this pernut. 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 prodded in this permit.
Permittee: Avoca, Inc,
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County,State,Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.U.Box 129
City, State,Zip: Merry Hill,NC 27957
Application Number: 0800044.14E
Complete Application Date: September 22, 2014
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington, NC 27889
Permit issued this the 19"' day of December, 2014.
U
William D. Willets,P.E.,Chief,Permitting Section
By Authority of the Environmental Management Commission
Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S)AND APPIJRTENANCES
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 PERMrF CONDITIONS
ATTACHMENTS
ATTACHMENT 1 List of Acronyms
Permit 01819T43
Page 3
SECTION I - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of ail pernutted emission sources and associated air pollution control devices and
appurtenances:
Emission Source Control Device Control Device
ID No. Emission Source Description 7 ID No. Description
Rotocel Operations
CD-31209 One chilled water
condenser venting to
ES-1001-2-1-P1
PSD Rotocel extractor, desolventizer, and CD-1001-2-S-1 One packed tower
CAM solvent separation/recovery scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
CD-1001-2-C-1 One chilled water
condenser venting to
ES-M-125A and
M-125B**** Two storage and recycle tanks(19,500 CD-1001-2-S-1 ' One packed tower
MACT FFFF gallons capacity each) scrubber(8 gallons per
minute minimum
mineral oil injection
rate)
ES-1001-2-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-2-1-
W W Rotocel Operations wastewater stream NA NA
PSD
MACT FFFF
Recovery Operations
CD-1001-1-3 One chilled water
condenser venting to
ES-1001-1-1-P1
PSD Arcon process tank M-1 CD-1001-2-S-1 ' One packed tower
CAM scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-1-1-P2 CD-1001-1-T513 One chilled water
PSD Stripper T-5 and receiver M-21 condenser venting to
CAM
MACT FFFF CD-1001-2-S-1 ' One packed tower
ES-1001-1-1-P3 Seven process tanks of various capacities scrubber(8 gallons per
PSD and one fixed roof methanol storage tank minute minimum
MACT FFFF (7,050 gallon capacity) mineral oil injection
rate)
Permit 01819T43
Page 4
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
ES-1001-1-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-1-1-
W W Recovery Operations wastewater stream NA NA
PSD
MALT FFFF
Concrete Operations
ES-1001-1-2-P One PSD Six process tanks of various capacities CD-1001-1-2 chilled water
con
MALT FFFF condenser
H13-1 One steam-heated hot hox NA NA
MACT FFFF
HB-2 One steam-heated hot box NA NA
MACT FFFF
HB-3 One steam-heated hot hox NA NA
MACT FFFF
1413-4 One steam-healed hot box NA NA
MACT FFFF
ES-1001-1-2-F process equipment leaks NA NA
MACT FFFF
ES-1001-1-2-
WW Concrete Operations wastewater stream NA NA
MACT FFFF
Sclareol Recrystallization(SFG)Operations"
T-3001 One hexane storage tank(6,700 gallon
MACT FFFF capacity) NA NA
-33002 through Four process tanks(2,500 gallons capacity3005 NA NA
MACT FFFF each)
ES-1003-10-F process equipment leaks NA NA
MACT FFFF
C-3001 One centrifuge NA NA
MACT FFFF
R-3001 One reactor equipped with a chilled water NA NA
MACT FFFF process condenser EX-3001)
R-3002 One reactor equipped with a chilled water
MACT FFFF process condenser(EX-3003) CD-3002 One chilled water
condenser in series
D-3001 One steam-heated dryer equipped with a with,
MACT FFFF chilled water process condenser(EX-3002) CD-3001 One chilled water
condenser
ES-1003-10-WW SFG Process wastewater stream NA NA
MACT FFFF
Biological Conversion Equipment for Purification of Sclareolide
Permit 01819T43
Page 5
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
ES-1001-1-3-P Twelve process tanks of various capacities NA NA
MACT FFFF
G-17
MACT FFFF One centrifuge NA NA
ES-1001-1-3-F process equipment leaks NA NA
MACT FFFF
D-1202 One steam-heated dryer NA NA
MACT FFFF
A-2 One distillation column(6 gallons per
NA N11
MACT FFFF minute nominal process rate)
ES-1001-1-3- Biological conversion equipment for
W W purification of selarcolide wastewater NA NA
MACT FFFF stream
Sclarcolide(SDE) Operations
ES-1001-1-4-P Four process tanks of various capacities NA NA
MACT FFFF
M-20 One acetic acid storage tank(10,135 gallon
MACT FFFF capacity)
NA NA
ES-1001-1-4-F process equipment leaks NA NA
MACT FFFF
M-]0
MACT FFFF One batch reactor
M-10A One venturi-type wet
MACT FFFF One batch reactor scrubber(10 gallons
D-1231A CD-M-34 per minute minimum
MACT FFFF One batch reactor liquid injection rate)
D-123113 One batch reactor
MACT FFFF
ES-1001-1-4-
WW SDE Operations wastewater stream NA NA
MACT FFFF
Plant Nutrient Extraction(PNE) Operations
EX2203 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0,5 gallons
D31214 per minute minimum
MACT FFFF One product extract reactor water injection rate)
venting to
CD-Z-921 fi a
One water spray fume
scrubber(0.5 gallons
Per minute minimum
water injection rate)
Permit 01819T43
Page 6
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
EX2205 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons
D31211 One waste solids separator vessel(1,333 per minute minimum.
MACT FFFF gallon capacity) water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
ES*TK-PNE-I Solvent Process Tank(9,500 gallons
NA NA
MACT FFFF
capacity
F,S-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
ES-1003-2-1-
WW PNE process wastewater stream NA NA
MACT FFFF
CD-Z-9215 2 One water spray fume
ES-1003-2-1-P Seven process tanks of various capacities scrubber(0.5 gallons
MACT FFFF per minute minimum
water injection rate)
venting to
CD-Z-9216'
C-31203 One centrifuge One water spray fume
MACT FFFF scrubber(0.5 gallons
per minute minimum
water injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
D-2202 CD-Z-9215 One water spray fume
MACT FFFF One reactor scrubber(0.5 gallons
D 1215 One reactor per minute ininimum
MACT FFFF water injection rate)
D-1218 venting to
MACT FFFF One reactor CD-Z-9216
One water spray fume
D-120] scrubber(0.5 gallons
MACT FFFF One steam-heated dryer per minute minimum
water injection rate)
ES-1003-2-2-F process equipment leaks NA NA
MACT FFFF
ES-1003-2-2-
WW EVG Operation wastewater stream NA NA
MACT FFFF
Permit 01819T43
Page 7
Emission Source Control Device Control Device
11)No. Emission Source Description lD No. Descri lion
Botanical Extraction Operations
CD-1001-11- One chilled water
Immersion extractor Z-1001, EX1002 condenser venting to
ES-1001-11-P desolventizerZ-1002,
PSD day tank 90024(6,000 gallon capacity), One cryogenic
CAM first-stage evaporator EX-1012, CD-1001-11- (nitrogen)condenser
MACT FFFF second-stage evaporator EX-1013, EX 1003 system(40 T
distillation column EX-90008, and maximum 24-hour
nine process tanks of various capacities average outlet
temperature)
ES-1001-11-F
PSD Process equipment leaks NA NA
MALT FFFF
One plant material grinder(1,011 pounds One bagfilter(244
MHZ-1002 per hour nominal feed rate) CD-1003-4-1 square feet of filter
area)
ES-1001-11-WW
PSD Botanical extraction operation wastewater NA NA
MACT FFFF stream
Biomass Extraction Operations
ES-1004-1 One cartridge filter
PSD Biomass extraction debagging CD-1004-1-FF1 (6.7:1 maximum air-to-
cloth ratio)
ES-1004-2-F process equipment leaks NA NA
PSD
ES-1004-2-WW Biomass extraction operation wastewater NA NA
PSD stream
Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
desolventizer Z-41002, condenser venting to
day tank 490025 (9,953 gallon capacity),
ES-1004-2-P isohexane storage tank 490024 (13,536 CD-1004-2EX1003 One cryogenic
PSD gallon capacity), (nitrogen) condenser
CAM first stage evaporator EX-41012, system(40 T
second stage evaporator EX-41013, maximum 24-hour
distillation column EX-490008,and average outlet
nine process tanks of various capacities temperature)
One bagfilter(254
ES-1004-2Silo Biomass silo loadout CD-1004-2-FF2 square feet of filter
area)
ES-MSDU- Moleeular sieve NIA NIA
1024***
Miscellaneous Opera Lions
H-101 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- NA NA
Lby7case MACTHtu per hour maximum heat input rate)
Permit 01 S 19T43
Page R
Emission Source Control Device Control Device
Na. Emission Source Description M No. Description
2 H-10
H- ease- One No. 2 fuel oil-fired boiler(20.3 million NA NA
by-ease MALT Btu per hour maximum heat input rate)
H-103 One No. 2 fuel oil-fired boiler(25.2 million
2D.1109 case- Btu per hour maximum heat input rate) NA NA
by-case MACT
ES-BB 1 and ES- One simple cyclone
BB2* (114 inches in
NSPS—Subpart Two biomasslbio-based solids-fired boilers CD-BB 1C and CD- diameter) in series with
Dc (24 million Btu per hour maximum heat * one bagfilter(8,900
MACT— input rate each) BB 1 BH square feet of filter
Subpart area)
DDDDD
ES-1ZD* one simple cyclone
One No. 2 fuel oil/propane-fired rotary (114 inches in
dryer(30.0 million Btu per hour maximum CD-BB I C and CD- diameter)in series with
heat input rate) BB1BH* one bagfilter(8,900
square feet of filter
area)
ES-PkGenl One No. 2 fuel oil-fired limited use One catalytic oxidizer
MACT ZZZZ emergency generator(2,935 kilowatt CD-CatOxl (695 °F minimum inlet
maximum rated power output) temperature)
WWTP-AT1
PSD Wastewater treatment plant aeration tank NA NA
MALT FFFF No. 1
E101 One No. 2 fuel oil-fired emergency generator
MALT ZZZZ (587 horsepower maximum rated power NIA NIA
output)
E102 One No. 2 fuel oil-fired emergency generator
MALT 7Z7�Z (760 horsepower maximum rated power NIA NIA
output)
);l 03 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (603 horsepower maximum rated power NIA NIA
output)
E 104**** One No.2 fuel oil-fired emergency generator
MACT ZZZZ output)
horsepower maximum rated power N/A N/A
output)
1~P One No. 2 fuel oil-fired emergency fire
MACT ZZZZ Water pump(285 horsepower maximum NIA NIA
rated power output)
1 The Permittee is pennitted to operate sources ES-M-125A and 125B,ES-1001-1-1-P1,ES-1001-1-1-P2,and ES-1001-1-1-P3
without the simultaneous operation oFserubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 13.Ld and e,below.
Operation of water spray fume scrubber CD-Z-9215 and water spray fume scrubber CD-Z-9216 shall only be required for
control of crnissions From the PNE Operations if that source is utilizing ethyl acetate as a solvent.
* These emission sources and control devices (ID Nos. ES-BB1,ES-BB2, ES-RD, CD-BB1C and CD-BBIBII)are listed as a
15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality Pcrmit Application on or before 12
months after commencing operation in accordance with General Condition NNA. The permit shield described in General
Condition R does not apply and compliance certification as described in General Condition P is not required.
"The emission sources in the SPG operation are listed as a 15A NCAC 2Q .0501(c)(2)modification. The Permittee shall
Permit 01819T43
Page 9
file a 'Title V Air Quality Permit Application on or before 12 months after commencing operation in accordance with
General Condition NN.1. The permit shield described in General Condition R does not apply and compliance
certification as described in General Condition P is not required.
*** This emission source (113 No. ES-MSDU-1024) are listed as a 502(b)(10) change per 15A NCAC 2Q .0523.
Notification shall be made in accordance with General Condition NN.3. The permit shield described in General
Condition R does not apply.
**** 'These emission sources (11) Nos. ES-ES-M-125A and 12513, M04, and ES-TK-PNE-1) 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 pennit shield as described
General Condition R)for this source shall become final on February 19,2015. Until this date,the affected permit terns
herein reflect the proposed operating language that the Permittee shall operate this source under pursuant to 15A NCAC
2Q.0515(f).
SECTION 2— SPECIFIC LIITATIONS 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. Three No.2 fuel ail-fired bailers (ID Nos.H-101,H-102, and H-103)
The Following table pro-v7des a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter 0.37 pounds per million Btu heat input 15A NCAC 2D .0503
Sulfur dioxide 2.3 pounds per million Stu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 2D.0521(d)
Visible emissions
40 percent opacity:H-101 and H-102 15A NCAC 2D .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 2D .1109
Control Technology [1120) Case-by-Case MALT]
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 2D
.0503(a)]
TestinE [15ANCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.l.a, above,the Pennittee shall be deemed in noncompliance with 15A NCAC 2D
.0503.
Permit 0 18 19T43
Page 10
MonitoringlReco_rdkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for particulate emissions from the firing of No. 2
fuel oil in boilers H-101,H-102, or H-103.
2. 15A NCAC 2D.051b: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources 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 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0516.
MonitoringlRecordkeeping!Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in boilers 11-101, H-102, or 11-103.
3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers H-101 and H-102 shall not be more than 40 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 40 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 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler H-103 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-minutc
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit, If the results of this test are above the limit
given in Section 2.1 A.3.a or b, above, as applicahle, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0521.
Monitorin IRecordkee in Re ortin [15A NCAC 2Q .0508(t)]
d. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in boilers H-101,1-1-102, or H-103.
4. 15A NCAC 2D .1109: 112(3) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 112(j)-Case-by-Case MACT for Boilers& Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers H-101, H-102, and
H-103. The initial compliance date for this work practice standard and the associated monitoring,
recordkeeping, and reporting requirements is August 17, 2013. These conditions need not be included
on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance, the Permittee shall perform an annual boiler inspection and maintenance on
boilers as recommended by the manufacturer, or as a minimum, the inspection and maintenance
requirement shall include the following:
Permit 01819T43
Page 11
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Penrnittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement. The Permittee shall be deemed in noncompliance with 15A NCAC
2D .1109 if the affected boilers are not inspected and maintained as required above.
Recordkeepin [15A NCAC 2Q .0508(t)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a log
(written or electronic format) on-site and made available to an authorized representative upon request.
The log shall record the Following;
i. The date and time of each recorded action;
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Report_i_ng [15A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-PkGenl) and one associated catalytic
oxidizer(ID No. CD-CatOxl)
The following table provides a sunimary of limits and standards for the enussion sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
15A NCAC 2D .1111
Hazardous Air Pollutants Maximum Achievable Control Technology [40 CFR Part 63, Subpart
ZZZZ]
Nitrogen Oxides(NOx) Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator ES-PkGen1 shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the comhustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard. [15A NCAC 2D
.0516]
Testin [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. 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 2D
.0516.
Permit 018I9T43
Page 12
Monitoring/Recordk.eening/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in limited use generator ES-PkGenl.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator ES-PkGenl 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. hi no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. if emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test arc above the limit
given in Section 2.1 B.2.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in limited use generator ES-PkGen 1.
3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
[40 CFR Part 63, Subpart ZZZZ]
Applicability [40 CFR§63.6580 and §63.6585]
a. Limited use generator ES-PkGenl shall comply with all applicable requirements of 15A NCAC 2D
.1111 "Maximum Achievable Control Technology" pursuant to 40 CFR Part 63, Subpart 777,2
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines(RICE)"including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR§63.6590(b)(1)(ii)and§63.66751
b. In accordance with 40 CFR §63.6590(a)(2)(i) this source is considered an existing Limited Use source
for purposes of Subpart ZZZZ. To qualify as such, the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittec shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations, on limited use generator ES-PkGenl. The Permittee shall conduct monthly
monitoring of hours of operation for this source as measured by the non-resettable hour meter. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring is not
performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGenl, as measured by the non-resettable hour meter, in a log (written or electronic format) on-site
and made available to an authorized representative upon request.
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring, recordkeeping, or reporting is required for hazardous air pollutant emissions from
limited use generator ES-PkGenl.
Permit 01814T43
Page 13
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. in order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator ES-PkGen1 shall discharge into the atmosphere less than 40 tons of nitrogen
oxides per consecutive 12-month period [15A NCAC 2D .0530].
Testing [15A NCAC 2Q .0508(f]]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 BA.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Operational Limitation[15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 B.4.a, above, the operation of limited
use generator ES-PkGen1 shall not exceed 1,500 hours in a consecutive 12-month period. The
Pernzittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitoring/Recordkeeping[15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not
conducted, these records are not maintained, or if the rolling total hours of operation for the limited use
generator exceed 1,500 hours per consecutive 12-month period.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered 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 must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months,
and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period
ending during the reporting period.
C. Rotocel Operations, including:
■ Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No.CD-I001-2-S-1);
■ Two storage and recycle tanks (ID No. ES-M-125A and M-125I1) and one associated chilled
water condenser (ID No. CD-1001-2-C-1) venting to one packed tower scrubber (ID No. CD-
1001-2-S-1);
• Process equipment leaks (ID No.ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser
(ID No.CD-1001-1-3)venting to one packed tower scrubber(ID No.C.D-1001-2-S-1); **
• One chilled water condenser (ID No. CD-1001-1-T5B) venting to packed tower scrubber (ID
No. CD-1001-2-S-1) controlling emissions from: **
Permit 0 1819T43
Page 14
o Stripper T-5 and receiver M-21 (ID No.ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(11)No.ES-1001-1-1-P3);
• Process equipment leaks(ID No.ES-1001-1-1-F); and
• Recovery Operations wastewater stream (Ill No. ES-1001-1-1-WW)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Best Available Control Technology
See Sections 12 13.1 and 2.2 B.2 15A NCAC 2D .0530
Excluding two solvent recycle process tanks
(ES-M-125A and M-125B)
Volatile organic Control VOC emissions by 98% 15A NCAC 02D .0524
compounds Subpart Kb
Compliance Assurance Monitoring
15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Maximum Achievable Control Technology 15A NCAC 2D .1111
Hazardous Air Pollutants [40 CFR Part 63, Subpart.
See Section 2.2 c.1 F-FFF]
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q.07051.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D.1100 -11
1. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CNR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CPR Part
64 and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic
compound (VOC) emission limits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this
permit.
Control Requirements/Pa rameter ranges [15A NCAC 2Q .0508(o]
b. VOC emissions from the rtocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (II)No. ES-M-125A and M-125B), arcon process tank
M-1 (ID No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight
process and storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower
scrubber (ID No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.Lc and d, below. In
addition, the Permittee shall maintain a daily average mineral oil temperature at the inlet of scrubber
CD-1001-2-S-1 of less than or equal to 100 degrees Fahrenheit (100 °F) whenever the associated
sources are operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.Led
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
I
Perrot 01814T43
Page 15
monitoring and recordkeeping requirements of Sections 2.1 C.l.c.i through iii, below, are not
performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral ail packed tower scrubber
CD-1001-2-S-1 at least once each day that the sources listed in Section 2.1 C.1.b,above,operate;
ii. The Permittee shall inspect, maintain, and operate mineral oil packed tower scrubber CD-1001-2-S-
1 in accordance with Section 2.2 B.l.i, below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gauge associated with
mineral oil packed tower scrubber CD-1001-2-S-1 in accordance with Section 2.2 B.1 j,below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable.Further, if mineral oil packed tower scrubber CD-100 1-2-S-1. operates
under conditions qualifying as an excursion for more than 5 percent of the operational time of the
sources listed in Section 2.1 C.Lb, above, during a consecutive 6-month period,then the Pertnittee shall
develop a Quality Improvement Plan(QIP)in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed
tower scrubber CD-1001-2-S-1 with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.l.b, above, while the associated emission sources are operating, except as allowed
pursuant to Sections 2.2 B.l.c and d, below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
inlet mineral oil temperature of packed tower scrubber CD-1001-2-S-1;
iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber CD-
100 1-2-S-1 or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittec shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered 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.
Permit 01819T43
Page 16
D. BotanicaI Extraction Operations, including:
• Immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator
EX-1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process
tanks of various capacities (ID No. ES-1001-11-1-P) and one associated chilled water
condenser(ID No. CD-1001-11-EX1002)venting to one cryogenic(nitrogen)condenser system
(ID No. CD-1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagflter (TD No.CD-1003-4-
1);
• Process equipment leaks (ID No.ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream (ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debugging (ID No. ES-1004-1) and one associated cartridge filter (ID No.
CD-1004-1-FFI);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, isohexane storage
tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation
column EX-490008 and nine process tanks of various capacities (TD No. ES-1004-2-P)and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen)condenser system (ID No.CD-1004-2EX1003);
• Process equipment leaks(ID No.ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
■ Biomass extraction operations wastewater stream(ID No.ES-1003-10-WW);
■ Biomass silo loadout (ID No. ES-1004-2Silo) and one associated bagflter (1D No. CD-1004-2-
FF2); and
• Molecular sieve(ID No.ES-MSDU-1024)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder,biomass extraction
debugging, and biomass silo loadout:
Particulate inatter E=4.10P°�' 15A NCAC 2D ,0515
Where:E=allowable emission rate in pounds per
hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0530
See Sections 2.213.1 and 2.2 B.2
Volatile organic compounds Compliance Assurance Monitoring 15A NCAC 2D .0614
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
15A NCAC 2D .1111
Hazardous Air Pollutants Maximum Achievable Control technology 15A
4D FR Part 63, Subpart
See Section 2.2 C.1 (Botanical extraction only) 40
Permit 01819T43
Page 17
Regulated Pollutant T Limits/Standards Applicable Regulation
Toxic Air Pollutants State.-Enforceable Only 15A NCAC 2Q .07051.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .1100
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (ID No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
E=4.10xP
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.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.l.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0515.
Monitoring Recordkeepin [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the plant material grinder, the biomass extraction debagging
operation, and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a
cartridge filter (ID No. CD-1004-1-17171), and a bagfilter (ID No. CD-1004-2-17172), respectively. To
assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and rmaintained.
d. The results of inspections and maintenance shall be maintained in a log (written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following.
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any iaintenance performed on the cartridge filter and bagfilters; and
iv. 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)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall sulunit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between
Permit 01819T43
Page 18
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
a. Visible emissions from the botanical extraction operations and the biomass extraction operations 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)]
Testing [I5A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2,1 D.2.a, above, the Permittee shall be deemed in noncompliance with I5A NCAC 2D
.0521.
Monitoring U5A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources
for any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly
observation must he made while the associated source is operating. If a source does not operate during a
monthly period, then a record documenting such non-operational status will satisfy this monitoring
requirement for that source. If visible emissions from a source are observed to be above normal, the
Permittee shall either:
i. Take appropriate action to correct the above-nonnal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2601 (Method 9)for 12 minutes is below the limit given in Section 2.1 D.2.a,
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting
, [I5A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered 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.
Permit 0 1819T43
Page 19
3. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR §64.2]
a. For the immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks (ID No.
ES-1001-11-1-P) and the immersion extractor Z-41001, desolventizer Z-41002, day tank 490025,
isohexane storage tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013,
distillation column EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P), the
Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this source
complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D.3 of this permit.
Control Rea uirementslParameter ranges [t 5 A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P)
shall be controlled by the associated cryogenic condenser system(ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system (ID No.CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40
degrees Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003
whenever the associated sources are operational; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F
for cryogenic condenser system CD-1004-2EX1003 whenever the associated sources are
operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.e.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D,3,c,i through iv, below, are not
performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1001-11-
EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D,3.b,
above,operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1004-
2EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above, operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems CD-1001-11-
EX1003 and CD-1004-2EX 1003 in accordance with Section 2.2 B.Lg, below; and
iv. The Permittee shall install,maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems CD-1001-11-EX1003 and CD-1004-2EX1003 in accordance with
Section 2.2 B.Lh, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system CD-1001-11-EX1003 or CD-
1004-2EX1003 operate under conditions qualifying as an excursion for more than 5 percent of the
operational time of their associated sources listed in Section 2.1 13.31, above, during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR §64.8.
For the purposes of this permit condition excursions are defined as operation of cryogenic condenser
system CD-1001-11-EX1003 or CD-1004-2EX1003 with a 12-hour average outlet temperature that
exceeds the associated limit cited in Sections 2.1 D.3.1b.i and ii, ahove, while the associated emission
sources are operating.
Permit 01 S 19T43
Page 20
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request.The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along wide any actions taken to correct the
outlet temperature of cryogenic condenser system CD-1001-11-EX1003 or CD-1004-2EX1003;
iii. The results of any inspections or maintenance performed on cryogenic condenser system CD-1001-
11-EX1003, cryogenic condenser system CD-1004-2EX1003, or the associated temperature gauges;
and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-nionth
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
he clearly identified.
E. Two biomass boilers (ID Nos. ES-BB1 and ES-BB2) and an associated propane/No. 2 fuel oil-
fired rotary dryer(ID No. ES-RD) operated in series controlled by a cyclone (ID No.CD-BBIQ
in series with a bagfYlter(LD No.CD-BB1BH)
The following;table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Boilers aD Nos. ES-BBI and BB2): 15A NCAC 02D .0503
matter 0.33 pounds per million Btu heat input
Rotary dryer(ID No. ES RD):
Particulate u 67 15A NCAC 02D.0515
matter E=4.10(P)
Sulfur 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
dioxide
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 02D .0521
emissions period
NIA Initial notification requirements, 15A NCAC 02D .0524
Notification of boiler size and fuel combusted, and NSPS—Subpart Dc
Record and maintain amount of each fuel cotnbusted
during each calendar month.
PM,HCI, Per Subpart 15A NCAC 02Q.1111
CO,Hg, MACT Subpart DDDDD
Dioxins/Fura
ns
Permit 01819T43
Page 21
L Te. stingy[15A NCAC 02Q A508(f)
Under the provisions of North Carolina.General Statute 143-215.108, in order to verify emission factors used
for calculating CO (0.54 lb/MMBtu)and NOx(0.22 lbIMMBtu)emissions the Permittee shall perform a stack
test on one of the boilers for CO and NOx within 60 days after start-up. The testing shall be conducted in
accordance with a testing protocol (using testing protocol submittal form) approved by the Division of Air
Quality. Details of emission testing requirements can be found in Section 3—General Condition JJ. If testing
shows emissions greater than the emission factors used, the Permittee must notify the Regional Office
Supervisor,in writing,no later than 60 days following the stack test date.
2. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos.ES-BB1 and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
hca.t input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition J.T.
If the results of this test are above the limit given in Section 2.1 A. 1. a. above,the Pennittee shall be
deemed in noncompliance with 15A NCAC 2D.0503.
Monitoring [15A NCAC 2Q .0508(o]
C. Particulate matter emissions from the boiler shall be controlled by a cyclone in series witb a bagfilter.
To assure compliance,the Pennittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and iaintenance recommendations, or if
there is no manufactureC's inspection and maintenance recommendations, as a minimum,the inspection
and maintenance requirement shall include the following:
i. monthly external inspection of the ductwork, cyclone, and bagfilter noting the structural
integrity; and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Pennittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone, bagfilter,
and ductwork is not inspected and maintained.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a log(written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i.the date and time of each recorded action;
ii. the results of each inspection;
iii.a report of any iaintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall suhinit a report of any
maintenance performed on the cyclone and bagfilter.
f. 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-montb 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.
Permit 01819T43
Page 22
3. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate inatter from the rotary dryer(ID No.ES-RD)shall not exceed an allowable emission rate
as calculated by the following equation: [I5A NCAC 2❑.0515(a)]
E=4.10 x P 0-157 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition.1.1. If the
results of this test are above the Iimit given in Section 2.1 E. 2. a. above,the Permittee shall be deemed in
noncompliance with 15A NCAC 213.0515.
Monitoring/Recordkeeping[15ANCAC 2Q.0508(f)]
c. The Permittee shall maintain production records such that the process rates"P" in tons per hour,as specified by the
formulas contained above(or the formulas contained in 15A NCAC 213.0515)can be derived,and shall make
these records available to a DAQ authorized representative upon request.The Pennittee shall be deemed in
noncompliance with 15A NCAC 2❑.0515 if the production records are not maintained or the types of materials
and finishes are not monitored.
4. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source 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 A.La. above,the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
c. No monitoringlrecordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
5. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(11)Nos. ES-BB1, ES-BB2,and ES-RD) 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 mare 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)]
Testin [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E. 3. a. above,the Pennittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
For boilers (ID Nos. ES BBI and ES BB2):
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance,once a day the Permittee shall observe the emission points of the boilers(11)
Nos. ES-BB1 and ES-13132) for any visible emissions above normal. The daily observation must be
made for each day of the calendar year period to ensure compliance with this requirement. The
Permittee shall be allowed three(3) days of absent observations per semi-annual period. The Permittee
Permit 01819T43
Page 23
shall establish"normal"for the boilers in the first 30 days following the effective date of the permit. If
visible emissions from this source are observed to be above normal, the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 213 .2610(Method 9) for 12 minutes is below the limit given in Section 2.1 E.3. a.
above.
If the above-normal emissions are not corrected per(i) above or if the demonstration in (ii)above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log(written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. the date and time of each recorded action:
ii. the results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii, the results of any corrective actions performed.
The Pcrmittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer(ID No. ES-RD):
1lZonitoring(RecordkeepinglReporting [15A NCAC 2Q .0508(f)]
f No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel
oil in the rotary dryer(ID No. ES-RD).
6. 15A NCAC 2D.0524: NSPS 40 CFR PART 60 SUBPART De
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as promulgated in 40
CFR Part 60 Subpart Dc, including Subpart A "General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUILREMENTS-In addition to any other required by 40 CFR 3 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 3 60.7)or reconstruction (40 CFR 3 60.15)of an affected facility is
commenced,postmarked no later than 30 days after such date, and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Rcoordkeeping [15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR 60.48c or recordkeeping requirements of
the EPA, the Permittee shall record and maintain records of the amounts of each fuel fired during each
day. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0524 if these records are
not maintained.
Permit 0 18 19T4 3
Page 24
7. 15A NCAC 02D.1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers (ID Nos. ES-BBI and ES-13132) are subject to 40 CFR Part 63, Subpart DDDDD.
F. Four emergency generators and fire water pump (ID Nos. E101, E102, E103,E1.04, and FP)
The following table provides a Summary of limits and standards for the emission sources)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible 20 percent opacity 15A NCAC 02D.0521
emissions
NIA NIA 15A NCAC 021).1111—
Subpart ZZZZ
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source 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(1)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3, If the results of this test are above the limit given in Section 2.1 A.La. above, the Pennillee shall be
deemed in noncompliance with 15A NCAC 2D.0516.
c. No monitoring/recordkeeping/ is required for Sulfur dioxide emissions from the firing of No. 2 fuel oil in these
sources.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event sliall the six-minute average exceed 87 percent opacity.
[15A NCAC 2D .0521 (d)]
Testing[15A NCAC 2Q.0508(f)]
b. if emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 F. 2. a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 21).0521.
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in these
sources.
3. 15A NCAC 213.1111 [40 CFR Part 63 Subpart ZZZZI;
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Slandard 15A NCAC 21).1111,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,
Subpart ZZZZ,"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines",by December 13,2004.
Alonitorin2/Recordkeepin,aIReportine [I 5A NCAC 2Q.0508(f}j
b. No monitoring/recordkeeping/reporting requirements.
Permit 01819T43
Page 25
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources [all permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101,H-102, and H-103]
The following,table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 2D .0958
Odorous emissions State-Enforceable Only 15A NCAC 21).180ti
Odorous emissions must be controlled
1. 15A NCAC 2D .0958. WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D .0958, for all sources that use volatile organic compounds (VOC) as
solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that
inix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a
product of chemical reactions,the Pennittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, when not
in use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety
procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile
organic compounds,
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other
coating equipment into closable containers and close such containers immediately after each use,or
transfer such solvents to closed tanks, or to a treatment facility regulated under section 402 of the
Clean Water Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank
or a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 21)
.0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush parts in the freeboard area,
ii. Take precautions to reduce the pooling of solvent on and in the parts,
iii. Tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all
dripping has stopped, whichever is longer,
iv. Not fill cleaning machines above the fill line,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 21) .0958(d)]
Monitoring [15A NCAC 2Q .0508(f)]
c, To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum,perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations. If the required inspections are not
conducted the Pennittee shall be deemed to be in noncompliance with 15A NCAC 21) .0958.
Permit 01819T43
Page 25
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with
rule 15A NCAC;2D .Og58.
Reporting [I 5A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations From the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D.I806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NESHAP source, any increase in toxic air pollutants must be evaluated.
Permit 01819T43
Page 27
B. Three No. 2 fuel oil-Fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 21) .0530
{VOC
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. The following Best Available Control Technology(BACT)limits shall not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tans per Condenser CD-31209
desolventixer, and solvent VOC 10.8 pounds consecutive
separation/recovery per hour 12-month and packed toyer
(ID No. ES-1001-2-1-P1) period
scrubber CD-14Q1-2-5-1
Rotocel equipment leaks VOC Leak detection and
(ID No. ES-1001-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(TD No. ES-100 1-2-1-WW) VOC wastewater treatment
tanks
Where Rwocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-I When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete.
8.76 pounds per hour and 0.53
tons per consecutive 12-month
period
Permit 01819T43
Page 28
Emission Source Pollutant BACT Emission Limits Control Technology
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-100 1-1-
receiver M-21 VDC Operating and Recovet T5B
(ID No. ES-1 001-1-1-P2) Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC Fixed roofs
(ID No. ES-1001-1-1-P3)
Recovery equipment leaks VOC LDAR
(ID No. ES-1 00 1-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting wastewater treatment
(ID No. ES-1001-1-1-W W) of methanol-wash tanks and biological
treatment
Botanical extraction
immersion extractor, 61.76 tons per
desolventizer, first and Condenser CD-1001-11-
second stage evaporators, VOC 14.1 pounds consecutive EX1002 and condenser
distillation column,day tank, per hour period month CD-1001-11-EXi003
and multiple process tanks
(ID No.ES-1001-11-P)
Botanical extraction
VOC
equipment leaks (ID No. ES- LDAR
1001-11-F) (Fe,gllive}
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC wastewater treatment
ES-1 001-11-WW) tanks
Biomass extraction
immersion extractor,
desolventizer,day tank, 61.8 tons per
isohexane storage tank, first. Condenser CD-1004-
and second stage VDCs 14.1 pounds consecutive 2EX1002 and condenser
period
evaporators, distillation Per hour period
th CD-1004-2EX1003
column, and multiple process
tanks
(ID No. ES-1004-2-P)
Permit 01819T43
Page 29
Emission Source Pollutant BAC T Emission Limits Control Technology
Biomass extraction
equipment leaks (ID No. ES- VOCs LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs wastewater treatment
ES-1004-2-WW) tanks
No. 2 fuel-oil fired boilers
(ID Nos. H-101,H-102,H- VDC 0.2 pounds per 1,000 gallons Combustion control
103)
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. 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 [15A NCAC 2Q .0508(f)]
c. The Permittee shall limit the operation of the recovery stripper T-5 and rceeiver M-21 (ID No. ES-
1001-1-1-P2) while source ES-1001-2-1-P1 is not operating to no greater than 34 days in any
consecutive 12-month period.
d, The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-P1) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises) while source ES-1001-2-1-P1 is not operating to no greater than 6 days in
any consecutive 12-month period.
e. The Permittee shall implement the leak detection and repair (LDAR) program of 40 CFR Part 63,
Subpart UU, as per the requirements Section 2,2 B.2, below. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530, if the LDAR program requirements are not implemented.
f. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant (i.e. Wastewater Treatment Plant Aeration Tank No. 1; ID No. WWTP-
AT1) for volatile organic compounds (VDC),when the wastewater stream consisting of methanol-wash
from the recovery operations(ID No. ES-1001-1-1-WW)is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VDC is not
determined every week or if the mass removal efficiency is less than 95%.
g. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.La,
above, shall be controlled by the associated condensers. To assure compliance, the Permittee shall
perform periodic inspections and maintenance as recommended by the equipment manufacturer. In
addition, the Permittee shall perform an annual inspection of each condenser system, including the
following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is under positive gauge pressure, leakage of the
contaminated gas stream. In order to monitor leakage of the coolant, the condensate shall be
inspected for the presence of coolant; and
H. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
h. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
Permit 01819T43
Page 30
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.La, above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The
temperatures output from the sensors shall be continuously monitored and hourly values used to
determine the 24-hour average temperature at the condenser outlets. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the outlet temperatures of the condensers are not
maintained heiow the limits in the table below; or the condensers are not equipped with sensors to
continuously measure the outlet temperatures; or if those sensors are not inspected and maintained..
Emission Source Condenser ID No. Required Outlet Temperature
Recovery areon tank M-1 CD-1001-1-3 45 OF,24-hour average, when
(ID No. ES-1001-1-1-P1) source ES-1001-2-1-PI is not
Recovery stripper T-5 and operating and the tanks are used
receiver M-21 (ID No.ES-1001- CD-1001-1-T5B for concrete processing in the
1-1-p2) recovery operation
Botanical extraction operations CD-1001-11-EXI003 -40°F, 24-hour average
(ID No.ES-1001-11-P)
Biomass extraction operations(ID No. ES-1004-2-P) GD-1004-2EX1003 -40°P, 24-hour average
i. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.1.a,
above, shall also be controlled by the associated packed tower scrubber (TD No. CD-1001-2-5-1),
except as allowed pursuant to Sections 2.2 B.1.c and d, above. To assure compliance, tl)e Permittee
shall perform periodic inspections and maintenance as recommended by the equipment manufacturer.
In addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system (if so
equipped), and perform maintenance and repair when necessary to assure proper operation of the
packed tower scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
The Pennittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the packed tower
scrubber is not inspected and maintained.
J. The Permitter shall install, iaintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor, and an emission stream inlet temperature sensor for packed tower
scrubber CD-1001-2-5-1 in accordance with manufacturer's recommendations. The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530 if the flow ineter and temperature sensors are not
installed, maintained, and calibrated, or if, except as allowed pursuant to Sections 2.2 B.I.e and d,
above:
i. The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
ii. The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeepin2 [15A NCAC 2Q .0508(f)]
k. The Penmittee shall maintain the following records:
Permit 01819T43
Page 31
i. VOC emissions for each calendar month, and for the consecutive 12-month period ending with each
calendar month, from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-PI, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1 00 1-1-1-P2,
and ES-1001-1-1-P3) when source ES-1001-2-1-P] is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations (ID No. ES-1001-11-P); and
(D)Biomass extraction operations(ID No. ES-1004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through j, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall be updated at least
monthly and record the following:
(A)The date and time of each recorded action;
(B) The actual hours of operation of the recovery arcon tank M-1 (ID No. ES-1001-1-1-PI), and
recovery stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), when source ES-1001-2-1-
Pl is not operating;
(C) The actual hours of operation of recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and
source ES-1001-2-1-P1. is not operating;
(D)The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
W WTP-AT1) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(E) The 24-hour average outlet temperature of the associated condenser(s) listed in Section 2.2
B.l.h, above:
(1) When source ES-1001-2-1-P1 is not operating and the Concrete Operations tanks (ID No.
ES-1001-1-2-P) are used for concrete processing in the recovery operation; and/or
(2) When the biomass extraction operations(11)No. ES-1004-2-P)is operating,
(r) The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream
inlet temperature of scrubber CD-1001-2-S-1 at least once each day that source ES-1001-2-1-P1
operates;
(G)The results of maintenance performed on the condensers and scrubber listed in Section 2.2
B.La,above, and the associated temperature sensors and Clow rate gauges; and
(H)Any variance from manufacturer's recommendations,if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
1. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.1.a, above.
m. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received 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. In
addition,the semiannual reports shall also contain the following:
i. The monthly VOC emissions from each of the following sources for each of the previous 17
months; and
(A)Rotocel and recovery operations (ID Nos, ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-I-P2,
and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-PI, ES-1001-1-1-P2,
Permit 01819T43
Page 32
and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations(ID No. ES-1001-11-P); and
(D)Biomass extraction operations (ID No. ES-1004-2-P).
ii. The cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.m.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D.0530: Prevention of Significant Deterioration]
Equipment identification [15A NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified. Identification of the equipment does not require
physical tagging of the equipment. For example,the equipment may be identified on a plant site plan, in
log entries, by designation of process unit or affected facility boundaries by some form of weatherproof
identification, or by other appropriate methods. In addition to the above, the following equipment shall
be specifically identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe miumer to perform monitoring;
(Connectors need not be individually identified if all connectors in a designated area or length of
pipe are identified as a group,and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rapture disk upstream of the pressure device;
iii. Valves, pumps, and connectors that are designated unsafe-to-monitor (i.e., Permittee has
determined that monitoring personnel would be exposed to an immediate danger as a consequence
of complying with the monitoring requirements);and
iv. Valves that are difficult-to-monitor (i.e., Permittee has determined that the valve cannot be
monitored without eIevating the monitoring personnel more than seven feet above a support surface
or it is not accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-
to-monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
explanation why the equipment is unsafe or difficult-to-monitor. These records must be kept at the plant
and be available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times, but not more frequently than the periodic monitoring
schedule otherwise applicable,and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment
at least once per calendar year and repair of the equipment if a leak is detected.
C. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process
unit shutdown. The identity of connectors designated as unsafc-to-repair and an explanation why the
connector is unsafe-to-repair shall be recorded.
Instrument and sensory monitoring for leaks [15A NCAC 2Q .0508(f)]
d. histrnment monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
Permit 01819T43
Pabc 33
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak
to the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instnunent response factor criteria in section 3.1.2, paragraph(a) of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis.The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there
is no instrument commercially available that will meet the performance criteria specified above,the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid,calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures
specified in Method 21 of 40 CFR part 60, appendix A.
iv. Calibration gases shall be zero air (less than 10 parts per million of hydrocarbon in air); and the
gases shall be mixtures of methane in air at a concentration no more than 2,000 parts per million
greater than the leak definition concentration of the equipment monitored, If the monitoring
instrument's design allows for multiple calibration scales, then the lower scale shall be calibrated
with a calibration gas that is no higher than 2,000 parts per million above the concentration
specified as a leak, and the highest scale shall be calibrated with a calibration gas that is
approximately equal to 10,000 parts per million.A calibration gas other than methane in air may be
used if the instrument does not respond to methane or if the instrument does not meet the
performance criteria specified Method 21 of 40 CFR part 60, appendix A. In such cases, the
calibration gas may be a mixture of one or more of the compounds to be measured in air.
v. Monitoring shall be perfonned when the equipment is in VOC service.
g. The Permittee may elect to adjustor not to adjust the instrument readings for background.
i. If the Pen nittee elects not to adjust instrument readings for background,the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,
above. In such cases, all instrument readings shall be compared directly to the applicable leak
definition for the monitored equipment to determine whether there is a leak or to determine
compliance with operational standards for pressure relief devices.
ii. If the Permitter elects to adjust instrument readings for background, the Permittee shall
(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B) Determine the background level using the procedures in Method 21 of 40 CFR part 60,
appendix A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored
equipment to determine whether there is a leak or to determine compliance operational
standards for pressure relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at
the time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
Permit Q 1819T43
Page 34
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair. The written procedures may be included as part of the startup, shutdown,
and malfunction plan, or may be part of a separate document that is maintained at the plant
site. In such cases, reasons for delay of repair may be documented by citing the relevant
sections of the written procedure (i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts, there must be documentation
that the spare parts were sufficiently stocked on-site before depletion and the reason for
depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
L The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar days
after it is detected, except as provided for in delay of repair and/or unsafe to repair connectors. A first
attempt at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at
repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring that
the seal flush is operating at design pressure and temperature.First attempt at repair for valves includes,
but is not limited to,tightening the bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the
packing gland nuts,and/or injecting lubricant into the lubricated packing,
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring.
Identification that has been placed on equipment determined to have a leak, except for a valve or for a
connector in gas/vapor or light liquid service,may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and, where appropriate, why the repair was
technically infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical, but no later than the end of the next
process unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed
for a valve if valve assembly replacement is necessary during the process unit shutdown, and valve
assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked
before the supplies were depleted. Delay of repair beyond the second process unit shutdown will
not be allowed unless the third process unit shutdown occurs sooner than six months after the first
process unit shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if:
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair, and
(B) When repair procedures are effected, the purged material cannot be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a duality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg, below) will provide better performance, or the repair is completed as
soon as practical, but not later than 6 months after the leak was detected and one of the following is
used;
(A)A dual mechanical seal system;
(B) A pump that meets has no external shaft penetrating the pump housing; or
Permit.01819TA 3
Page 35
(C) A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNapor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines
a leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak,the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with
less than one percent leaking valves.
(B) The Permittee may elect to monitor each valve once every four quarters for process units with
less than 0.5 percent leaking valves.
(C) The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the
monitoring frequency provisions to each subgroup. If the Permittee subdivides the valves in the group
of process units,then the following provisions apply.
i. The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup. Valves with less
than one year of monitoring data or valves not monitored within the last twelve months must be
placed initially into the most frequently monitored subgroup until at least one year of
monitoring data have been obtained.
(B)Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to
a less frequently monitored subgroup provided that the valves to be reassigned have not leaked
for the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the
valve or group of valves is to be reassigned to a subgroup being monitored annually). Non-
repairable valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so
indicate the performance in the next periodic report.If the overall performance of total valves in the
applicable process unit or group of process units is two percent leaking valves or greater, the
Permittee shall no longer subgroup and shall revert to the program required in Section 2.2 B.2.p. for
that group of process units. The Permittec can again elect to comply with the valve subgrouping
procedures if future overall performance of total valves in the process unit or group of process units
is again less than two percent. The overall performance of total valves in the applicable process unit
or group of process units shall be calculated as a weighted average of the percent leaking valves of
each subgroup according to following equation.
Permit 01 S 19T43
Page 36
%VL,. X V)
%VLfJ —— "
n
Y Vi
i=I
Where: %VLo=Overall performance of total valves in the applicable process unit or group of
process units
%VLi =Percent leaking valves in subgroup i,most recent value
Vi =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee sball maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for caeb subgroup for each monitoring period;
(C) Which valves are reassigned, the last monitoring result prior to reassignment, and when they
were reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next
monitoring period of the decision to subgroup valves. The notification shall identify the
participating process units and the number of valves assigned to each subgroup, if applicable, and
may be included in the next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for eaeb process group (i.e., botanical extraction,
biomass extraction, and Rotocellrecovery) for comparison with the sub grouping criteria specified in
Section 2.2 B,2,m, above, and the percent, leaking valves for each monitoring period for each process
unit or valve subgroup shall be calculated using the following equation.
%VL = L )XI00
VT
Where: %VL = Percent leaking valves.
VL = Number of valves found leaking, excluding non-repairahle valves and including those
valves found whose repair was not confirmed with hoth post leak repair monitoring
and periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly, or semiannual monitoring frequencies, the percent leaking valves shall be the arithmetic
average of the percent leaking valves from the last two monitoring periods. When determining
monitoring frequency for each process unit or valve subgroup subject to annual or biennial (once every
2 years) monitoring frequencies, the percent leaking valves shall be the arithmetic average of the
percent leaking valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time
the valve is identified as leaking and non-repairable. Otherwise, a numher of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in
regulated material service at a process unit or affected facility, the number of non-repairable valves
Permit 0 1 819T43
Pagc 37
exceeding one percent of the total number of valves in regulated material service shall be included
in the calculation of percent leaking valves.
p. If a leak is determined,then the leak shall be repaired. After a leak has been repaired,the valve shall he
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and
first attempt at repair. The monitoring shall be conducted to determine whether the valve has
resumed leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides
with the time specified. Alternatively, other monitoring may be performed to satisfy the
requirement regardless of whether the tinning of the monitoring period for periodic monitoring
coincides with the time above.
iii. If a leak is detected by monitoring that is conducted after leak repair, the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) if the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy tine
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1, above, and the Permittee shall monitor the valve according to the
written plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
pen-nit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that
is designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b, above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection, the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of
2,000 parts per nullion (ppm) or greater it shall be repaired using the procedures in Sections 2.2
B.2.i through 2.2 B.21, above; or
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly
visual inspection provided that each pump is visually inspected as often as practical and at least
monthly.
t. If, whcnn calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak, the Permittee
shall implement a. quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.gg,
below.The Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except
that pumps found leaking in a continuous process unit within one month after start-up of the pump
shall not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
%PL = IPLP Ps}_PS x100
T
Permit 01819T43
Page 38
Where: °/GPL=Percent leaking pumps
PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current
monitoring period.
PT =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in}gas and vapor service and in light liquid service standards [15A NCAC 2Q .0509(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater thau or equal to 500 parts per million is
measured, a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this
requirement and shall be monitored and inspected according to the written plan specified in Section 2.2
B.2.b, above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year),
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but
less than 0.5 percent, then monitor within four years. The Permittee may comply with this
requirement by monitoring at least 40 percent of the connectors within two years of the start of the
monitoring period, provided all connectors have been monitored by the end of the four year
monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical, but within the next six months, all connectors that have not yet
been monitored during the monitoring period if the percent leaking connectors is greater than or
equal to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new
monitoring period shall be started based on the percent leaking connectors of the total
monitored connectors.], or
(B) Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
iv. If,during the monitoring,a connector is found to be leaking, it shall be re-monitored once within 90
days after repair to confirm that it is not leaking.
v. The Pcrmittee shall keep a record of the start date and end date of each monitoring period under
this section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows.
%C, = CT
X 100
T
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
Cr = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried, insulated in a manner tliat prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
Permit 0 18 19 T4 3
Page 39
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding,or
v. Not able to be accessed in a safe manner to perform monitoring
are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory, or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [I5A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below,each pressure relief device in gas and vapor service
shall he operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of
less than 500 parts per million, as soon as practical, but no later than five calendar days after each
pressure release,except as provided for in delay of repair provisions of this permit;
iL The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background, and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during
the monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar
days after each pressure release, except as provided for in delay of repair.
Quality improvement program for pumps [15A NCAC 2Q .0508(f)]
bh. If, on a fi-month rolling average, at least the greater of either 10 percent of the pumps in a process unit
or three pumps in a process unit leak, the Permitter shall implement a quality improvement plan until
the number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in
the process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t,above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program. The data may be collected and the records may be
maintained on a process unit,affected facility, or plant site basis.
i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design(e.g., external shaft, flanged body); materials of construction;
if applicable, barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. 1're maximum instrument readings observed in each monitoring observation before repair, response
factor for the stream if appropriate, instrument model number, and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site) remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seat failures and were
removed from the process unit due to leaks. 1-he inspection shall determine the probable cause of the
pump seal failure or of the pump leak and shall include reconunendations, as appropriate, for design
changes or changes in specifications to reduce leak potential.
ee. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above, to determine the services, operating or maintenance practices, and pump or pump seat designs or
technologies that have poorer than average emission performance and those that have better than
Permit 01819T43
Page 40
average emission performance. The analysis shall determine if specific trouble areas can be identified
on the basis of service, operating conditions or maintenance practices, equipment design, or other
process-specific factors.
i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the services), operating conditions, or pump or pump seal
designs associated with poorer than average emission performance. A superior performing pump or
pump seal technology is one with a leak frequency of less than 10 percent for specific applications
in the process unit. A candidate superior performing pump or pump seal technology is one
demonstrated or reported in the available literature or through a group study as having low emission
performance and as being capable of achieving less than 10 percent leaking pumps in the process
unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process
unit duc to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site, a company,
am
or a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The
quality assurance program may establish any number of categories, or classes, of pumps as needed to
distinguish among operating conditions and services associated with poorer than average emission
performance as well as those associated with better than average emission performance. The quality
assurance program shall be developed considering the findings of the data analysis required under
paragraph Section 2.213.2.ee, above, and the operating conditions in the process unit. The quality
assurance program shall be updated each year as long as the process unit has the greater of either 10
percent or more leaking pumps or has three leaking pumps.
i. The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage, or other applicable identified critical parameters.
(B)Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C) Provide for an audit procedure for quality control of purchased equipment to ensure
conformance with purchase specifications.
(D)Retail off-line pump maintenance and repair procedures. Thesc procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program,
gg. Three years after the start of the quality improvement program,the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
Pennit 01819T43
Page 41
been identified as superior emission performance technology and that comply with the quality
assurance standards for the pump category. Superior emission performance technology is that category
or design of pumps or pump seals with emission perfonnance that when combined with appropriate
process, operating, and maintenance practices, will result in less than 10 percent leaking pumps for
specific applications in the process unit. Superior emission performance technology includes material
or design changes to the existing pump, pump seal, seal support system, installation of multiple
mechanical seals or equivalent, or pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number
of pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero
integer value. The minimum number of pumps or pump seals shall be one. Pump replacement shall
continue until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above,
are pumps determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the
next planned process unit shutdown, provided the number of pump seals and pumps replaced is
equivalent to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shall maintain records for the period of the quality improvement program for the process
unit prescribed below.
i. When using a pump quality improvement program,the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B)Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,
above, and any recommendations for design or specification changes to reduce leak frequency;
and
(C) The beginning and ending dates while meeting the quality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak, the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream, the operating conditions and maintenance practices.
iv. All records documenting the quality assurance prograrn for pumps as specified in the quality
assurance program, including records indicating that all pumps replaced or modified during the
period of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg,above.
Recordkeepin2 requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not
physically tagged and the Permittee is electing to identify the equipment through written documentation
such as a log or other designation.
J. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
mm. For valves, the Permittee shall maintain the monitoring schedule for each process unit and the
valve subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pwnp visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service, the Permittee shall keep records of
the dates and results of monitoring following a pressure release.
qq. For a pump QIP program,the Permittee shall maintain the following records:
i. Individual pump records as specified in Section 2.2 B.2.ce, above;
Permit 01 S 19T43
Page 42
ii. Quality assurance program documentation as specified in Section 2.2 B.2.ff,above; and
iii. Quality improvement program records as specified in Section 2.2 13.2.hh, above.
Reporting requirements [15A NCAC 2Q .0508(f)]
rr. The Permittee shall submit a.summary report of monitoring and recordkeeping activities postmarked or
received 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 in summary format by equipment type(i.e., valves in gas/vapor/light
liquid service, Pumps in light liquid service, and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves,pumps and connectors, and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired, and for valves
and connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
U. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection
instrument reading, of less than 500 parts per million, report the results of all monitoring to show
compliance conducted within the semiannual reporting period.
vv. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report,if applicable,the initiation of a quality improvement program for pumps.
Permit 0 18 1 9T43
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C. Sclareolide(SDE) Operations, including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity; 1D No.M-20);
• Process equipment leaks (ID No.ES-1001-1-4-F);
■ Four batch reactors (ID Nos. M-10, M-10A, D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate; Ill No. CD-M-34); and
• SDE Operations wastewater stream(ID No.ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide, including:
■ Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks (ID No.ES-1001-1-3-F);
• One distillation column(6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for Sclareolide purification wastewater stream (113 No. ES-1001-
1-3-WW)
Ethyl Vanillin Glucoside (EVG) Operations, including:
• One water spray fume scrubber (0.5 gallon per minute minimum water injection rate; ID No.
CD-Z-9215) venting to one water spray fume scrubber (0.5 gallon per minute minimum water
injection rate; ID No.CD-Z-9216)controlling emissions from:
o Three reactors (ID Nos. D-2202,D-1215,and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks (ID No. ES-1003-2-2-F); and
■ EVG Operations wastewater stream(ID No. ES-1003-2-2-WW)
Sclareol Recrystallizati.on (SFG) Operations,including:
• Four process tanks (2,500 gallons capacity each; ID Nos.T-3002 through 3005);
• One hexane storage tank(6,700 gallon capacity; ID No.T-3001);
■ One centrifuge(ID No. C-3001);
• One chilled water condenser(ID No. CD-3001) controlling emissions from-
- One reactor(ID No.R-3001) equipped with a process chilled water condenser(EX-3001)
- One reactor(ID No.R-3002)equipped with a process chilled water condenser(EX-3003)
- One steam heated dryer(ID No.D-3001)
• Process equipment leaks(ID No. ES-1003-10-17);
• SFG Operations wastewater stream (ID No.ES-1003-10-VL NV)
Plant Nutrient Extraetion (PNE) Operations, including one water spray fume scrubber (0.5
gallon per minute minimum water injection rate; ID No. CD-Z-9215) venting to one water
spray fume scrubber (0.5 gallon per minute minimum water solution injection rate; ID No.
CD-Z-9216) controlling emissions from:
• One product extract reactor (ID No.D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities(ID No.ES-1003-2-1-P);
• One centrifuge(ID No.C-31203);
■ One process solvent tank(ID No. ES-TK-PNE-1)
■ Process equipment leaks(ID No.ES-1003-2-1-F);
■ One waste solids separator vessel (1,333 gallon capacity; ID No. D31211) and one associated
chilled water condenser (ID No. EX2205); and
Permit 01919T43
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PNE Process wastewater stream (1D No. ES-1003-2-1-W%V)
Concrete Operations, including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and 1113-4);
■ Process equipment leaks (ID No.ES-1001-1-2-F); -
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser(ID No.CD-1001-1-2); and
■ Concrete Operations wastewater stream(ID No.ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C, above;
Two Storage and Recycle Tanks (1D No. ES-M-125A and M-125B)
Recovery Operations, as described in Section 2.1 C, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-AT1)
The fbUowtE table provides a summary of limits and standards for the emission souree(s)describe above:
Regulated Pollutant Limits/Standards --FApplicable Regulation
Maximum Achievable Control 15A NCAC 2D .1111
Hazardous Air Pollutants(HAP) Technology [40 CFR Part 63, Subpart
11 FFFF]
1. 2D.1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63,Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF, including Subpart A "General Provisions". For convenience, some of the
relevant definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435,
63.2440, 63.2445(b), and 63.25501
Group I batch process vent means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions froin all of the batch process vents are greater than or equal to
10,000 lb/yr at an existing source or greater than or equal to 3,000 ib/yr at a new source.
Group 2 batch process Neat means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group 1 continuous process vent means a continuous process vent for which the flow rate is greater
than or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b), is less than or equal to 1.9 at an existing source and less than or
equal to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not meet the definition of
a Group 1 continuous process vent.
Group 1 storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group I wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria.for Group 1 status in §63.2485(c) for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in §63.132(d)for compounds in Table 8 to subpart G of this part 63.
Permit 01819T43
Page 45
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group 1 wastewater stream.
In organic HAP service means that a piece of equipment either contains or contacts a fluid (liquid or
gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions
of§63.180(d). The provisions of§63.180(d) also specify how to determine that a piece of equipment is
not in organic HAP service.
M veellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in §63.2435(b). For
the purposes of this subpart, process includes any, all or a combination of reaction, recovery,
separation, purification, or other activity, operation, manufacture, or treatment which are used to
produce a product or isolated intermediate.
Nonstandard batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch.A nonstandard batch may be necessary as a result of a malfunction,but
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of
an MCPU as described by records specified in §63.2525(b).
Paint of determination means each point where process wastewater exits the MCPU or control device.
Standard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions from a standard batch are based on the operating
conditions that result in highest emissions. Tfie standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Rep uirementslLimitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.1.bd through v, below:
i. The Permittee must submit a Notice of Compliance Status Report for the SDE Operations, the
Concrete Operations, and/or the PNE Operations prior to the operation of those operations in
organic HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63,
Subpart FFFF apply to those operations,pursuant to 40 CFR§63.2520(d).
ii. Opening a safety device, as defined in §63.25509 is allowed at any time conditions require it to
avoid unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. if a Group 2 emission point becomes a Group 1 emission point, the Permittee must be in
compliance with the Group 1 requirements beginning on the slate the switch occurs. An initial
compliance demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within
150 days aflcr the switch in group status occurs. The Permittee shall be deemed in non-compliance
with 15A NCAC 2D .1111 if the Pemiittee does not meet these requirements. [40 CFR
§63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR§63.6(e) for the affected sources. The Pennittee is not,however,required to
address equipment leaks (except for control devices) or Group 2 emission points in the SSM Plan,
The SSM Plan must describe, in detail, procedures for operating and maintaining the affected
sources during periods of startup, shutdown, and malfunction; and corrective actions for
malfunctioning process, control,and monitoring equipment used to comply with Subpart FFFF. The
SSM Plan does not need to address any scenario that would not cause an affected source to exceed
an applicable emission limit in Subpart FFFF. The SSM Plan must be maintained on site and made
available for inspection by authorized personnel. [40 CFR§§63.6(e)(3)and 63.25256)]
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the
Pen-nit 01819T43
Page 46
requirements of Sections 2.2 C.1.b.i through v,above.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
c. The Permittec shall comply with the specific requirements of Sections 2.2 C.l.e.i through vii,below:
L Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.1.c.i(A) and (B), below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.g through j,
above.
(B) For contiuuous process Gent associated with the Botanical Extraction Operations,the Permittee
shall perform the monitoring found in Sections 2.2 B.1.g and h, above.
ii. Batch process vents: To ensure compliance; the Permittee shall perform the monitoring of
Sections 2.2 C.1.c.ii(A)through(C),below,for the affected batch process vents:
(A)For the batch process vents associated with the SFG Operations. the EVG Operations, and the
Biological conversion equipment for purification of sclareolide, the Permittee shall comply
with the requirements of 40 CFR §63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF. To
maintain Group 2 classification for these emission sources the organic HAP emissions must be
less than 10,000 pounds per consecutive 365-day period, each source. The Permittee shall
monitor the organic HAP emissions from each of these emission sources, monthly, as follows:
(1) Organic HAP emissions from the SFG Operations shall calculated using the following
equation:
r oun.dsl ( ounds ounds ourzds1Organic HAP= 37.89I � f xBtf +[11.45p �xRgI+ 15.03�8 )xBrec + 9.7<p ) B,�tank all batch ` hatch 6utr:h
Where: BSeg = The number of regular batches processed in the SFG Operations; and
B,, = The number of recrop batches processed in the SFG Operations
Bte = The number of third crop batches processed in the SFG Operations; and
Btf = The number of hexane tank(T-3001) fills.
(2) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HifP= 1.0 poundr x B
hatch
Where: B = The number of batches processed in the EVG Operations
(3) Organic HAP emissions from the Biological conversion equipment for purification of
selareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x$
batch
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B)The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.Le.ii(A)(1)through (3),above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations, the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of
40 CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,
combined. The Permittee shall monitor the organic HAP emissions from these batch process vents,
monthly, as follows:
Permit 01819'143
Page 47
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 11.3 pou�ds x B f 31.8 pounds x B
hatch r� batch r"
Where: B,,, = The number of regular batches processed in the EVG Operations; and
B,, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.l.c.iii(A), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Permittee shall comply
with the requirements of 40 CFR §63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair
(LDAR) program found in Section 2.2 B.2, above, for the equipment associated with the affected
sources.
vi. Wastewater streams: For the wastewater streams associated with the affected miscellaneous
organic chemical manufacturing processes (MCPU), the Permittee shall comply with the
requirements of 40 CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca,
Inc. facility; and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2, unless the conditions of Section 2.2 C.l.b.iv, above, have been
met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will
be used to detect leaks of process fluids into cooling water. This plan shall require monitoring
of one or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more
process parameters or other conditions that indicate a leak. The plan shall include the
following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s) or conditions(s) that shall constitute a leak. This shall be
documented by data or calculations showing that the selected levels or conditions will
reliably identify leaks. The monitoring must be sufficiently sensitive to determine the range
of parameter levels or conditions when the system is not leaking. When the selected
parameter level or condition is outside that range, a leak is indicated;
(3) The monitoring frequency which shall be no less frequent than monthly for the first 6
months and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after
discovery of the leak.
Permit U 1819T43
Page 48
(C) The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded,retain the most recent superseded plan at least until 5 years from
the date of its creation.
(D)if a leak is detected in any heat exchanger system, it shall he repaired as soon as practical but
not later than 45 calendar days after the Permittee receives results of monitoring tests indicating
a leak, unless the Permittee demonstrates that the results are due to a condition other than a
leak. Once the leak has been repaired, the owner or operator shall confirm that the heat
exchange system has been repaired within 7 calendar days of the repair or startup, whichever is
later, except where the Permittee appropriately applies the delay of repair provisions found in
Section 2.2 C.1.e.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the
process. Delay of repair is also allowed if repair is technically infeasible without a shutdown
and any one of the conditions listed in 40 CFR §f 3.104(e)(1)through(2)is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.c.i through vii, above.
RecordkeeRing Requirements [15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.l.dd through v,below.
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B) An identification of related process vents (including associated emissions episodes),
wastewater points of determination (PODS), and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents,the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of
operating and/or testing conditions for any associated control device;
(E) The process vents, wastewater POD, transfer racks, and storage tanks (including those from
other processes) that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G) Calculations and engineering analyses required to demonstrate compliance,
iii. For each affected MPCU with a Group 2 process vent, the Permittee shall retain the following
records:
(A)A record of the day each hatch was completed;
(B)A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a
non-standard batch; and
(D)Records of the daily 365-day rolling summations of emissions, or alternative records that
correlate to the emissions(e.g.,number of batches),calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream, the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds l isted in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw),including documentation of the methodology used to determine concentration; and,
(D) Stream flow rate(in liters/min).
v. For each affected heat exchanger system,the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak, the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan,including the date the leak was discovered;
Permit 01819T43
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(C) The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittec does not
meet the requirements of Sections 2.2 C.1.d.i through v, above.
Reporting[15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR§63.2460(b)(6) and 40 CFR§63.2520(e)(10).
f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and Decemher, and July 30 of
each calendar year for the preceding six-month period between January and June. The report shall
contain the following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard
specified in this subpart, include a statement that there were no deviations from the emission limits,
operating limits, or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period; and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable), as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered
by the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary Format by equipment type, the number of
components for which leaks were detected and for valves, pumps and connectors show the percent
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required, and for valves and connectors, identify the number
of components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B)Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized, report that delay of repair has occurred and report
the number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report,if applicable, the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay ❑F repair,
include the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s) for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired,the expected date of repair.
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2. 15A NCAC 2Q.0317. AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation,the SFG operations shall discharge into the atmosphere
less than 95.29 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .05301
Monitorine/Reeordkeening [I5A NCAC 2Q .0508 (f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format). The Permittec shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed this limit.
Reporting [15A NCAC 2Q ,0508(f)]
d. The Perniittee shall submit a semi-annual 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. The monthly VOC emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
3. LIMITATION TO AVOID BEING CLASSIFIED AS A MON GROUP 1 BATCH PROCESS VENT
a. In order to remain classified as a Group 2 batch process vent for hazardous air pollutants (HAP) under
40 CFR 63, Subpart FFFF, uncontrolled HAP emissions from the SFG operations shall be less than
10,000 pounds per year. The Permittee shall be deemed a Group 1 batch process vent if the HAP
emissions exceed this limit.
Monitorin2/Recordkeepin2 Requirements [15A NCAC 2Q .0508(f)]
b. Maintain monthly calculations of HAP emissions. The Permittee shall be deemed a Group 1 batch
process vent if the records are not maintained.
Reporting Requirements [I5A NCAC 2Q .0503(f)]
c. Submit to the Regional Supervisor, Division of Air Quality, semiannually,a report summarizing HAP
emissions from SFG operations containing the following:
i. greatest quantity in pounds of an individual hazardous air pollutant used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average;
ii. pounds of all hazardous air pollutants used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average.
D. Biomass boilers(il)Nos.ES-BB1 and BB2)
Rotary sage dryer(ID No.ES-RD
I. 15A NCAC ZQ.0317: AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
Permit 01819T43
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a. In order to avoid applicability of this regulation,the above emission sources shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]
Monitorim/Recordkeeping[I5A NCAC 2Q .0508 (f)]
b. For any sage sent to the dryer,the Permittee shall:
i. Measure the sage input on a daily basis,
ii, Measure the hexane content of the sage exiting the process on a weekly basis, The sampling shall
include collecting sage material as it exits the desolventizer before it enters the rotary dryer every
hour for a 24-hour period each week.
iii. Calculate daily VOC emissions by using the daily sage input and the hexane content(lb hexane/lb
sage)determined weekly for the sage drying until the next weekly result is obtained.
c. The facility has determined the potential VOC emissions from both boilers to be 3.57 tons per 12
months or 0.30 tons per month. The Permittee has requested to use 0.15 tons per month of VOC
emitted per boiler for any month in which the boiler(s)operate to determine compliance with this
permit condition.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format).
Reporting [15A NCAC 2Q .0508(f))
e, The Permittee shall submit a semi-annual 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_ The monthly VOC emissions for the previous 17 months.The emissions must be calculated for
each of the 12-month periods over the pre,6ous 17 months.
E. Rotary Sage Dryer(ID No. ES-RD)
1. 15A NCAC 2Q.0317: AVOIDANCE CONDITIONS
LIMITATION TO AVOID 15A NCAC 02D.1112: 112(g) Case by Case Maximum Achievable
Control Technology
a. In order to avoid applicability of 112(g),n-hexane emissions from the rotary dryer(ID No. ES-RD)
shall be less than 10 tons per year.
MonitoringAecordkeeping Requirements [I5A NCAC 2Q .0508(f)]
b. Maintain monthly consumption records of each material containing n-hexane as follows:
i. Maintain a quantity of n-hexane in pounds used in the rotocel operations each month and for the
12-month period ending on that month.
ii. Maintain a record of purchase orders and invoices of materials containing n-hexane that are used in
the rotocel operations.
iii. Utilize the calculations specified in Permit Condition No. 2.2-D.1.b. above and calculate n-hexane
emissions based on the n-hexane content utilized in the rotocel operations as determined at the
desolventizer as the emissions from the rotary dryer.
c, The Permittee shall keep a record of the applicability determination on site at the source for a period of
five years after the determination, or until the source becomes an affected source. The determination
must include the analysis demonstrating why the Permittee believes the source is unaffected pursuant to
40 CFR Part 63.10(b)(3)
Permit 01819T43
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Reporting Requirements [15A NCAC 2Q .0508(f)]
d. The Perrnittee shall submit a semi-annual 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. The monthly n-hexane emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
SECTION 3 - GENERAL CONDITIONS (version 3.6)
This section describes terms and conditions applicable to this Title V facility,
A. General Provisions[NCGS 143-215 and 15ANCAC 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 ux 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 maybe 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 Pernlittee 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 Stateus 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 Pemnittee 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. Severahlliity 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 Regicmal 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,qnality 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:
Permit 01819T43
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Supervisor,Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit),
E. Duty to Comply [I5A NCAC 2Q.0508(i)(3)]
The Penn ittee 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 requirement%constitutes a violation of
the Federal.Clean Air Act. Noncompliance with any permit condition is pounds 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 drat 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 I1Zodifications
1.Administrative Permit Amendments[15A NCAC 2Q.05141
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 i 5A NCAC 2Q.0524 and 2Q
.0505.
3.Minor Permit Modifications[15A NCAC 2Q.0515]
The Permittec shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q.0515.
4.Significant Permit Modifications[I5A 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 Permittee 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 1
must be reported to the Regional Supervisor,DAQ:
a. changes in the ink oration 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)(I0)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 federally enforceable permit
terms and conditions that are monitoring(including test methods),recordkccping,reporting,or compliance
certification requirements.
b. The Permittee may make Section 502(b)(l0)changes without having the pennit revised if:
i. the changes are not a modification under Title 1 of the Federal.Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Penn ittee notifies the Director and EPA with written notification at least seven days before the change
is made;and
Permit 01819T43
Page 54
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[15ANCAC 2Q.0523(b)]
The Permitteo 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.Enssions Trading[l5A 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. ReuortinL Requirements for Excess Emissions and Permit Deviations
[15ANCAC 2D.0535(t)and 2Q.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable mission limitation or standard allowed by any
rule in Sections.0500,.0900,.1200,or.1400 of Subchapter 2D;or by a permit condition;or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q.0700. (Nate:Definition ofexcess emissions under 2D,I110 and 2D
.1111 shall aj_?ply 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.1111),or the operating pernut 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 Pennittee 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
• 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 wrilwn report as described in 15A NCAC
2D.0535(f)(3).
Permit De-6ations
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 deti7ations 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 pen-nit requirements.
Permit 01819T43
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I.B. Other Requirements under 15A NCAC 2D.0535
The Pernrittee shall comply with all other applicable requirements contained in 15A NCAC 2D.0535,including 15A
NCAC 2D.0535(c)as follow~:
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 ovmer 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 21].0535(g). Excess enssions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emereency Provisions[40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1.An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitation under the permit due to unavoidable
increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment,lack of preventive maintenance,careless or improper operation,or operator
error.
2.An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based
emission limitations if the conditions specified in 3.below are met.
3.The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Pcrmittee 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 pemut;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)]
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 tern.
Permit expiration terminates the facilitys 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 Permittec 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 inonths before the date of permit expiration for facilities
subject to 15A NCAC 2Q .0400 requirements. In either of these events, all terns 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 Dcfcuse [15A NCAC 2Q.0508(i)(4)]
It shall not be a defense for a Perrnittcc 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. Dub,to Providc Information(submittal of information) [I5ANCAC 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
w_ ritin to determine whether cause exists for modifying,revoking and reissuing,or tenninating 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
Permit 01819T43
Page 56
upon request along with a claim of confidentiality.
N. Duty to Supplement[15ANCAC 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.
0. 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[15ANCAC 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 maybe specified under Sections 114(a)(3)or 504)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 terns and conditions of the pennit for the period covered by the certification);
3.whether compliance was continuous or intermittent;and
4.the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Offrcial[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 inlonnation in the document are true,accurate,and complete.
R. Permit Shield for Applicable Requirements[15ANCAC 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 it-,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 incorrecL;
2.the conditions under which the permit or permit.renewal was granted have changed;
3.violations of conditions contained in the permit have occurred;
Permit 01819T43
Page 57
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 ofNCGS Chapter 143,Article 21B.
T. Insienifrcant Activities[I SA 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(hat the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement. The Pemuttee 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. Proven►•Rights[15A NCAC 2Q.0508(i)(8)]
This permit does not convey any property rights in tither real or personal property or any exclusive privileges.
V. Inspection and Entry[15ANCAC 2Q.0508(1)and NCGS 143-215.3(a)(2)]
1.Upon presentation of credentials and other documents as may be required by lacy,the Permittee shall allow the DAQ,or
an authorized representative,to perform the following:
a. enter the Pernuttee's premis,es where the permitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions of the permit;
b, have access to and copy,at reasonable times,any records that are required to be kept under the conditions of the
permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring
and air pollution control equipment),practices,or operations,regulated or required under the permit;and
d. sample or monitor substances or paramneters,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 Pennittee under
Section 114 or other provisions of(he 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 assessinent of civil penalties.
W. Annual Tee Payment[15ANCAC 2Q.0508(i)(10)]
1.The Permittee shall pay all fees in accordance with 15A NCAC 2Q.0200.
2.Payment of fees maybe by check or inoney 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 Pemuttee 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
Permittce 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.
Permit 01 8 19T43
Page 58
AA.Standard Application Form and Required Information[I5A 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 Pennittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or 11
ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40
CFR Para.82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment
according to the work practices,personnel certification requirements,and certified recycling and recovery equipment
specified in 40 CFR Part 82 Subpart F.
2.The Permittee shall not knowingly vent or otherwise release any Class I or I1 substance into the enviromnent 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 81166. Reports shall be
subnu-ted 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.
LE, 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 117 Allowances[15A NCAC 2Q.0508( )(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 laNNTfully holds under Tide IV of the Federal Clean Air Act.
GG.Air Pollution Emergency Episode[I5A NCAC 213.0300]
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[I5A NCAC 2D.0202]
The Director of the DAQ may require the Permittec 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).
1I, 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 sha11 be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 2D.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.
IJ. 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 inay 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
Permit 01819T43
Page 59
Permittee submits emissions testing to the DAQ to demonstrate compliance,the Pennittee shall perform such testing in
accordance with I SA NCAC 2D.2600 and follow the procedures outlined below
-
I, 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 fulfalls 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 time 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 comp]iance 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.
K.K.Reouenine for Cause[15A NCAC 2Q.0517]
1.A pennit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with reinaining permit term of three or more
years;
L additional requirements(including excess emission requirements)become applicable to a source covered by Title
IV;
c. the Director or EPA fords 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 pennit,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 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 pennit is to be reopened,except in
cases of imminent threat to puhlic 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 Reguirements for Non-Operating Equipment[15A NCAC 2Q.0508(i)(1 G)]
Permit 01819T43
Page 60
The Penn ittee shall maintain a record of operation for Perm tted equipment noting whenever the equipment is taken from
and placed into operation. During operation the monitoring recordkeeping and reporting requiremems as prescribed by the
permit shall be implemented within the monitoring period.
MM.Fugitive Dust Control Requirement[E 5A 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(t).
"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 begirt operation of the air
emission source(s)and associated air pollution control device(s)until a Title V Air Quality Permit Application is
frlcd 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 Pcrmittee shall submit a,page"E5" of die application forms signed by the responsible official verifying that the
application for the 502(b)(10)change/modification,is true,accurate,and complete. Further note that
modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstruction
requirements.
00.Third Party Participation and EPA Review[15A NCAC 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 availahlc to submit a public petition pursuant to 15A NCAC 2Q.0518 begins at the end of the 45-day
EPA review period.
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
CAIR Clean Air Interstate Rule
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
MALT Maximum Achievable Control Technology
MCPU Miscellaneous Organic Chemical Manufacturing Process Units
NAA Non-Attaimnent Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
DAH 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
SGz Sulfur Dioxide
tpy Tons Per Year
VQC Volatile Organic Compound
A
hNCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarfa, ill
Governor Secretary
December 19, 2014
Dr. David M. Peele,Ph.D.
President
Avoca Incorporated
P.O. Box 129
Merry Hill, North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T43
Facility ID: 0800044
Avoca Incorporated
Merry Hill, Bettie County,North Carolina
Fee Class: Title V
Dear Dr. Pecle:
In accordance with your completed Air Quality Permit Application for a 17li..nor tnodil"ication to your Title
V permit under 15A NCAC 02D .05I5 received September 22, 2014, we are forwarding herewith Air Quality
Perntit No. 01819T43 to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, 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 cerrtification 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.
These emission sources (Ill Nos. ES-M-125A and 125B, E104, and ES-TIC-PNE-1) 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 February 19, 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).
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q .0504 for
the SFG operations on or before 12 months after commencing operation.
The Permittee shall notify the Director and EPA with written notification at least seven days before the
"change is made" pursuant to 15A NCAC 2Q .0523(a)(1)(C) for the air emission source(s) (ID No. ES-MSDU-
1024).
As the designated responsible official it is your responsibility to review, understand, and abide by all of the
terms and conditions of the attached pennit. It is also your responsibility to ensure that any person who operates
any emission source and associated air pollution control device subject to any tern or condition of the attached
permit reviews, understands, and abides by the condition(s) of the attached pen-nit that are applicable to that
particular emission source.
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
Phone:919-707-8400l Internet:www.ncdenr.gov
An Equal 4ppartunil 1 Affirmative Action Employer—Made in part with recycled paper
Mr.David M. Peele, Ph.D.
December 19, 2014
Page 2
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you, you
have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit,identifying
the specific issues to be contested. 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 fonn 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 regnest 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
150E-22. This request must be submitted in writing to the Director and must identify the speeific provisions or
issues for which the modification is sought. Please note that this Air Quality Permit will become final and
binding regardless of a request for informal modification unless a request for a hearing is also made under
NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control device(s), or
modifications to the emission source(s) and air pollution control device(s) described in this permit must be
covered under an Air Quality Permit issued by the Division of Air Quality prior to construction unless the
Pennittee has fulfilled the requirements of GS 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 GS 143-215.108A and may subject the
Penmittee to civil or criminal penalties as described in GS 143-215.114A and 143-215.114B.
This Air Quality Permit shall be effective from December 19, 2014 until July 31, 2015, is nontransferable
to future owners and operators, and shall be subject to the conditions and limitations as specified therein.
Should you have any questions concerning this matter,please contact Kevin Godwin at(919) 707-8480.
Sincerely yours,
William D.Willets,P.L.,Chief,Permitting Section
Division of Air Quality,NCDF.NR
Enclosure
c; Rob Fisher, Supervisor,Washington Regional Office
Heather Ceron, EPA Region 4
Central Files
Insignificant Activities under 15A NCAC 2Q.0503(8)
Emission Control Device Control Device
Source I No. Emission Source Description ID No. Dencri tion
IWWTP-ET] Wastewater treatment plant equalization tank NIA NIA
No. 1 (65,500 gallon capacity)
IW WTP-ET2 Wastewater treatment plant equalization tank NIA NIA
No.2 65,500 gallon capacity)
Wastewater treatment plant aeration tank No.2
IW WTP-AT2 (63,500 Ion capacity)
NIA NIA
Wastewater treatment plant aeration tank No. 3
IWWTP-AT3 (63,500 gallon capacity)
MIA NIA
IWWTP CLR Wastewater treatment plant clarifier(1,310 NIA NIA
gallon capacity)
rFK9238 No. 2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
ITKIO2 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
ITK103 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
ITKFP No.2 fuel oil storage tank(270 gallon NIA N/A
capacity)
One water spray fume
CD-Z-92I 5 scrubber(0.5 gallons
per minute minimum
water injection rate)
tECS ECS process:batch preparation of venting to
ethylenediaminel copper sulfate solution CD-Z-9216
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
IES-PV Propane vaporizer NIA NIA
I-Briquette Sage Briquetting Machine N/A NIA
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable
requirement or that the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in
determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100
"Control of Toxic Air Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and MACT ZZZZ see the NC DAQ
web site: littp:IId aq.st ate.n c.us,,toxi e slarea s ource sl.
The following table 2anjdcs a summmy of the changes in Permit No. 01 M 9T43.
Page No. Condition Description of Change(s)
Included language pertaining to minor modification under I5A NCA.0
NIA Cover letter 02Q .0515 for tanks (ID Nos.ES-M-125A and 125B,and ES-TK-PNE-
1}.
Global Global Updated permit number.permit format, and dates.
Table of - ljpdated'tank size to 19,500 gallons-capacity each for ES-M-i 25A
3 Emission and 125B,
Sources - Removed NSPS Kb designation for these tanks,
- Included one chilled water condenser "ID No,C-D 30023
QId page 2 1 C.2. Removal condition pertaining to l5A NCAC 0524 NSPS Subpart Kb
No. 15 for new tanks.
State of North Carolina, 4 so
Department of Environment, �►.•��
and Natural Resources NCDENR
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T43 01819T42 December 19, 2014 July 31, 2015
Until .such time as this permit expires or is modified or revoked, the below named Permittee is authorized to
construct and operate the emission source(s) and associated air pollution eontrol device(s) specified herein, in
accordance with the terms, conditions, and limitations within this pernut. 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 prodded in this permit.
Permittee: Avoca, Inc,
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County,State,Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.U.Box 129
City, State,Zip: Merry Hill,NC 27957
Application Number: 0800044.14E
Complete Application Date: September 22, 2014
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington, NC 27889
Permit issued this the 19"' day of December, 2014.
U
William D. Willets,P.E.,Chief,Permitting Section
By Authority of the Environmental Management Commission
Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S)AND APPIJRTENANCES
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 PERMrF CONDITIONS
ATTACHMENTS
ATTACHMENT 1 List of Acronyms
Permit 01819T43
Page 3
SECTION I - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of ail pernutted emission sources and associated air pollution control devices and
appurtenances:
Emission Source Control Device Control Device
ID No. Emission Source Description 7 ID No. Description
Rotocel Operations
CD-31209 One chilled water
condenser venting to
ES-1001-2-1-P1
PSD Rotocel extractor, desolventizer, and CD-1001-2-S-1 One packed tower
CAM solvent separation/recovery scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
CD-1001-2-C-1 One chilled water
condenser venting to
ES-M-125A and
M-125B**** Two storage and recycle tanks(19,500 CD-1001-2-S-1 ' One packed tower
MACT FFFF gallons capacity each) scrubber(8 gallons per
minute minimum
mineral oil injection
rate)
ES-1001-2-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-2-1-
W W Rotocel Operations wastewater stream NA NA
PSD
MACT FFFF
Recovery Operations
CD-1001-1-3 One chilled water
condenser venting to
ES-1001-1-1-P1
PSD Arcon process tank M-1 CD-1001-2-S-1 ' One packed tower
CAM scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-1-1-P2 CD-1001-1-T513 One chilled water
PSD Stripper T-5 and receiver M-21 condenser venting to
CAM
MACT FFFF CD-1001-2-S-1 ' One packed tower
ES-1001-1-1-P3 Seven process tanks of various capacities scrubber(8 gallons per
PSD and one fixed roof methanol storage tank minute minimum
MACT FFFF (7,050 gallon capacity) mineral oil injection
rate)
Permit 01819T43
Page 4
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
ES-1001-1-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-1-1-
W W Recovery Operations wastewater stream NA NA
PSD
MALT FFFF
Concrete Operations
ES-1001-1-2-P One PSD Six process tanks of various capacities CD-1001-1-2 chilled water
con
MALT FFFF condenser
H13-1 One steam-heated hot hox NA NA
MACT FFFF
HB-2 One steam-heated hot box NA NA
MACT FFFF
HB-3 One steam-heated hot hox NA NA
MACT FFFF
1413-4 One steam-healed hot box NA NA
MACT FFFF
ES-1001-1-2-F process equipment leaks NA NA
MACT FFFF
ES-1001-1-2-
WW Concrete Operations wastewater stream NA NA
MACT FFFF
Sclareol Recrystallization(SFG)Operations"
T-3001 One hexane storage tank(6,700 gallon
MACT FFFF capacity) NA NA
-33002 through Four process tanks(2,500 gallons capacity3005 NA NA
MACT FFFF each)
ES-1003-10-F process equipment leaks NA NA
MACT FFFF
C-3001 One centrifuge NA NA
MACT FFFF
R-3001 One reactor equipped with a chilled water NA NA
MACT FFFF process condenser EX-3001)
R-3002 One reactor equipped with a chilled water
MACT FFFF process condenser(EX-3003) CD-3002 One chilled water
condenser in series
D-3001 One steam-heated dryer equipped with a with,
MACT FFFF chilled water process condenser(EX-3002) CD-3001 One chilled water
condenser
ES-1003-10-WW SFG Process wastewater stream NA NA
MACT FFFF
Biological Conversion Equipment for Purification of Sclareolide
Permit 01819T43
Page 5
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
ES-1001-1-3-P Twelve process tanks of various capacities NA NA
MACT FFFF
G-17
MACT FFFF One centrifuge NA NA
ES-1001-1-3-F process equipment leaks NA NA
MACT FFFF
D-1202 One steam-heated dryer NA NA
MACT FFFF
A-2 One distillation column(6 gallons per
NA N11
MACT FFFF minute nominal process rate)
ES-1001-1-3- Biological conversion equipment for
W W purification of selarcolide wastewater NA NA
MACT FFFF stream
Sclarcolide(SDE) Operations
ES-1001-1-4-P Four process tanks of various capacities NA NA
MACT FFFF
M-20 One acetic acid storage tank(10,135 gallon
MACT FFFF capacity)
NA NA
ES-1001-1-4-F process equipment leaks NA NA
MACT FFFF
M-]0
MACT FFFF One batch reactor
M-10A One venturi-type wet
MACT FFFF One batch reactor scrubber(10 gallons
D-1231A CD-M-34 per minute minimum
MACT FFFF One batch reactor liquid injection rate)
D-123113 One batch reactor
MACT FFFF
ES-1001-1-4-
WW SDE Operations wastewater stream NA NA
MACT FFFF
Plant Nutrient Extraction(PNE) Operations
EX2203 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0,5 gallons
D31214 per minute minimum
MACT FFFF One product extract reactor water injection rate)
venting to
CD-Z-921 fi a
One water spray fume
scrubber(0.5 gallons
Per minute minimum
water injection rate)
Permit 01819T43
Page 6
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description
EX2205 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons
D31211 One waste solids separator vessel(1,333 per minute minimum.
MACT FFFF gallon capacity) water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
ES*TK-PNE-I Solvent Process Tank(9,500 gallons
NA NA
MACT FFFF
capacity
F,S-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
ES-1003-2-1-
WW PNE process wastewater stream NA NA
MACT FFFF
CD-Z-9215 2 One water spray fume
ES-1003-2-1-P Seven process tanks of various capacities scrubber(0.5 gallons
MACT FFFF per minute minimum
water injection rate)
venting to
CD-Z-9216'
C-31203 One centrifuge One water spray fume
MACT FFFF scrubber(0.5 gallons
per minute minimum
water injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
D-2202 CD-Z-9215 One water spray fume
MACT FFFF One reactor scrubber(0.5 gallons
D 1215 One reactor per minute ininimum
MACT FFFF water injection rate)
D-1218 venting to
MACT FFFF One reactor CD-Z-9216
One water spray fume
D-120] scrubber(0.5 gallons
MACT FFFF One steam-heated dryer per minute minimum
water injection rate)
ES-1003-2-2-F process equipment leaks NA NA
MACT FFFF
ES-1003-2-2-
WW EVG Operation wastewater stream NA NA
MACT FFFF
Permit 01819T43
Page 7
Emission Source Control Device Control Device
11)No. Emission Source Description lD No. Descri lion
Botanical Extraction Operations
CD-1001-11- One chilled water
Immersion extractor Z-1001, EX1002 condenser venting to
ES-1001-11-P desolventizerZ-1002,
PSD day tank 90024(6,000 gallon capacity), One cryogenic
CAM first-stage evaporator EX-1012, CD-1001-11- (nitrogen)condenser
MACT FFFF second-stage evaporator EX-1013, EX 1003 system(40 T
distillation column EX-90008, and maximum 24-hour
nine process tanks of various capacities average outlet
temperature)
ES-1001-11-F
PSD Process equipment leaks NA NA
MALT FFFF
One plant material grinder(1,011 pounds One bagfilter(244
MHZ-1002 per hour nominal feed rate) CD-1003-4-1 square feet of filter
area)
ES-1001-11-WW
PSD Botanical extraction operation wastewater NA NA
MACT FFFF stream
Biomass Extraction Operations
ES-1004-1 One cartridge filter
PSD Biomass extraction debagging CD-1004-1-FF1 (6.7:1 maximum air-to-
cloth ratio)
ES-1004-2-F process equipment leaks NA NA
PSD
ES-1004-2-WW Biomass extraction operation wastewater NA NA
PSD stream
Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
desolventizer Z-41002, condenser venting to
day tank 490025 (9,953 gallon capacity),
ES-1004-2-P isohexane storage tank 490024 (13,536 CD-1004-2EX1003 One cryogenic
PSD gallon capacity), (nitrogen) condenser
CAM first stage evaporator EX-41012, system(40 T
second stage evaporator EX-41013, maximum 24-hour
distillation column EX-490008,and average outlet
nine process tanks of various capacities temperature)
One bagfilter(254
ES-1004-2Silo Biomass silo loadout CD-1004-2-FF2 square feet of filter
area)
ES-MSDU- Moleeular sieve NIA NIA
1024***
Miscellaneous Opera Lions
H-101 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- NA NA
Lby7case MACTHtu per hour maximum heat input rate)
Permit 01 S 19T43
Page R
Emission Source Control Device Control Device
Na. Emission Source Description M No. Description
2 H-10
H- ease- One No. 2 fuel oil-fired boiler(20.3 million NA NA
by-ease MALT Btu per hour maximum heat input rate)
H-103 One No. 2 fuel oil-fired boiler(25.2 million
2D.1109 case- Btu per hour maximum heat input rate) NA NA
by-case MACT
ES-BB 1 and ES- One simple cyclone
BB2* (114 inches in
NSPS—Subpart Two biomasslbio-based solids-fired boilers CD-BB 1C and CD- diameter) in series with
Dc (24 million Btu per hour maximum heat * one bagfilter(8,900
MACT— input rate each) BB 1 BH square feet of filter
Subpart area)
DDDDD
ES-1ZD* one simple cyclone
One No. 2 fuel oil/propane-fired rotary (114 inches in
dryer(30.0 million Btu per hour maximum CD-BB I C and CD- diameter)in series with
heat input rate) BB1BH* one bagfilter(8,900
square feet of filter
area)
ES-PkGenl One No. 2 fuel oil-fired limited use One catalytic oxidizer
MACT ZZZZ emergency generator(2,935 kilowatt CD-CatOxl (695 °F minimum inlet
maximum rated power output) temperature)
WWTP-AT1
PSD Wastewater treatment plant aeration tank NA NA
MALT FFFF No. 1
E101 One No. 2 fuel oil-fired emergency generator
MALT ZZZZ (587 horsepower maximum rated power NIA NIA
output)
E102 One No. 2 fuel oil-fired emergency generator
MALT 7Z7�Z (760 horsepower maximum rated power NIA NIA
output)
);l 03 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (603 horsepower maximum rated power NIA NIA
output)
E 104**** One No.2 fuel oil-fired emergency generator
MACT ZZZZ output)
horsepower maximum rated power N/A N/A
output)
1~P One No. 2 fuel oil-fired emergency fire
MACT ZZZZ Water pump(285 horsepower maximum NIA NIA
rated power output)
1 The Permittee is pennitted to operate sources ES-M-125A and 125B,ES-1001-1-1-P1,ES-1001-1-1-P2,and ES-1001-1-1-P3
without the simultaneous operation oFserubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 13.Ld and e,below.
Operation of water spray fume scrubber CD-Z-9215 and water spray fume scrubber CD-Z-9216 shall only be required for
control of crnissions From the PNE Operations if that source is utilizing ethyl acetate as a solvent.
* These emission sources and control devices (ID Nos. ES-BB1,ES-BB2, ES-RD, CD-BB1C and CD-BBIBII)are listed as a
15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality Pcrmit Application on or before 12
months after commencing operation in accordance with General Condition NNA. The permit shield described in General
Condition R does not apply and compliance certification as described in General Condition P is not required.
"The emission sources in the SPG operation are listed as a 15A NCAC 2Q .0501(c)(2)modification. The Permittee shall
Permit 01819T43
Page 9
file a 'Title V Air Quality Permit Application on or before 12 months after commencing operation in accordance with
General Condition NN.1. The permit shield described in General Condition R does not apply and compliance
certification as described in General Condition P is not required.
*** This emission source (113 No. ES-MSDU-1024) are listed as a 502(b)(10) change per 15A NCAC 2Q .0523.
Notification shall be made in accordance with General Condition NN.3. The permit shield described in General
Condition R does not apply.
**** 'These emission sources (11) Nos. ES-ES-M-125A and 12513, M04, and ES-TK-PNE-1) 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 pennit shield as described
General Condition R)for this source shall become final on February 19,2015. Until this date,the affected permit terns
herein reflect the proposed operating language that the Permittee shall operate this source under pursuant to 15A NCAC
2Q.0515(f).
SECTION 2— SPECIFIC LIITATIONS 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. Three No.2 fuel ail-fired bailers (ID Nos.H-101,H-102, and H-103)
The Following table pro-v7des a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter 0.37 pounds per million Btu heat input 15A NCAC 2D .0503
Sulfur dioxide 2.3 pounds per million Stu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 2D.0521(d)
Visible emissions
40 percent opacity:H-101 and H-102 15A NCAC 2D .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 2D .1109
Control Technology [1120) Case-by-Case MALT]
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 2D
.0503(a)]
TestinE [15ANCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.l.a, above,the Pennittee shall be deemed in noncompliance with 15A NCAC 2D
.0503.
Permit 0 18 19T43
Page 10
MonitoringlReco_rdkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for particulate emissions from the firing of No. 2
fuel oil in boilers H-101,H-102, or H-103.
2. 15A NCAC 2D.051b: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources 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 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0516.
MonitoringlRecordkeeping!Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in boilers 11-101, H-102, or 11-103.
3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers H-101 and H-102 shall not be more than 40 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 40 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 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler H-103 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-minutc
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit, If the results of this test are above the limit
given in Section 2.1 A.3.a or b, above, as applicahle, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0521.
Monitorin IRecordkee in Re ortin [15A NCAC 2Q .0508(t)]
d. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in boilers H-101,1-1-102, or H-103.
4. 15A NCAC 2D .1109: 112(3) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 112(j)-Case-by-Case MACT for Boilers& Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers H-101, H-102, and
H-103. The initial compliance date for this work practice standard and the associated monitoring,
recordkeeping, and reporting requirements is August 17, 2013. These conditions need not be included
on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance, the Permittee shall perform an annual boiler inspection and maintenance on
boilers as recommended by the manufacturer, or as a minimum, the inspection and maintenance
requirement shall include the following:
Permit 01819T43
Page 11
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Penrnittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement. The Permittee shall be deemed in noncompliance with 15A NCAC
2D .1109 if the affected boilers are not inspected and maintained as required above.
Recordkeepin [15A NCAC 2Q .0508(t)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a log
(written or electronic format) on-site and made available to an authorized representative upon request.
The log shall record the Following;
i. The date and time of each recorded action;
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Report_i_ng [15A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-PkGenl) and one associated catalytic
oxidizer(ID No. CD-CatOxl)
The following table provides a sunimary of limits and standards for the enussion sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
15A NCAC 2D .1111
Hazardous Air Pollutants Maximum Achievable Control Technology [40 CFR Part 63, Subpart
ZZZZ]
Nitrogen Oxides(NOx) Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator ES-PkGen1 shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the comhustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard. [15A NCAC 2D
.0516]
Testin [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. 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 2D
.0516.
Permit 018I9T43
Page 12
Monitoring/Recordk.eening/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in limited use generator ES-PkGenl.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator ES-PkGenl 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. hi no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. if emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test arc above the limit
given in Section 2.1 B.2.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in limited use generator ES-PkGen 1.
3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
[40 CFR Part 63, Subpart ZZZZ]
Applicability [40 CFR§63.6580 and §63.6585]
a. Limited use generator ES-PkGenl shall comply with all applicable requirements of 15A NCAC 2D
.1111 "Maximum Achievable Control Technology" pursuant to 40 CFR Part 63, Subpart 777,2
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines(RICE)"including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR§63.6590(b)(1)(ii)and§63.66751
b. In accordance with 40 CFR §63.6590(a)(2)(i) this source is considered an existing Limited Use source
for purposes of Subpart ZZZZ. To qualify as such, the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittec shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations, on limited use generator ES-PkGenl. The Permittee shall conduct monthly
monitoring of hours of operation for this source as measured by the non-resettable hour meter. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring is not
performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGenl, as measured by the non-resettable hour meter, in a log (written or electronic format) on-site
and made available to an authorized representative upon request.
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring, recordkeeping, or reporting is required for hazardous air pollutant emissions from
limited use generator ES-PkGenl.
Permit 01814T43
Page 13
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. in order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator ES-PkGen1 shall discharge into the atmosphere less than 40 tons of nitrogen
oxides per consecutive 12-month period [15A NCAC 2D .0530].
Testing [15A NCAC 2Q .0508(f]]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 BA.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Operational Limitation[15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 B.4.a, above, the operation of limited
use generator ES-PkGen1 shall not exceed 1,500 hours in a consecutive 12-month period. The
Pernzittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitoring/Recordkeeping[15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not
conducted, these records are not maintained, or if the rolling total hours of operation for the limited use
generator exceed 1,500 hours per consecutive 12-month period.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered 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 must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months,
and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period
ending during the reporting period.
C. Rotocel Operations, including:
■ Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No.CD-I001-2-S-1);
■ Two storage and recycle tanks (ID No. ES-M-125A and M-125I1) and one associated chilled
water condenser (ID No. CD-1001-2-C-1) venting to one packed tower scrubber (ID No. CD-
1001-2-S-1);
• Process equipment leaks (ID No.ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser
(ID No.CD-1001-1-3)venting to one packed tower scrubber(ID No.C.D-1001-2-S-1); **
• One chilled water condenser (ID No. CD-1001-1-T5B) venting to packed tower scrubber (ID
No. CD-1001-2-S-1) controlling emissions from: **
Permit 0 1819T43
Page 14
o Stripper T-5 and receiver M-21 (ID No.ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(11)No.ES-1001-1-1-P3);
• Process equipment leaks(ID No.ES-1001-1-1-F); and
• Recovery Operations wastewater stream (Ill No. ES-1001-1-1-WW)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Best Available Control Technology
See Sections 12 13.1 and 2.2 B.2 15A NCAC 2D .0530
Excluding two solvent recycle process tanks
(ES-M-125A and M-125B)
Volatile organic Control VOC emissions by 98% 15A NCAC 02D .0524
compounds Subpart Kb
Compliance Assurance Monitoring
15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Maximum Achievable Control Technology 15A NCAC 2D .1111
Hazardous Air Pollutants [40 CFR Part 63, Subpart.
See Section 2.2 c.1 F-FFF]
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q.07051.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D.1100 -11
1. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CNR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CPR Part
64 and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic
compound (VOC) emission limits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this
permit.
Control Requirements/Pa rameter ranges [15A NCAC 2Q .0508(o]
b. VOC emissions from the rtocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (II)No. ES-M-125A and M-125B), arcon process tank
M-1 (ID No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight
process and storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower
scrubber (ID No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.Lc and d, below. In
addition, the Permittee shall maintain a daily average mineral oil temperature at the inlet of scrubber
CD-1001-2-S-1 of less than or equal to 100 degrees Fahrenheit (100 °F) whenever the associated
sources are operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.Led
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
I
Perrot 01814T43
Page 15
monitoring and recordkeeping requirements of Sections 2.1 C.l.c.i through iii, below, are not
performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral ail packed tower scrubber
CD-1001-2-S-1 at least once each day that the sources listed in Section 2.1 C.1.b,above,operate;
ii. The Permittee shall inspect, maintain, and operate mineral oil packed tower scrubber CD-1001-2-S-
1 in accordance with Section 2.2 B.l.i, below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gauge associated with
mineral oil packed tower scrubber CD-1001-2-S-1 in accordance with Section 2.2 B.1 j,below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable.Further, if mineral oil packed tower scrubber CD-100 1-2-S-1. operates
under conditions qualifying as an excursion for more than 5 percent of the operational time of the
sources listed in Section 2.1 C.Lb, above, during a consecutive 6-month period,then the Pertnittee shall
develop a Quality Improvement Plan(QIP)in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed
tower scrubber CD-1001-2-S-1 with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.l.b, above, while the associated emission sources are operating, except as allowed
pursuant to Sections 2.2 B.l.c and d, below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
inlet mineral oil temperature of packed tower scrubber CD-1001-2-S-1;
iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber CD-
100 1-2-S-1 or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittec shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered 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.
Permit 01819T43
Page 16
D. BotanicaI Extraction Operations, including:
• Immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator
EX-1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process
tanks of various capacities (ID No. ES-1001-11-1-P) and one associated chilled water
condenser(ID No. CD-1001-11-EX1002)venting to one cryogenic(nitrogen)condenser system
(ID No. CD-1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagflter (TD No.CD-1003-4-
1);
• Process equipment leaks (ID No.ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream (ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debugging (ID No. ES-1004-1) and one associated cartridge filter (ID No.
CD-1004-1-FFI);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, isohexane storage
tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation
column EX-490008 and nine process tanks of various capacities (TD No. ES-1004-2-P)and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen)condenser system (ID No.CD-1004-2EX1003);
• Process equipment leaks(ID No.ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
■ Biomass extraction operations wastewater stream(ID No.ES-1003-10-WW);
■ Biomass silo loadout (ID No. ES-1004-2Silo) and one associated bagflter (1D No. CD-1004-2-
FF2); and
• Molecular sieve(ID No.ES-MSDU-1024)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder,biomass extraction
debugging, and biomass silo loadout:
Particulate inatter E=4.10P°�' 15A NCAC 2D ,0515
Where:E=allowable emission rate in pounds per
hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0530
See Sections 2.213.1 and 2.2 B.2
Volatile organic compounds Compliance Assurance Monitoring 15A NCAC 2D .0614
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
15A NCAC 2D .1111
Hazardous Air Pollutants Maximum Achievable Control technology 15A
4D FR Part 63, Subpart
See Section 2.2 C.1 (Botanical extraction only) 40
Permit 01819T43
Page 17
Regulated Pollutant T Limits/Standards Applicable Regulation
Toxic Air Pollutants State.-Enforceable Only 15A NCAC 2Q .07051.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .1100
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (ID No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
E=4.10xP
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.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.l.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0515.
Monitoring Recordkeepin [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the plant material grinder, the biomass extraction debagging
operation, and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a
cartridge filter (ID No. CD-1004-1-17171), and a bagfilter (ID No. CD-1004-2-17172), respectively. To
assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and rmaintained.
d. The results of inspections and maintenance shall be maintained in a log (written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following.
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any iaintenance performed on the cartridge filter and bagfilters; and
iv. 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)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall sulunit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between
Permit 01819T43
Page 18
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
a. Visible emissions from the botanical extraction operations and the biomass extraction operations 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)]
Testing [I5A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2,1 D.2.a, above, the Permittee shall be deemed in noncompliance with I5A NCAC 2D
.0521.
Monitoring U5A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources
for any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly
observation must he made while the associated source is operating. If a source does not operate during a
monthly period, then a record documenting such non-operational status will satisfy this monitoring
requirement for that source. If visible emissions from a source are observed to be above normal, the
Permittee shall either:
i. Take appropriate action to correct the above-nonnal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2601 (Method 9)for 12 minutes is below the limit given in Section 2.1 D.2.a,
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting
, [I5A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered 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.
Permit 0 1819T43
Page 19
3. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR §64.2]
a. For the immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks (ID No.
ES-1001-11-1-P) and the immersion extractor Z-41001, desolventizer Z-41002, day tank 490025,
isohexane storage tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013,
distillation column EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P), the
Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this source
complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D.3 of this permit.
Control Rea uirementslParameter ranges [t 5 A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P)
shall be controlled by the associated cryogenic condenser system(ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system (ID No.CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40
degrees Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003
whenever the associated sources are operational; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F
for cryogenic condenser system CD-1004-2EX1003 whenever the associated sources are
operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.e.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D,3,c,i through iv, below, are not
performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1001-11-
EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D,3.b,
above,operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1004-
2EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above, operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems CD-1001-11-
EX1003 and CD-1004-2EX 1003 in accordance with Section 2.2 B.Lg, below; and
iv. The Permittee shall install,maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems CD-1001-11-EX1003 and CD-1004-2EX1003 in accordance with
Section 2.2 B.Lh, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system CD-1001-11-EX1003 or CD-
1004-2EX1003 operate under conditions qualifying as an excursion for more than 5 percent of the
operational time of their associated sources listed in Section 2.1 13.31, above, during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR §64.8.
For the purposes of this permit condition excursions are defined as operation of cryogenic condenser
system CD-1001-11-EX1003 or CD-1004-2EX1003 with a 12-hour average outlet temperature that
exceeds the associated limit cited in Sections 2.1 D.3.1b.i and ii, ahove, while the associated emission
sources are operating.
Permit 01 S 19T43
Page 20
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request.The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along wide any actions taken to correct the
outlet temperature of cryogenic condenser system CD-1001-11-EX1003 or CD-1004-2EX1003;
iii. The results of any inspections or maintenance performed on cryogenic condenser system CD-1001-
11-EX1003, cryogenic condenser system CD-1004-2EX1003, or the associated temperature gauges;
and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-nionth
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
he clearly identified.
E. Two biomass boilers (ID Nos. ES-BB1 and ES-BB2) and an associated propane/No. 2 fuel oil-
fired rotary dryer(ID No. ES-RD) operated in series controlled by a cyclone (ID No.CD-BBIQ
in series with a bagfYlter(LD No.CD-BB1BH)
The following;table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Boilers aD Nos. ES-BBI and BB2): 15A NCAC 02D .0503
matter 0.33 pounds per million Btu heat input
Rotary dryer(ID No. ES RD):
Particulate u 67 15A NCAC 02D.0515
matter E=4.10(P)
Sulfur 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
dioxide
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 02D .0521
emissions period
NIA Initial notification requirements, 15A NCAC 02D .0524
Notification of boiler size and fuel combusted, and NSPS—Subpart Dc
Record and maintain amount of each fuel cotnbusted
during each calendar month.
PM,HCI, Per Subpart 15A NCAC 02Q.1111
CO,Hg, MACT Subpart DDDDD
Dioxins/Fura
ns
Permit 01819T43
Page 21
L Te. stingy[15A NCAC 02Q A508(f)
Under the provisions of North Carolina.General Statute 143-215.108, in order to verify emission factors used
for calculating CO (0.54 lb/MMBtu)and NOx(0.22 lbIMMBtu)emissions the Permittee shall perform a stack
test on one of the boilers for CO and NOx within 60 days after start-up. The testing shall be conducted in
accordance with a testing protocol (using testing protocol submittal form) approved by the Division of Air
Quality. Details of emission testing requirements can be found in Section 3—General Condition JJ. If testing
shows emissions greater than the emission factors used, the Permittee must notify the Regional Office
Supervisor,in writing,no later than 60 days following the stack test date.
2. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos.ES-BB1 and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
hca.t input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition J.T.
If the results of this test are above the limit given in Section 2.1 A. 1. a. above,the Pennittee shall be
deemed in noncompliance with 15A NCAC 2D.0503.
Monitoring [15A NCAC 2Q .0508(o]
C. Particulate matter emissions from the boiler shall be controlled by a cyclone in series witb a bagfilter.
To assure compliance,the Pennittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and iaintenance recommendations, or if
there is no manufactureC's inspection and maintenance recommendations, as a minimum,the inspection
and maintenance requirement shall include the following:
i. monthly external inspection of the ductwork, cyclone, and bagfilter noting the structural
integrity; and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Pennittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone, bagfilter,
and ductwork is not inspected and maintained.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a log(written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i.the date and time of each recorded action;
ii. the results of each inspection;
iii.a report of any iaintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall suhinit a report of any
maintenance performed on the cyclone and bagfilter.
f. 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-montb 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.
Permit 01819T43
Page 22
3. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate inatter from the rotary dryer(ID No.ES-RD)shall not exceed an allowable emission rate
as calculated by the following equation: [I5A NCAC 2❑.0515(a)]
E=4.10 x P 0-157 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition.1.1. If the
results of this test are above the Iimit given in Section 2.1 E. 2. a. above,the Permittee shall be deemed in
noncompliance with 15A NCAC 213.0515.
Monitoring/Recordkeeping[15ANCAC 2Q.0508(f)]
c. The Permittee shall maintain production records such that the process rates"P" in tons per hour,as specified by the
formulas contained above(or the formulas contained in 15A NCAC 213.0515)can be derived,and shall make
these records available to a DAQ authorized representative upon request.The Pennittee shall be deemed in
noncompliance with 15A NCAC 2❑.0515 if the production records are not maintained or the types of materials
and finishes are not monitored.
4. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source 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 A.La. above,the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
c. No monitoringlrecordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
5. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(11)Nos. ES-BB1, ES-BB2,and ES-RD) 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 mare 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)]
Testin [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E. 3. a. above,the Pennittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
For boilers (ID Nos. ES BBI and ES BB2):
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance,once a day the Permittee shall observe the emission points of the boilers(11)
Nos. ES-BB1 and ES-13132) for any visible emissions above normal. The daily observation must be
made for each day of the calendar year period to ensure compliance with this requirement. The
Permittee shall be allowed three(3) days of absent observations per semi-annual period. The Permittee
Permit 01819T43
Page 23
shall establish"normal"for the boilers in the first 30 days following the effective date of the permit. If
visible emissions from this source are observed to be above normal, the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 213 .2610(Method 9) for 12 minutes is below the limit given in Section 2.1 E.3. a.
above.
If the above-normal emissions are not corrected per(i) above or if the demonstration in (ii)above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log(written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. the date and time of each recorded action:
ii. the results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii, the results of any corrective actions performed.
The Pcrmittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer(ID No. ES-RD):
1lZonitoring(RecordkeepinglReporting [15A NCAC 2Q .0508(f)]
f No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel
oil in the rotary dryer(ID No. ES-RD).
6. 15A NCAC 2D.0524: NSPS 40 CFR PART 60 SUBPART De
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as promulgated in 40
CFR Part 60 Subpart Dc, including Subpart A "General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUILREMENTS-In addition to any other required by 40 CFR 3 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 3 60.7)or reconstruction (40 CFR 3 60.15)of an affected facility is
commenced,postmarked no later than 30 days after such date, and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Rcoordkeeping [15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR 60.48c or recordkeeping requirements of
the EPA, the Permittee shall record and maintain records of the amounts of each fuel fired during each
day. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0524 if these records are
not maintained.
Permit 0 18 19T4 3
Page 24
7. 15A NCAC 02D.1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers (ID Nos. ES-BBI and ES-13132) are subject to 40 CFR Part 63, Subpart DDDDD.
F. Four emergency generators and fire water pump (ID Nos. E101, E102, E103,E1.04, and FP)
The following table provides a Summary of limits and standards for the emission sources)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible 20 percent opacity 15A NCAC 02D.0521
emissions
NIA NIA 15A NCAC 021).1111—
Subpart ZZZZ
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source 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(1)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3, If the results of this test are above the limit given in Section 2.1 A.La. above, the Pennillee shall be
deemed in noncompliance with 15A NCAC 2D.0516.
c. No monitoring/recordkeeping/ is required for Sulfur dioxide emissions from the firing of No. 2 fuel oil in these
sources.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event sliall the six-minute average exceed 87 percent opacity.
[15A NCAC 2D .0521 (d)]
Testing[15A NCAC 2Q.0508(f)]
b. if emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 F. 2. a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 21).0521.
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in these
sources.
3. 15A NCAC 213.1111 [40 CFR Part 63 Subpart ZZZZI;
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Slandard 15A NCAC 21).1111,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,
Subpart ZZZZ,"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines",by December 13,2004.
Alonitorin2/Recordkeepin,aIReportine [I 5A NCAC 2Q.0508(f}j
b. No monitoring/recordkeeping/reporting requirements.
Permit 01819T43
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2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources [all permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101,H-102, and H-103]
The following,table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 2D .0958
Odorous emissions State-Enforceable Only 15A NCAC 21).180ti
Odorous emissions must be controlled
1. 15A NCAC 2D .0958. WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D .0958, for all sources that use volatile organic compounds (VOC) as
solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that
inix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a
product of chemical reactions,the Pennittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, when not
in use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety
procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile
organic compounds,
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other
coating equipment into closable containers and close such containers immediately after each use,or
transfer such solvents to closed tanks, or to a treatment facility regulated under section 402 of the
Clean Water Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank
or a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 21)
.0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush parts in the freeboard area,
ii. Take precautions to reduce the pooling of solvent on and in the parts,
iii. Tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all
dripping has stopped, whichever is longer,
iv. Not fill cleaning machines above the fill line,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 21) .0958(d)]
Monitoring [15A NCAC 2Q .0508(f)]
c, To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum,perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations. If the required inspections are not
conducted the Pennittee shall be deemed to be in noncompliance with 15A NCAC 21) .0958.
Permit 01819T43
Page 25
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with
rule 15A NCAC;2D .Og58.
Reporting [I 5A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations From the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D.I806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NESHAP source, any increase in toxic air pollutants must be evaluated.
Permit 01819T43
Page 27
B. Three No. 2 fuel oil-Fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 21) .0530
{VOC
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. The following Best Available Control Technology(BACT)limits shall not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tans per Condenser CD-31209
desolventixer, and solvent VOC 10.8 pounds consecutive
separation/recovery per hour 12-month and packed toyer
(ID No. ES-1001-2-1-P1) period
scrubber CD-14Q1-2-5-1
Rotocel equipment leaks VOC Leak detection and
(ID No. ES-1001-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(TD No. ES-100 1-2-1-WW) VOC wastewater treatment
tanks
Where Rwocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-I When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete.
8.76 pounds per hour and 0.53
tons per consecutive 12-month
period
Permit 01819T43
Page 28
Emission Source Pollutant BACT Emission Limits Control Technology
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-100 1-1-
receiver M-21 VDC Operating and Recovet T5B
(ID No. ES-1 001-1-1-P2) Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC Fixed roofs
(ID No. ES-1001-1-1-P3)
Recovery equipment leaks VOC LDAR
(ID No. ES-1 00 1-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting wastewater treatment
(ID No. ES-1001-1-1-W W) of methanol-wash tanks and biological
treatment
Botanical extraction
immersion extractor, 61.76 tons per
desolventizer, first and Condenser CD-1001-11-
second stage evaporators, VOC 14.1 pounds consecutive EX1002 and condenser
distillation column,day tank, per hour period month CD-1001-11-EXi003
and multiple process tanks
(ID No.ES-1001-11-P)
Botanical extraction
VOC
equipment leaks (ID No. ES- LDAR
1001-11-F) (Fe,gllive}
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC wastewater treatment
ES-1 001-11-WW) tanks
Biomass extraction
immersion extractor,
desolventizer,day tank, 61.8 tons per
isohexane storage tank, first. Condenser CD-1004-
and second stage VDCs 14.1 pounds consecutive 2EX1002 and condenser
period
evaporators, distillation Per hour period
th CD-1004-2EX1003
column, and multiple process
tanks
(ID No. ES-1004-2-P)
Permit 01819T43
Page 29
Emission Source Pollutant BAC T Emission Limits Control Technology
Biomass extraction
equipment leaks (ID No. ES- VOCs LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs wastewater treatment
ES-1004-2-WW) tanks
No. 2 fuel-oil fired boilers
(ID Nos. H-101,H-102,H- VDC 0.2 pounds per 1,000 gallons Combustion control
103)
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. 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 [15A NCAC 2Q .0508(f)]
c. The Permittee shall limit the operation of the recovery stripper T-5 and rceeiver M-21 (ID No. ES-
1001-1-1-P2) while source ES-1001-2-1-P1 is not operating to no greater than 34 days in any
consecutive 12-month period.
d, The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-P1) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises) while source ES-1001-2-1-P1 is not operating to no greater than 6 days in
any consecutive 12-month period.
e. The Permittee shall implement the leak detection and repair (LDAR) program of 40 CFR Part 63,
Subpart UU, as per the requirements Section 2,2 B.2, below. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530, if the LDAR program requirements are not implemented.
f. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant (i.e. Wastewater Treatment Plant Aeration Tank No. 1; ID No. WWTP-
AT1) for volatile organic compounds (VDC),when the wastewater stream consisting of methanol-wash
from the recovery operations(ID No. ES-1001-1-1-WW)is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VDC is not
determined every week or if the mass removal efficiency is less than 95%.
g. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.La,
above, shall be controlled by the associated condensers. To assure compliance, the Permittee shall
perform periodic inspections and maintenance as recommended by the equipment manufacturer. In
addition, the Permittee shall perform an annual inspection of each condenser system, including the
following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is under positive gauge pressure, leakage of the
contaminated gas stream. In order to monitor leakage of the coolant, the condensate shall be
inspected for the presence of coolant; and
H. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
h. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
Permit 01819T43
Page 30
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.La, above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The
temperatures output from the sensors shall be continuously monitored and hourly values used to
determine the 24-hour average temperature at the condenser outlets. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the outlet temperatures of the condensers are not
maintained heiow the limits in the table below; or the condensers are not equipped with sensors to
continuously measure the outlet temperatures; or if those sensors are not inspected and maintained..
Emission Source Condenser ID No. Required Outlet Temperature
Recovery areon tank M-1 CD-1001-1-3 45 OF,24-hour average, when
(ID No. ES-1001-1-1-P1) source ES-1001-2-1-PI is not
Recovery stripper T-5 and operating and the tanks are used
receiver M-21 (ID No.ES-1001- CD-1001-1-T5B for concrete processing in the
1-1-p2) recovery operation
Botanical extraction operations CD-1001-11-EXI003 -40°F, 24-hour average
(ID No.ES-1001-11-P)
Biomass extraction operations(ID No. ES-1004-2-P) GD-1004-2EX1003 -40°P, 24-hour average
i. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.1.a,
above, shall also be controlled by the associated packed tower scrubber (TD No. CD-1001-2-5-1),
except as allowed pursuant to Sections 2.2 B.1.c and d, above. To assure compliance, tl)e Permittee
shall perform periodic inspections and maintenance as recommended by the equipment manufacturer.
In addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system (if so
equipped), and perform maintenance and repair when necessary to assure proper operation of the
packed tower scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
The Pennittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the packed tower
scrubber is not inspected and maintained.
J. The Permitter shall install, iaintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor, and an emission stream inlet temperature sensor for packed tower
scrubber CD-1001-2-5-1 in accordance with manufacturer's recommendations. The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530 if the flow ineter and temperature sensors are not
installed, maintained, and calibrated, or if, except as allowed pursuant to Sections 2.2 B.I.e and d,
above:
i. The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
ii. The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeepin2 [15A NCAC 2Q .0508(f)]
k. The Penmittee shall maintain the following records:
Permit 01819T43
Page 31
i. VOC emissions for each calendar month, and for the consecutive 12-month period ending with each
calendar month, from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-PI, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1 00 1-1-1-P2,
and ES-1001-1-1-P3) when source ES-1001-2-1-P] is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations (ID No. ES-1001-11-P); and
(D)Biomass extraction operations(ID No. ES-1004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through j, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall be updated at least
monthly and record the following:
(A)The date and time of each recorded action;
(B) The actual hours of operation of the recovery arcon tank M-1 (ID No. ES-1001-1-1-PI), and
recovery stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), when source ES-1001-2-1-
Pl is not operating;
(C) The actual hours of operation of recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and
source ES-1001-2-1-P1. is not operating;
(D)The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
W WTP-AT1) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(E) The 24-hour average outlet temperature of the associated condenser(s) listed in Section 2.2
B.l.h, above:
(1) When source ES-1001-2-1-P1 is not operating and the Concrete Operations tanks (ID No.
ES-1001-1-2-P) are used for concrete processing in the recovery operation; and/or
(2) When the biomass extraction operations(11)No. ES-1004-2-P)is operating,
(r) The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream
inlet temperature of scrubber CD-1001-2-S-1 at least once each day that source ES-1001-2-1-P1
operates;
(G)The results of maintenance performed on the condensers and scrubber listed in Section 2.2
B.La,above, and the associated temperature sensors and Clow rate gauges; and
(H)Any variance from manufacturer's recommendations,if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
1. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.1.a, above.
m. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received 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. In
addition,the semiannual reports shall also contain the following:
i. The monthly VOC emissions from each of the following sources for each of the previous 17
months; and
(A)Rotocel and recovery operations (ID Nos, ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-I-P2,
and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-PI, ES-1001-1-1-P2,
Permit 01819T43
Page 32
and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations(ID No. ES-1001-11-P); and
(D)Biomass extraction operations (ID No. ES-1004-2-P).
ii. The cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.m.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D.0530: Prevention of Significant Deterioration]
Equipment identification [15A NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified. Identification of the equipment does not require
physical tagging of the equipment. For example,the equipment may be identified on a plant site plan, in
log entries, by designation of process unit or affected facility boundaries by some form of weatherproof
identification, or by other appropriate methods. In addition to the above, the following equipment shall
be specifically identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe miumer to perform monitoring;
(Connectors need not be individually identified if all connectors in a designated area or length of
pipe are identified as a group,and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rapture disk upstream of the pressure device;
iii. Valves, pumps, and connectors that are designated unsafe-to-monitor (i.e., Permittee has
determined that monitoring personnel would be exposed to an immediate danger as a consequence
of complying with the monitoring requirements);and
iv. Valves that are difficult-to-monitor (i.e., Permittee has determined that the valve cannot be
monitored without eIevating the monitoring personnel more than seven feet above a support surface
or it is not accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-
to-monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
explanation why the equipment is unsafe or difficult-to-monitor. These records must be kept at the plant
and be available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times, but not more frequently than the periodic monitoring
schedule otherwise applicable,and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment
at least once per calendar year and repair of the equipment if a leak is detected.
C. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process
unit shutdown. The identity of connectors designated as unsafc-to-repair and an explanation why the
connector is unsafe-to-repair shall be recorded.
Instrument and sensory monitoring for leaks [15A NCAC 2Q .0508(f)]
d. histrnment monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
Permit 01819T43
Pabc 33
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak
to the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instnunent response factor criteria in section 3.1.2, paragraph(a) of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis.The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there
is no instrument commercially available that will meet the performance criteria specified above,the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid,calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures
specified in Method 21 of 40 CFR part 60, appendix A.
iv. Calibration gases shall be zero air (less than 10 parts per million of hydrocarbon in air); and the
gases shall be mixtures of methane in air at a concentration no more than 2,000 parts per million
greater than the leak definition concentration of the equipment monitored, If the monitoring
instrument's design allows for multiple calibration scales, then the lower scale shall be calibrated
with a calibration gas that is no higher than 2,000 parts per million above the concentration
specified as a leak, and the highest scale shall be calibrated with a calibration gas that is
approximately equal to 10,000 parts per million.A calibration gas other than methane in air may be
used if the instrument does not respond to methane or if the instrument does not meet the
performance criteria specified Method 21 of 40 CFR part 60, appendix A. In such cases, the
calibration gas may be a mixture of one or more of the compounds to be measured in air.
v. Monitoring shall be perfonned when the equipment is in VOC service.
g. The Permittee may elect to adjustor not to adjust the instrument readings for background.
i. If the Pen nittee elects not to adjust instrument readings for background,the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,
above. In such cases, all instrument readings shall be compared directly to the applicable leak
definition for the monitored equipment to determine whether there is a leak or to determine
compliance with operational standards for pressure relief devices.
ii. If the Permitter elects to adjust instrument readings for background, the Permittee shall
(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B) Determine the background level using the procedures in Method 21 of 40 CFR part 60,
appendix A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored
equipment to determine whether there is a leak or to determine compliance operational
standards for pressure relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at
the time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
Permit Q 1819T43
Page 34
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair. The written procedures may be included as part of the startup, shutdown,
and malfunction plan, or may be part of a separate document that is maintained at the plant
site. In such cases, reasons for delay of repair may be documented by citing the relevant
sections of the written procedure (i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts, there must be documentation
that the spare parts were sufficiently stocked on-site before depletion and the reason for
depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
L The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar days
after it is detected, except as provided for in delay of repair and/or unsafe to repair connectors. A first
attempt at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at
repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring that
the seal flush is operating at design pressure and temperature.First attempt at repair for valves includes,
but is not limited to,tightening the bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the
packing gland nuts,and/or injecting lubricant into the lubricated packing,
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring.
Identification that has been placed on equipment determined to have a leak, except for a valve or for a
connector in gas/vapor or light liquid service,may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and, where appropriate, why the repair was
technically infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical, but no later than the end of the next
process unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed
for a valve if valve assembly replacement is necessary during the process unit shutdown, and valve
assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked
before the supplies were depleted. Delay of repair beyond the second process unit shutdown will
not be allowed unless the third process unit shutdown occurs sooner than six months after the first
process unit shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if:
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair, and
(B) When repair procedures are effected, the purged material cannot be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a duality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg, below) will provide better performance, or the repair is completed as
soon as practical, but not later than 6 months after the leak was detected and one of the following is
used;
(A)A dual mechanical seal system;
(B) A pump that meets has no external shaft penetrating the pump housing; or
Permit.01819TA 3
Page 35
(C) A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNapor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines
a leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak,the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with
less than one percent leaking valves.
(B) The Permittee may elect to monitor each valve once every four quarters for process units with
less than 0.5 percent leaking valves.
(C) The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the
monitoring frequency provisions to each subgroup. If the Permittee subdivides the valves in the group
of process units,then the following provisions apply.
i. The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup. Valves with less
than one year of monitoring data or valves not monitored within the last twelve months must be
placed initially into the most frequently monitored subgroup until at least one year of
monitoring data have been obtained.
(B)Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to
a less frequently monitored subgroup provided that the valves to be reassigned have not leaked
for the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the
valve or group of valves is to be reassigned to a subgroup being monitored annually). Non-
repairable valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so
indicate the performance in the next periodic report.If the overall performance of total valves in the
applicable process unit or group of process units is two percent leaking valves or greater, the
Permittee shall no longer subgroup and shall revert to the program required in Section 2.2 B.2.p. for
that group of process units. The Permittec can again elect to comply with the valve subgrouping
procedures if future overall performance of total valves in the process unit or group of process units
is again less than two percent. The overall performance of total valves in the applicable process unit
or group of process units shall be calculated as a weighted average of the percent leaking valves of
each subgroup according to following equation.
Permit 01 S 19T43
Page 36
%VL,. X V)
%VLfJ —— "
n
Y Vi
i=I
Where: %VLo=Overall performance of total valves in the applicable process unit or group of
process units
%VLi =Percent leaking valves in subgroup i,most recent value
Vi =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee sball maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for caeb subgroup for each monitoring period;
(C) Which valves are reassigned, the last monitoring result prior to reassignment, and when they
were reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next
monitoring period of the decision to subgroup valves. The notification shall identify the
participating process units and the number of valves assigned to each subgroup, if applicable, and
may be included in the next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for eaeb process group (i.e., botanical extraction,
biomass extraction, and Rotocellrecovery) for comparison with the sub grouping criteria specified in
Section 2.2 B,2,m, above, and the percent, leaking valves for each monitoring period for each process
unit or valve subgroup shall be calculated using the following equation.
%VL = L )XI00
VT
Where: %VL = Percent leaking valves.
VL = Number of valves found leaking, excluding non-repairahle valves and including those
valves found whose repair was not confirmed with hoth post leak repair monitoring
and periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly, or semiannual monitoring frequencies, the percent leaking valves shall be the arithmetic
average of the percent leaking valves from the last two monitoring periods. When determining
monitoring frequency for each process unit or valve subgroup subject to annual or biennial (once every
2 years) monitoring frequencies, the percent leaking valves shall be the arithmetic average of the
percent leaking valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time
the valve is identified as leaking and non-repairable. Otherwise, a numher of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in
regulated material service at a process unit or affected facility, the number of non-repairable valves
Permit 0 1 819T43
Pagc 37
exceeding one percent of the total number of valves in regulated material service shall be included
in the calculation of percent leaking valves.
p. If a leak is determined,then the leak shall be repaired. After a leak has been repaired,the valve shall he
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and
first attempt at repair. The monitoring shall be conducted to determine whether the valve has
resumed leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides
with the time specified. Alternatively, other monitoring may be performed to satisfy the
requirement regardless of whether the tinning of the monitoring period for periodic monitoring
coincides with the time above.
iii. If a leak is detected by monitoring that is conducted after leak repair, the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) if the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy tine
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1, above, and the Permittee shall monitor the valve according to the
written plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
pen-nit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that
is designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b, above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection, the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of
2,000 parts per nullion (ppm) or greater it shall be repaired using the procedures in Sections 2.2
B.2.i through 2.2 B.21, above; or
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly
visual inspection provided that each pump is visually inspected as often as practical and at least
monthly.
t. If, whcnn calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak, the Permittee
shall implement a. quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.gg,
below.The Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except
that pumps found leaking in a continuous process unit within one month after start-up of the pump
shall not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
%PL = IPLP Ps}_PS x100
T
Permit 01819T43
Page 38
Where: °/GPL=Percent leaking pumps
PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current
monitoring period.
PT =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in}gas and vapor service and in light liquid service standards [15A NCAC 2Q .0509(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater thau or equal to 500 parts per million is
measured, a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this
requirement and shall be monitored and inspected according to the written plan specified in Section 2.2
B.2.b, above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year),
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but
less than 0.5 percent, then monitor within four years. The Permittee may comply with this
requirement by monitoring at least 40 percent of the connectors within two years of the start of the
monitoring period, provided all connectors have been monitored by the end of the four year
monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical, but within the next six months, all connectors that have not yet
been monitored during the monitoring period if the percent leaking connectors is greater than or
equal to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new
monitoring period shall be started based on the percent leaking connectors of the total
monitored connectors.], or
(B) Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
iv. If,during the monitoring,a connector is found to be leaking, it shall be re-monitored once within 90
days after repair to confirm that it is not leaking.
v. The Pcrmittee shall keep a record of the start date and end date of each monitoring period under
this section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows.
%C, = CT
X 100
T
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
Cr = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried, insulated in a manner tliat prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
Permit 0 18 19 T4 3
Page 39
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding,or
v. Not able to be accessed in a safe manner to perform monitoring
are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory, or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [I5A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below,each pressure relief device in gas and vapor service
shall he operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of
less than 500 parts per million, as soon as practical, but no later than five calendar days after each
pressure release,except as provided for in delay of repair provisions of this permit;
iL The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background, and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during
the monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar
days after each pressure release, except as provided for in delay of repair.
Quality improvement program for pumps [15A NCAC 2Q .0508(f)]
bh. If, on a fi-month rolling average, at least the greater of either 10 percent of the pumps in a process unit
or three pumps in a process unit leak, the Permitter shall implement a quality improvement plan until
the number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in
the process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t,above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program. The data may be collected and the records may be
maintained on a process unit,affected facility, or plant site basis.
i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design(e.g., external shaft, flanged body); materials of construction;
if applicable, barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. 1're maximum instrument readings observed in each monitoring observation before repair, response
factor for the stream if appropriate, instrument model number, and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site) remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seat failures and were
removed from the process unit due to leaks. 1-he inspection shall determine the probable cause of the
pump seal failure or of the pump leak and shall include reconunendations, as appropriate, for design
changes or changes in specifications to reduce leak potential.
ee. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above, to determine the services, operating or maintenance practices, and pump or pump seat designs or
technologies that have poorer than average emission performance and those that have better than
Permit 01819T43
Page 40
average emission performance. The analysis shall determine if specific trouble areas can be identified
on the basis of service, operating conditions or maintenance practices, equipment design, or other
process-specific factors.
i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the services), operating conditions, or pump or pump seal
designs associated with poorer than average emission performance. A superior performing pump or
pump seal technology is one with a leak frequency of less than 10 percent for specific applications
in the process unit. A candidate superior performing pump or pump seal technology is one
demonstrated or reported in the available literature or through a group study as having low emission
performance and as being capable of achieving less than 10 percent leaking pumps in the process
unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process
unit duc to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site, a company,
am
or a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The
quality assurance program may establish any number of categories, or classes, of pumps as needed to
distinguish among operating conditions and services associated with poorer than average emission
performance as well as those associated with better than average emission performance. The quality
assurance program shall be developed considering the findings of the data analysis required under
paragraph Section 2.213.2.ee, above, and the operating conditions in the process unit. The quality
assurance program shall be updated each year as long as the process unit has the greater of either 10
percent or more leaking pumps or has three leaking pumps.
i. The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage, or other applicable identified critical parameters.
(B)Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C) Provide for an audit procedure for quality control of purchased equipment to ensure
conformance with purchase specifications.
(D)Retail off-line pump maintenance and repair procedures. Thesc procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program,
gg. Three years after the start of the quality improvement program,the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
Pennit 01819T43
Page 41
been identified as superior emission performance technology and that comply with the quality
assurance standards for the pump category. Superior emission performance technology is that category
or design of pumps or pump seals with emission perfonnance that when combined with appropriate
process, operating, and maintenance practices, will result in less than 10 percent leaking pumps for
specific applications in the process unit. Superior emission performance technology includes material
or design changes to the existing pump, pump seal, seal support system, installation of multiple
mechanical seals or equivalent, or pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number
of pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero
integer value. The minimum number of pumps or pump seals shall be one. Pump replacement shall
continue until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above,
are pumps determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the
next planned process unit shutdown, provided the number of pump seals and pumps replaced is
equivalent to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shall maintain records for the period of the quality improvement program for the process
unit prescribed below.
i. When using a pump quality improvement program,the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B)Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,
above, and any recommendations for design or specification changes to reduce leak frequency;
and
(C) The beginning and ending dates while meeting the quality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak, the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream, the operating conditions and maintenance practices.
iv. All records documenting the quality assurance prograrn for pumps as specified in the quality
assurance program, including records indicating that all pumps replaced or modified during the
period of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg,above.
Recordkeepin2 requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not
physically tagged and the Permittee is electing to identify the equipment through written documentation
such as a log or other designation.
J. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
mm. For valves, the Permittee shall maintain the monitoring schedule for each process unit and the
valve subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pwnp visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service, the Permittee shall keep records of
the dates and results of monitoring following a pressure release.
qq. For a pump QIP program,the Permittee shall maintain the following records:
i. Individual pump records as specified in Section 2.2 B.2.ce, above;
Permit 01 S 19T43
Page 42
ii. Quality assurance program documentation as specified in Section 2.2 B.2.ff,above; and
iii. Quality improvement program records as specified in Section 2.2 13.2.hh, above.
Reporting requirements [15A NCAC 2Q .0508(f)]
rr. The Permittee shall submit a.summary report of monitoring and recordkeeping activities postmarked or
received 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 in summary format by equipment type(i.e., valves in gas/vapor/light
liquid service, Pumps in light liquid service, and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves,pumps and connectors, and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired, and for valves
and connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
U. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection
instrument reading, of less than 500 parts per million, report the results of all monitoring to show
compliance conducted within the semiannual reporting period.
vv. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report,if applicable,the initiation of a quality improvement program for pumps.
Permit 0 18 1 9T43
Page 43
C. Sclareolide(SDE) Operations, including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity; 1D No.M-20);
• Process equipment leaks (ID No.ES-1001-1-4-F);
■ Four batch reactors (ID Nos. M-10, M-10A, D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate; Ill No. CD-M-34); and
• SDE Operations wastewater stream(ID No.ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide, including:
■ Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks (ID No.ES-1001-1-3-F);
• One distillation column(6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for Sclareolide purification wastewater stream (113 No. ES-1001-
1-3-WW)
Ethyl Vanillin Glucoside (EVG) Operations, including:
• One water spray fume scrubber (0.5 gallon per minute minimum water injection rate; ID No.
CD-Z-9215) venting to one water spray fume scrubber (0.5 gallon per minute minimum water
injection rate; ID No.CD-Z-9216)controlling emissions from:
o Three reactors (ID Nos. D-2202,D-1215,and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks (ID No. ES-1003-2-2-F); and
■ EVG Operations wastewater stream(ID No. ES-1003-2-2-WW)
Sclareol Recrystallizati.on (SFG) Operations,including:
• Four process tanks (2,500 gallons capacity each; ID Nos.T-3002 through 3005);
• One hexane storage tank(6,700 gallon capacity; ID No.T-3001);
■ One centrifuge(ID No. C-3001);
• One chilled water condenser(ID No. CD-3001) controlling emissions from-
- One reactor(ID No.R-3001) equipped with a process chilled water condenser(EX-3001)
- One reactor(ID No.R-3002)equipped with a process chilled water condenser(EX-3003)
- One steam heated dryer(ID No.D-3001)
• Process equipment leaks(ID No. ES-1003-10-17);
• SFG Operations wastewater stream (ID No.ES-1003-10-VL NV)
Plant Nutrient Extraetion (PNE) Operations, including one water spray fume scrubber (0.5
gallon per minute minimum water injection rate; ID No. CD-Z-9215) venting to one water
spray fume scrubber (0.5 gallon per minute minimum water solution injection rate; ID No.
CD-Z-9216) controlling emissions from:
• One product extract reactor (ID No.D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities(ID No.ES-1003-2-1-P);
• One centrifuge(ID No.C-31203);
■ One process solvent tank(ID No. ES-TK-PNE-1)
■ Process equipment leaks(ID No.ES-1003-2-1-F);
■ One waste solids separator vessel (1,333 gallon capacity; ID No. D31211) and one associated
chilled water condenser (ID No. EX2205); and
Permit 01919T43
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PNE Process wastewater stream (1D No. ES-1003-2-1-W%V)
Concrete Operations, including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and 1113-4);
■ Process equipment leaks (ID No.ES-1001-1-2-F); -
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser(ID No.CD-1001-1-2); and
■ Concrete Operations wastewater stream(ID No.ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C, above;
Two Storage and Recycle Tanks (1D No. ES-M-125A and M-125B)
Recovery Operations, as described in Section 2.1 C, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-AT1)
The fbUowtE table provides a summary of limits and standards for the emission souree(s)describe above:
Regulated Pollutant Limits/Standards --FApplicable Regulation
Maximum Achievable Control 15A NCAC 2D .1111
Hazardous Air Pollutants(HAP) Technology [40 CFR Part 63, Subpart
11 FFFF]
1. 2D.1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63,Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF, including Subpart A "General Provisions". For convenience, some of the
relevant definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435,
63.2440, 63.2445(b), and 63.25501
Group I batch process vent means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions froin all of the batch process vents are greater than or equal to
10,000 lb/yr at an existing source or greater than or equal to 3,000 ib/yr at a new source.
Group 2 batch process Neat means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group 1 continuous process vent means a continuous process vent for which the flow rate is greater
than or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b), is less than or equal to 1.9 at an existing source and less than or
equal to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not meet the definition of
a Group 1 continuous process vent.
Group 1 storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group I wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria.for Group 1 status in §63.2485(c) for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in §63.132(d)for compounds in Table 8 to subpart G of this part 63.
Permit 01819T43
Page 45
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group 1 wastewater stream.
In organic HAP service means that a piece of equipment either contains or contacts a fluid (liquid or
gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions
of§63.180(d). The provisions of§63.180(d) also specify how to determine that a piece of equipment is
not in organic HAP service.
M veellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in §63.2435(b). For
the purposes of this subpart, process includes any, all or a combination of reaction, recovery,
separation, purification, or other activity, operation, manufacture, or treatment which are used to
produce a product or isolated intermediate.
Nonstandard batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch.A nonstandard batch may be necessary as a result of a malfunction,but
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of
an MCPU as described by records specified in §63.2525(b).
Paint of determination means each point where process wastewater exits the MCPU or control device.
Standard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions from a standard batch are based on the operating
conditions that result in highest emissions. Tfie standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Rep uirementslLimitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.1.bd through v, below:
i. The Permittee must submit a Notice of Compliance Status Report for the SDE Operations, the
Concrete Operations, and/or the PNE Operations prior to the operation of those operations in
organic HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63,
Subpart FFFF apply to those operations,pursuant to 40 CFR§63.2520(d).
ii. Opening a safety device, as defined in §63.25509 is allowed at any time conditions require it to
avoid unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. if a Group 2 emission point becomes a Group 1 emission point, the Permittee must be in
compliance with the Group 1 requirements beginning on the slate the switch occurs. An initial
compliance demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within
150 days aflcr the switch in group status occurs. The Permittee shall be deemed in non-compliance
with 15A NCAC 2D .1111 if the Pemiittee does not meet these requirements. [40 CFR
§63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR§63.6(e) for the affected sources. The Pennittee is not,however,required to
address equipment leaks (except for control devices) or Group 2 emission points in the SSM Plan,
The SSM Plan must describe, in detail, procedures for operating and maintaining the affected
sources during periods of startup, shutdown, and malfunction; and corrective actions for
malfunctioning process, control,and monitoring equipment used to comply with Subpart FFFF. The
SSM Plan does not need to address any scenario that would not cause an affected source to exceed
an applicable emission limit in Subpart FFFF. The SSM Plan must be maintained on site and made
available for inspection by authorized personnel. [40 CFR§§63.6(e)(3)and 63.25256)]
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the
Pen-nit 01819T43
Page 46
requirements of Sections 2.2 C.1.b.i through v,above.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
c. The Permittec shall comply with the specific requirements of Sections 2.2 C.l.e.i through vii,below:
L Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.1.c.i(A) and (B), below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.g through j,
above.
(B) For contiuuous process Gent associated with the Botanical Extraction Operations,the Permittee
shall perform the monitoring found in Sections 2.2 B.1.g and h, above.
ii. Batch process vents: To ensure compliance; the Permittee shall perform the monitoring of
Sections 2.2 C.1.c.ii(A)through(C),below,for the affected batch process vents:
(A)For the batch process vents associated with the SFG Operations. the EVG Operations, and the
Biological conversion equipment for purification of sclareolide, the Permittee shall comply
with the requirements of 40 CFR §63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF. To
maintain Group 2 classification for these emission sources the organic HAP emissions must be
less than 10,000 pounds per consecutive 365-day period, each source. The Permittee shall
monitor the organic HAP emissions from each of these emission sources, monthly, as follows:
(1) Organic HAP emissions from the SFG Operations shall calculated using the following
equation:
r oun.dsl ( ounds ounds ourzds1Organic HAP= 37.89I � f xBtf +[11.45p �xRgI+ 15.03�8 )xBrec + 9.7<p ) B,�tank all batch ` hatch 6utr:h
Where: BSeg = The number of regular batches processed in the SFG Operations; and
B,, = The number of recrop batches processed in the SFG Operations
Bte = The number of third crop batches processed in the SFG Operations; and
Btf = The number of hexane tank(T-3001) fills.
(2) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HifP= 1.0 poundr x B
hatch
Where: B = The number of batches processed in the EVG Operations
(3) Organic HAP emissions from the Biological conversion equipment for purification of
selareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x$
batch
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B)The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.Le.ii(A)(1)through (3),above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations, the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of
40 CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,
combined. The Permittee shall monitor the organic HAP emissions from these batch process vents,
monthly, as follows:
Permit 01819'143
Page 47
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 11.3 pou�ds x B f 31.8 pounds x B
hatch r� batch r"
Where: B,,, = The number of regular batches processed in the EVG Operations; and
B,, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.l.c.iii(A), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Permittee shall comply
with the requirements of 40 CFR §63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair
(LDAR) program found in Section 2.2 B.2, above, for the equipment associated with the affected
sources.
vi. Wastewater streams: For the wastewater streams associated with the affected miscellaneous
organic chemical manufacturing processes (MCPU), the Permittee shall comply with the
requirements of 40 CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca,
Inc. facility; and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2, unless the conditions of Section 2.2 C.l.b.iv, above, have been
met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will
be used to detect leaks of process fluids into cooling water. This plan shall require monitoring
of one or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more
process parameters or other conditions that indicate a leak. The plan shall include the
following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s) or conditions(s) that shall constitute a leak. This shall be
documented by data or calculations showing that the selected levels or conditions will
reliably identify leaks. The monitoring must be sufficiently sensitive to determine the range
of parameter levels or conditions when the system is not leaking. When the selected
parameter level or condition is outside that range, a leak is indicated;
(3) The monitoring frequency which shall be no less frequent than monthly for the first 6
months and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after
discovery of the leak.
Permit U 1819T43
Page 48
(C) The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded,retain the most recent superseded plan at least until 5 years from
the date of its creation.
(D)if a leak is detected in any heat exchanger system, it shall he repaired as soon as practical but
not later than 45 calendar days after the Permittee receives results of monitoring tests indicating
a leak, unless the Permittee demonstrates that the results are due to a condition other than a
leak. Once the leak has been repaired, the owner or operator shall confirm that the heat
exchange system has been repaired within 7 calendar days of the repair or startup, whichever is
later, except where the Permittee appropriately applies the delay of repair provisions found in
Section 2.2 C.1.e.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the
process. Delay of repair is also allowed if repair is technically infeasible without a shutdown
and any one of the conditions listed in 40 CFR §f 3.104(e)(1)through(2)is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.c.i through vii, above.
RecordkeeRing Requirements [15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.l.dd through v,below.
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B) An identification of related process vents (including associated emissions episodes),
wastewater points of determination (PODS), and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents,the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of
operating and/or testing conditions for any associated control device;
(E) The process vents, wastewater POD, transfer racks, and storage tanks (including those from
other processes) that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G) Calculations and engineering analyses required to demonstrate compliance,
iii. For each affected MPCU with a Group 2 process vent, the Permittee shall retain the following
records:
(A)A record of the day each hatch was completed;
(B)A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a
non-standard batch; and
(D)Records of the daily 365-day rolling summations of emissions, or alternative records that
correlate to the emissions(e.g.,number of batches),calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream, the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds l isted in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw),including documentation of the methodology used to determine concentration; and,
(D) Stream flow rate(in liters/min).
v. For each affected heat exchanger system,the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak, the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan,including the date the leak was discovered;
Permit 01819T43
Page 49
(C) The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittec does not
meet the requirements of Sections 2.2 C.1.d.i through v, above.
Reporting[15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR§63.2460(b)(6) and 40 CFR§63.2520(e)(10).
f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and Decemher, and July 30 of
each calendar year for the preceding six-month period between January and June. The report shall
contain the following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard
specified in this subpart, include a statement that there were no deviations from the emission limits,
operating limits, or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period; and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable), as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered
by the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary Format by equipment type, the number of
components for which leaks were detected and for valves, pumps and connectors show the percent
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required, and for valves and connectors, identify the number
of components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B)Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized, report that delay of repair has occurred and report
the number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report,if applicable, the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay ❑F repair,
include the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s) for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired,the expected date of repair.
Permit 0I819T43
Page 50
2. 15A NCAC 2Q.0317. AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation,the SFG operations shall discharge into the atmosphere
less than 95.29 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .05301
Monitorine/Reeordkeening [I5A NCAC 2Q .0508 (f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format). The Permittec shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed this limit.
Reporting [15A NCAC 2Q ,0508(f)]
d. The Perniittee shall submit a semi-annual 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. The monthly VOC emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
3. LIMITATION TO AVOID BEING CLASSIFIED AS A MON GROUP 1 BATCH PROCESS VENT
a. In order to remain classified as a Group 2 batch process vent for hazardous air pollutants (HAP) under
40 CFR 63, Subpart FFFF, uncontrolled HAP emissions from the SFG operations shall be less than
10,000 pounds per year. The Permittee shall be deemed a Group 1 batch process vent if the HAP
emissions exceed this limit.
Monitorin2/Recordkeepin2 Requirements [15A NCAC 2Q .0508(f)]
b. Maintain monthly calculations of HAP emissions. The Permittee shall be deemed a Group 1 batch
process vent if the records are not maintained.
Reporting Requirements [I5A NCAC 2Q .0503(f)]
c. Submit to the Regional Supervisor, Division of Air Quality, semiannually,a report summarizing HAP
emissions from SFG operations containing the following:
i. greatest quantity in pounds of an individual hazardous air pollutant used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average;
ii. pounds of all hazardous air pollutants used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average.
D. Biomass boilers(il)Nos.ES-BB1 and BB2)
Rotary sage dryer(ID No.ES-RD
I. 15A NCAC ZQ.0317: AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
Permit 01819T43
Page 5 t
a. In order to avoid applicability of this regulation,the above emission sources shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]
Monitorim/Recordkeeping[I5A NCAC 2Q .0508 (f)]
b. For any sage sent to the dryer,the Permittee shall:
i. Measure the sage input on a daily basis,
ii, Measure the hexane content of the sage exiting the process on a weekly basis, The sampling shall
include collecting sage material as it exits the desolventizer before it enters the rotary dryer every
hour for a 24-hour period each week.
iii. Calculate daily VOC emissions by using the daily sage input and the hexane content(lb hexane/lb
sage)determined weekly for the sage drying until the next weekly result is obtained.
c. The facility has determined the potential VOC emissions from both boilers to be 3.57 tons per 12
months or 0.30 tons per month. The Permittee has requested to use 0.15 tons per month of VOC
emitted per boiler for any month in which the boiler(s)operate to determine compliance with this
permit condition.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format).
Reporting [15A NCAC 2Q .0508(f))
e, The Permittee shall submit a semi-annual 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_ The monthly VOC emissions for the previous 17 months.The emissions must be calculated for
each of the 12-month periods over the pre,6ous 17 months.
E. Rotary Sage Dryer(ID No. ES-RD)
1. 15A NCAC 2Q.0317: AVOIDANCE CONDITIONS
LIMITATION TO AVOID 15A NCAC 02D.1112: 112(g) Case by Case Maximum Achievable
Control Technology
a. In order to avoid applicability of 112(g),n-hexane emissions from the rotary dryer(ID No. ES-RD)
shall be less than 10 tons per year.
MonitoringAecordkeeping Requirements [I5A NCAC 2Q .0508(f)]
b. Maintain monthly consumption records of each material containing n-hexane as follows:
i. Maintain a quantity of n-hexane in pounds used in the rotocel operations each month and for the
12-month period ending on that month.
ii. Maintain a record of purchase orders and invoices of materials containing n-hexane that are used in
the rotocel operations.
iii. Utilize the calculations specified in Permit Condition No. 2.2-D.1.b. above and calculate n-hexane
emissions based on the n-hexane content utilized in the rotocel operations as determined at the
desolventizer as the emissions from the rotary dryer.
c, The Permittee shall keep a record of the applicability determination on site at the source for a period of
five years after the determination, or until the source becomes an affected source. The determination
must include the analysis demonstrating why the Permittee believes the source is unaffected pursuant to
40 CFR Part 63.10(b)(3)
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Reporting Requirements [15A NCAC 2Q .0508(f)]
d. The Perrnittee shall submit a semi-annual 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. The monthly n-hexane emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
SECTION 3 - GENERAL CONDITIONS (version 3.6)
This section describes terms and conditions applicable to this Title V facility,
A. General Provisions[NCGS 143-215 and 15ANCAC 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 ux 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 maybe 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 Pernlittee 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 Stateus 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 Pemnittee 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. Severahlliity 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 Regicmal 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,qnality 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:
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Supervisor,Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit),
E. Duty to Comply [I5A NCAC 2Q.0508(i)(3)]
The Penn ittee 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 requirement%constitutes a violation of
the Federal.Clean Air Act. Noncompliance with any permit condition is pounds 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 drat 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 I1Zodifications
1.Administrative Permit Amendments[15A NCAC 2Q.05141
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 i 5A NCAC 2Q.0524 and 2Q
.0505.
3.Minor Permit Modifications[15A NCAC 2Q.0515]
The Permittec shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q.0515.
4.Significant Permit Modifications[I5A 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 Permittee 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 1
must be reported to the Regional Supervisor,DAQ:
a. changes in the ink oration 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)(I0)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 federally enforceable permit
terms and conditions that are monitoring(including test methods),recordkccping,reporting,or compliance
certification requirements.
b. The Permittee may make Section 502(b)(l0)changes without having the pennit revised if:
i. the changes are not a modification under Title 1 of the Federal.Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Penn ittee notifies the Director and EPA with written notification at least seven days before the change
is made;and
Permit 01819T43
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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[15ANCAC 2Q.0523(b)]
The Permitteo 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.Enssions Trading[l5A 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. ReuortinL Requirements for Excess Emissions and Permit Deviations
[15ANCAC 2D.0535(t)and 2Q.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable mission limitation or standard allowed by any
rule in Sections.0500,.0900,.1200,or.1400 of Subchapter 2D;or by a permit condition;or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q.0700. (Nate:Definition ofexcess emissions under 2D,I110 and 2D
.1111 shall aj_?ply 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.1111),or the operating pernut 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 Pennittee 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
• 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 wrilwn report as described in 15A NCAC
2D.0535(f)(3).
Permit De-6ations
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 deti7ations 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 pen-nit requirements.
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I.B. Other Requirements under 15A NCAC 2D.0535
The Pernrittee shall comply with all other applicable requirements contained in 15A NCAC 2D.0535,including 15A
NCAC 2D.0535(c)as follow~:
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 ovmer 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 21].0535(g). Excess enssions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emereency Provisions[40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1.An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitation under the permit due to unavoidable
increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment,lack of preventive maintenance,careless or improper operation,or operator
error.
2.An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based
emission limitations if the conditions specified in 3.below are met.
3.The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Pcrmittee 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 pemut;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)]
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 tern.
Permit expiration terminates the facilitys 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 Permittec 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 inonths before the date of permit expiration for facilities
subject to 15A NCAC 2Q .0400 requirements. In either of these events, all terns 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 Dcfcuse [15A NCAC 2Q.0508(i)(4)]
It shall not be a defense for a Perrnittcc 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. Dub,to Providc Information(submittal of information) [I5ANCAC 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
w_ ritin to determine whether cause exists for modifying,revoking and reissuing,or tenninating 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
Permit 01819T43
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upon request along with a claim of confidentiality.
N. Duty to Supplement[15ANCAC 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.
0. 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[15ANCAC 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 maybe specified under Sections 114(a)(3)or 504)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 terns and conditions of the pennit for the period covered by the certification);
3.whether compliance was continuous or intermittent;and
4.the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Offrcial[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 inlonnation in the document are true,accurate,and complete.
R. Permit Shield for Applicable Requirements[15ANCAC 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 it-,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 incorrecL;
2.the conditions under which the permit or permit.renewal was granted have changed;
3.violations of conditions contained in the permit have occurred;
Permit 01819T43
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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 ofNCGS Chapter 143,Article 21B.
T. Insienifrcant Activities[I SA 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(hat the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement. The Pemuttee 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. Proven►•Rights[15A NCAC 2Q.0508(i)(8)]
This permit does not convey any property rights in tither real or personal property or any exclusive privileges.
V. Inspection and Entry[15ANCAC 2Q.0508(1)and NCGS 143-215.3(a)(2)]
1.Upon presentation of credentials and other documents as may be required by lacy,the Permittee shall allow the DAQ,or
an authorized representative,to perform the following:
a. enter the Pernuttee's premis,es where the permitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions of the permit;
b, have access to and copy,at reasonable times,any records that are required to be kept under the conditions of the
permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring
and air pollution control equipment),practices,or operations,regulated or required under the permit;and
d. sample or monitor substances or paramneters,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 Pennittee under
Section 114 or other provisions of(he 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 assessinent of civil penalties.
W. Annual Tee Payment[15ANCAC 2Q.0508(i)(10)]
1.The Permittee shall pay all fees in accordance with 15A NCAC 2Q.0200.
2.Payment of fees maybe by check or inoney 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 Pemuttee 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
Permittce 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.
Permit 01 8 19T43
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AA.Standard Application Form and Required Information[I5A 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 Pennittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or 11
ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40
CFR Para.82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment
according to the work practices,personnel certification requirements,and certified recycling and recovery equipment
specified in 40 CFR Part 82 Subpart F.
2.The Permittee shall not knowingly vent or otherwise release any Class I or I1 substance into the enviromnent 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 81166. Reports shall be
subnu-ted 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.
LE, 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 117 Allowances[15A NCAC 2Q.0508( )(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 laNNTfully holds under Tide IV of the Federal Clean Air Act.
GG.Air Pollution Emergency Episode[I5A NCAC 213.0300]
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[I5A NCAC 2D.0202]
The Director of the DAQ may require the Permittec 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).
1I, 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 sha11 be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 2D.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.
IJ. 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 inay 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
Permit 01819T43
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Permittee submits emissions testing to the DAQ to demonstrate compliance,the Pennittee shall perform such testing in
accordance with I SA NCAC 2D.2600 and follow the procedures outlined below
-
I, 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 fulfalls 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 time 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 comp]iance 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.
K.K.Reouenine for Cause[15A NCAC 2Q.0517]
1.A pennit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with reinaining permit term of three or more
years;
L additional requirements(including excess emission requirements)become applicable to a source covered by Title
IV;
c. the Director or EPA fords 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 pennit,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 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 pennit is to be reopened,except in
cases of imminent threat to puhlic 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 Reguirements for Non-Operating Equipment[15A NCAC 2Q.0508(i)(1 G)]
Permit 01819T43
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The Penn ittee shall maintain a record of operation for Perm tted equipment noting whenever the equipment is taken from
and placed into operation. During operation the monitoring recordkeeping and reporting requiremems as prescribed by the
permit shall be implemented within the monitoring period.
MM.Fugitive Dust Control Requirement[E 5A 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(t).
"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 begirt operation of the air
emission source(s)and associated air pollution control device(s)until a Title V Air Quality Permit Application is
frlcd 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 Pcrmittee shall submit a,page"E5" of die application forms signed by the responsible official verifying that the
application for the 502(b)(10)change/modification,is true,accurate,and complete. Further note that
modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstruction
requirements.
00.Third Party Participation and EPA Review[15A NCAC 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 availahlc to submit a public petition pursuant to 15A NCAC 2Q.0518 begins at the end of the 45-day
EPA review period.
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
CAIR Clean Air Interstate Rule
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
MALT Maximum Achievable Control Technology
MCPU Miscellaneous Organic Chemical Manufacturing Process Units
NAA Non-Attaimnent Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
DAH 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
SGz Sulfur Dioxide
tpy Tons Per Year
VQC Volatile Organic Compound