HomeMy WebLinkAboutAQ_F_1400008_20150121_PRMT_Permit CDE
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
January 21, 2015
Mr. Peter Craymer
Chief Financial Officer and Senior VP
Bernhardt Furniture Company
P.O. Box 740
Lenoir,NC 28645
Subject: Air Permit No 01755R22
Bernhardt Furniture Company -Plants 2 & 5
Lenoir, Caldwell County, North Carolina
Permit Class: Synthetic Minor -
Facility ID# 1400008
Dear Mr. Craymer:
In accordance with your completed application received October 24, 2014, we are
forwarding herewith Permit No. 01755R22 to Bernhardt Furniture Company - Plants 2 &5, Lenoir,
Caldwell County,North Carolina for the construction and operation of air emissions sources or air
cleaning devices and appurtenances. Additionally, any emissions activities determined from your air
permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have =_
been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note =the records retention requirements are contained in General Condition 2 of the General Conditions -and Limitations.
If any parts, requirements, or limitations contained in this permit are.unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative .
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 150E-23,this air permit shall be final and -
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
Asheville Regional Office-Division of Air Quality
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:828-296-4500/FAX:828-299-7043
Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper
Mr. Peter Craymer
January 21, 2015
Page 2
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 150B-23.
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from January 21, 2015 until December 31, 2022, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements,limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
• A condition requiring stack test results from the wood waste/coal-fired boiler(ID No.
ES-515) be submitted by December 31,2016 is added to the permit with this renewal;
• Language covering NESHAP, Subpart JJJJJJ,Boiler GACT is added to the permit
with this renewal;
• This Permit contains an emissions inventory requirement for the 2021 calendar year as -
part of the next renewal in 2022; and
• 'Permits are now issued for eight years.
Should you have any questions concerning this matter,please contact Christopher Scott at
828-296-4500.
Sincerely,
OIL
77
Paul K. Muller, P.E., Regional Supervisor
Division of Air Quality,NCDENR
PKM:ces
Enclosures
c: Asheville Regional Office
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 01755R22
Issue Date: January 21, 2015 Effective Date: January 21, 2015
Expiration Date: December 31, 2022 Replaces Permit: 01755R21
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws,Rules and Regulations,
Bernhardt Furniture Company- Plants 2 & 5
1828 Morganton Boulevard
Lenoir, Caldwell County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 1400008
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
..........
Plant 2 woodworking operations consisting of
ES-WDSP-2 i one wood material collection 11 CD-203 one simple cyclone j
system installed on woodworking j(136 inches in diameter), and j
E operations CD-219 1 one bagfilter
15 767 square feet of filter area j
_... __._.. . . 1 __ ..q �__.._ ,
Plant 2 wood coating_ and finishing operations consisting of:
.. ......
j ES-SBP-2-226 I one baffle type spray booth i N/A N/A
(NESHAP)..... . ..
ES-SBP-2-240 and two dry.filter type spray booths j
ES-SBP-2-241 j N/A f N/A
(NESHAP) j
ES-SBP-2-271 and two wash off tanks
ES-SBP-2-272 N/A N/A
(NESHAP) 1
Permit No. 0 175 5R22
Page 2
_. . . ___ Control Control System
Emission Emission Source i
Source ID Description System ID p I y Description
Plant 5 woodworking operations consisting of
_.. _ . ... . ..g o n
.P.... ..- _. g. _. . ...._. ..._.. . .. ... .... _.... _..�
ES-WDSP-5 one wood material collection CD-506 cyclone
system installed on I 1(128 inches in diameter), I
woodworking operations CD-507 and
1 i one bagfilter
(4,882 square feet of filter
1 area)
___. _..._. .. ...... ___. __..._ __... _.. ...
CD-501 one bagfilter
1(4,614 square feet of filter
j area)
CD-503 rone cyclone E
4 inches in diameter) E
'Plant 5 wood coating and finishing operations consisting of:
I ES-SBP-5-520, (eight baffle-type spray booths --�
ES-SBP-5-521,
(ES-SBP-5-522,
I �
((ES-SBP-5-523,
I ES-SBP-5-524, N/A j N/A
ES-SBP-5-525,
ES-SBP-5-526 and
ES-SBP-5-527
(NESHAP)
I ES-SBP-5-528 and two dry filter type spray booths I
ES-SBP75-529 I located in automated chair leg
N/A N/A
(NESHAP) finishing system
ES-SBP-5-530 one drying oven
(NESHAP) _ I N/A I N/A I......_.. _...... _ E..:..._ .. ..............-
ES-SBP-5-531 one wash off tank � N/A �� N/A ^�
II(NESHAP)
j ES-Glue —j gluing operations. _ ! _ . N/A N/A i
. .. _ ._ .
Boiler operations consisting of:
ES-515 one wood waste/coal-fired CD-515 multicyclone
boiler(25 million Btu per hour (fourteen 9-inch diameter
maximum heat input)with no ;tubes) I
flyash reinjection
in accordance with the completed application 1400008.14A received October 24, 2014 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environment and Natural Resources, Division of Air Quality(DAQ) and are
incorporated as part of this permit.
S
Permit No. 01755R22
Page 3
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1 Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee.shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0503, 2D .0504, 21) .0512, 21) .0516, 2D .0521, 2D .0535, 2D .0540, 21)
.0605, 2D .I 111 (40 CFR 63, Subparts JJ and JJJJJJ), 2D .1806, 2Q .0315 and 2Q .0317
(PSD Avoidance).
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit,shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and (f).Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request (with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2021 calendar year.
3. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 213 .0503
"Particulates from Fuel Burning Indirect Heat Exchangers,"particulate matter emissions
from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates
listed below:
Source
Emission Limit
(lbs/million Btu)
. _.-_ _..... . _.m..
wood waste/coal-fired boiler G
[ 0.43 firing coal only
(ID No..ES 515). . - JI
4. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 213 .0504
"Particulates from Wood Burning Indirect Heat Exchangers," particulate matter emissions
from the wood burning indirect heat exchangers shall not exceed the allowable emission
rates listed below:
Emission Limit
Source
(lbs/million Btu)
calculated by 21) .0504(f) when firing a
wood waste/coal-fired boiler combination of wood and coal
(ID No. ES-515) --. .. . .-_ __.. .
0.57 firing wood only I
Permit No. 0 175 5R22
Page 4
5. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0512
"Particulates from Wood Products Finishing Plants," the Permittee shall not discharge
particulate matter caused by the working, sanding, or finishing of wood without providing,
as a minimum for its collection, adequate duct work and properly designed collectors, or
other such devices as approved by the Commission.
6. SULFUR DIOXIDE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the
wood waste/coal-fired boiler(ID No. ES-515) shall not exceed 2.3 pounds per million Btu
heat input.
7. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the two dry filter type spray
booths (ID Nos. ES-SBP-2-240 and ES-SBP-2-241), the two dry filter type spray booths
located in automated chair leg finishing system(ID Nos. ES-SBP-5-528 and ES-SBP-5-529)
and the two wood material collection systems installed on woodworking operations (ID Nos.
ES-WDSP-2 and ES-WDSP-5), manufactured after July 1, 1971, shall not be more than 20
percent opacity when averaged over a six-minute period, except that six-minute periods
averaging not more than 87 percent opacity may occur not more than once in any hour nor
more than four times in any 24-hour period. However, sources which must comply with 15A
NCAC 2D .0524 "New Source Performance Standards" or .I I 10 "National Emission
Standards for Hazardous Air Pollutants" must comply with applicable visible emissions
requirements contained therein.
8. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the wood waste/coal-fired
boiler(ID No. ES-515) and the nine baffle type spray booths (ID Nos. ES-SBP-2-226 and
ES-SBP-5-520 through ES-SBP-5-527), manufactured as of July 1, 1971, shall not be more -
than 40 percent opacity when averaged over a six-minute period, except that six-minute
periods averaging not more than 90 percent opacity may occur not more than once in any
hour nor more than four times in any 24-hour period. However, sources which must comply
with 15A NCAC 2D .0524 "New Source Performance Standards" or .1110 "National
Emission Standards for Hazardous Air Pollutants" must comply with applicable visible
emissions requirements contained therein.
9. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of
.a source of excess emissions.that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
Permit No. 01755R22
Page 5
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
10. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints or excessive fugitive
dust emissions from the facility are observed beyond the property boundaries for six minutes
in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile working,plant parking lots,
and plant roads (including access roads and haul roads).
11. TESTING REQUIREMENT- Under the provisions of North Carolina General Statute 143-
215.108 and in accordance with 15A NCAC 2D .0605,the Permittee shall demonstrate
compliance with the emission limit(s) by testing the emission source(s)for the specified
pollutant(s) as follows:
..
Affected Sources I Pollutant Emission Limit _� Test Method_
_.. _ ...... .... O ��_.._ �E�
I as calculated by 2D .05031 Methods 5
E wood waste/coal-fired boiler I Particulate Matter� an 504 and 202
and/or 2D 0
(ID No. ES-515) _ _. 1.
40% Opacity Method 9
a. The Permittee shall arrange for air emission testing protocols to be provided to the
DAQ prior to testing. Testing protocols are not required to be pre-approved by the
DAQ prior to testing. The DAQ shall review testing protocols for pre-approval prior
to testing if requested by the Permittee at least 45 days before conducting the test.
b. To afford the Regional Supervisor, DAQ, the opportunity to have an observer
present, the Permittee shall PROVIDE the Regional Office, in WRITING, at least 15
days notice of any required performance test(s).
c. Two copies of the test results must be submitted to the Regional Supervisor, DAQ, in
accordance with the approved procedures of the Environmental Management
Commission by December 31,2016.
d. This permit may be revoked, with proper notice to the Permittee, or enforcement
procedures initiated, if the results of the test(s) indicate that the facility does not meet
applicable limitations.
Permit No. 0 175 5R22
Page 6
e. The source shall be responsible for ensuring, within the limits of practicality, that the
equipment or process being tested is operated at or near its maximum normal
production rate, or at a lesser rate if specified by the Director or his delegate.
f. All associated testing costs are the responsibility of the Permittee.
12. 15A NCAC 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - The
wood furniture manufacturing operations nine baffle type spray booths (ID Nos. ES-SBP-2-
226 and ES-SBP-5-520 through ES-SBP-5-527), two dry filter type spray booths (ID Nos.
ES-SBP-2-240 and ES-SBP-2-241), three wash off tanks (ID Nos. ES-SBP-2-271,ES-SBP-
2-272 and ES-SBP-5-531),two dry filter type spray booths located in automated chair leg
finishing system (ID Nos. ES-SBP-5-528 and ES-SBP-5-529) and one drying oven (ID No.
ES-SBP-5-530) shall comply with all requirements of 15A NCAC 2D .1111 "Maximum
Achievable Control Technology" and 40 CFR Part 63, Subpart JJ "National Emission
Standards for Wood Furniture Manufacturing Operations." [40 CFR 63.800]
Regulated Material Emission Limitation
thinners 10%by weight HAP
;stains, washcoats, sealers, topcoats, basecoats,'
1.0 lb VHAP/lb solids, as applied
and enamels
washcoat, basecoat, or enamel formulated coatings - 1.0 lb VHAP/lb solids
onsite thinners - 3.0%by weight VHAP
strippable spray booth coatings 0.8 lb VOC per lb solids, as applied
foam contact adhesives used in products
which meet flammability requirements per
California Technical Bulletin 116, 117, or
133, the Business and Institutional Furniture 1.8 lb VHAP per lb solids, as applied
Manufacturers Association's (BIFMA's)X5.7,
UFAC flammability testing, or any similar
requirements from local, State, or Federal fire
regulatory agencies
all other contact adhesives 1.0 lb VHAP/solids, as applied
1.0%o by weight formaldehyde or 400 pounds
coatings and contact adhesives formaldehyde emissions per rolling 12-month
period
a. Definitions and Nomenclature -For the purpose of this permit condition,the
definitions and nomenclature contained in 40 CFR 63.801 shall apply.
b. Regulated Pollutants - Volatile Hazardous Air Pollutants (VHAPs) and Volatile -
Organic Compounds (VOCs) as defined in 40 CFR 63.801.
c. General Provisions - The Permittee shall comply with the requirements of 40 CFR
Part 63, Subpart A "General Provisions," according to the applicability of Subpart A
to such sources, as identified in Table 1 of 40 CFR Part 63, Subpart JJ.
Permit No. 01755R22
Page 7
d. Work Practice Standards - The Permittee shall adhere to the work practice standards
as specified by 40 CFR 63.803.
e. Recordkeeping Requirements - The Permittee shall prepare, maintain, and follow a
written work practice implementation plan in accordance with 40 CFR 63.806(e)that
defines environmentally desirable work practices for each wood furniture
manufacturing operation and addresses each of the work practice standards specified
below:
i. Operator Training- in accordance with 40 CFR 63.803(b);
ii. Inspection and Maintenance Plan- in accordance with 40 CFR 63.803(c);
iii. Cleaning and Washoff Solvent Accounting System - in accordance with 40 _
CFR 63.803(d);
iv. Chemical Composition of Cleaning and Washoff Solvents - in accordance
with 40 CFR 63.803(e);
V. Spray Booth Cleaning- in accordance with 40 CFR 63.803 ft-
vi. Storage Requirements - in accordance with 40 CFR 63.803(g);
vii. Application Equipment Requirements - in accordance with 40 CFR
63.803(h); Effective November 21,2014 conventional air spray guns are
allowed only when emissions are vented to a control device;
viii. Line Cleaning - in accordance with 40 CFR 63.803(i);
ix. Gun Cleaning - in accordance with 40 CFR 63.8030);
X. Washoff Operations - in accordance with 40 CFR 63.803(k); and
xi. Formulation Assessment Plan- in accordance with 40 CFR 63.803(1).
f. Reporting Requirements -The Permittee shall submit the compliance status report to
the Regional Supervisor by in accordance with 40 CFR 63.804(f)(8) and 40 CFR
63.807(b). The Permittee shall submit semi-annual reports to the Regional
Supervisor in accordance with 40 CFR 63.804(g)(8)and 40 CFR 63.807(c). The
Permittee shall follow the reporting requirements in 40 CFR 63.807(e)as required and 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
g. Finishing_Operations -Per 40 CFR 63.804(a)(4), the Permittee has chosen to use the
compliant coatings compliance option for the finishing operations.
i. Emission Limits - The Permittee shall comply with all provision of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations. All
thinners, stains, washcoats, sealers,topcoats,basecoats, and enamels used at
the facility shall meet the emission limitations as detailed in the following
table:
Permit No. 01755R22
Page 8
. ...........
Regulated Material Emission Limitation
thinners 10%by weight HAP
stains,washcoats, sealers,topcoats, 1.0 lb VHAP/lb solids, as applied
i basecoats, and enamels
washcoat, basecoat, or enamel coatings - 1.0 lb VHAP/lb solids
j formulated onsite j thinners 3.0%by weight VHAP
ii. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate for emissions sources of the finishing operation that only
compliant thinners are used and that all stains, washcoats, sealers,topcoats,
basecoats, and enamels, are compliant,as applied, in accordance with 40
CFR 63.804(g)(2) for non-continuous coaters and 40 CFR 63.804(g)(3) for
continuous coaters, as applicable.
iii. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.804(g)(2), 40 CFR 63.806(b)(1) and(b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
iv. Reporting Requirements - The Permittee shall submit semi-annual reports by
January 30 and July 30 of every year,to the Regional Supervisor in
accordance with 40 CFR 63.804(g)(1) and 40 CFR 63.807(c). The Permittee
shall follow the reporting requirements in 40 CFR 63.807(a) following the
applicability criteria in 40 CFR 63.800(d).
h. Finishing Operations -Per 40 CFR 63.804(a)(4), the Permittee may choose as an
ALTERNATIVE OPERATING SCENARIO (AOS) to use both the compliant ---
coatings and the facility averaging compliance options for the finishing operations.
Compliance with each of these options is considered a separate alternate operating
scenario and the Permittee, contemporaneously with making a change from one AOS
to another, shall record in a log the scenario under which it is operating. Records
shall be retained for five years. [15A NCAC 2Q .0508(p)]
AOS1: Compliant Coatings Option
i. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations. All
thinners, stains,washcoats, sealers,topcoats,basecoats, and enamels used at -
the facility shall meet the emission limitations as detailed in the following
table:
Regulated Material Emission Limitation
thinners 10%o by weight HAP
stains,washcoats, sealers,topcoats,
1:0 lb VHAP/lb solids, as applied
basecoats, and enamels
washcoat, basecoat, or enamel coatings - 1.0 lb VHAP/lb solids
•. formulated onsite thinners - 3.0% by weight VHAP
Permit No. 01755R22
Page 9
ii. Compliance Procedures and Monitoring Requirements -Emission sources of
the finishing operations are using non-continuous coaters. The Permittee shall
demonstrate that only compliant thinners are used and that all stains,
washcoats, sealers,topcoats, basecoats, and enamels, are compliant, as
applied, in accordance with 40 CFR 63.804(g)(2).
iii. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.804(g)(2), 40 CFR 63.806(b)(1) and(b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
iv. Reporting Requirements - The Permittee shall submit semi-annual reports by
January 30 and July 30 of every year, to the Regional Supervisor in
accordance with 40 CFR 63.804(g)(2) and 40 CFR 63.807(c). The Permittee -
shall follow the reporting requirements in 40 CFR 63.807(a) following the
applicability criteria in 40 CFR 63.800(d).
AOS2: Facility Averaging Option
V. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(1) as applicable to the finishing operations. The
weighted average VHAP content across all coatings, as applied, shall not
exceed 1.0 kg VHAP per kg solids.
vi. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate that the monthly average VHAP content for all finishing
materials used at the facility is no greater than 1.0 kg VHAP per kg solids, as =-
applied, in accordance with 40 CFR 63.803(g)(1).
vii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
viii. Recordkeeping Requirements - Permittee shall keep records in accordance
with 40 CFR 63.806(a) following the applicability criteria in 40 CFR
63.800(d), 40 CFR 63.804(g)(1), 40 CFR 63.806(b)(1) and (b)(2), 40 CFR
63.806(c), 40 CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
ix. Reporting Requirements - The Permittee shall submit semi-annual reports by
January 30 and July 30 of every year,to the Regional Supervisor in
accordance with 40 CFR 63.804(g)(1) and 40 CFR 63.807(c). The Permittee
shall follow the reporting requirements in 40 CFR 63.807(a) following the
applicability criteria in 40 CFR 63.800(d).
i. Cleaning Operations
i. Emission Limits - The Permittee shall comply with the limits of 40 CFR
63.802(a)(3) applicable to the strippable spray booth operations as detailed in
the following table:
Permit No. 0 175 5R22
Page 10
..... _
Regulated Material Emission Limitation
strippable spray booth coatings 0.8 lb VOC per lb solids, as applied
ii. Compliance Procedures and Monitoring Requirements - When the emission
source is using foam and other contact adhesives,the Permittee shall
demonstrate that only compliant adhesives are used in accordance with 40
CFR 63.804(g)(5).
iii. Performance Test Method -EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements - The Perrnittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.806(b)(1) and (b)(3), 40 CFR 63.806(h), 40 CFR
63.806(i), and 40 CFR 63.8060).
v. Reporting Requirements - The Permittee shall submit semi-annual reports by
January 30 and July 30 of every year,to the Regional Supervisor in
accordance with 40 CFR 63.804(g)(7) and 4.0 CFR 63.807(c). The Permittee
shall follow the reporting requirements in 40 CFR 63.807(a)following the
applicability criteria in 40 CFR 63.800(d).
j. Formaldehyde Requirements - The permittee shall comply with one of the following
two options by November 21, 2014 and thereafter:
i. . Option#1 (400 pounds formaldehyde limit per rolling 12 month period)-
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b),
limit total formaldehyde (Ftotal) use in coatings and contact adhesives
to no more than 400 pounds per rolling 12 month period.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), calculate total formaldehyde
emissions from all finishing materials and contact adhesives used at
the facility using Equation 5 and maintain a value of Ftotal no more
than 400 pounds per rolling 12 month period.
C. Recordkeeping_Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep records of the formaldehyde content,-in
pounds per gallon, as applied, of each finishing material and contact
adhesive subject to the emission limits of 40 CFR 63.802(a) and(b).
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40-CFR
63.807(c).
ii. Option#2 (CPDS < 1.0%by weight formaldehyde) -
Permit No. 01755R22
Page 11
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b),use
coatings and contact adhesives only if they are low-formaldehyde
coatings and adhesives, in any wood furniture manufacturing
operations. Low formaldehyde means, in the context of a coating or
contact adhesive, a product concentration of less than or equal to 1.0
percent formaldehyde by weight, as described in a certified product
data sheet for the material.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), demonstrate compliance by use
of coatings and contact adhesives only if they are low formaldehyde
coatings and contact adhesives maintaining a certified product data
sheet for each coating and contact adhesive used and submitting a
compliance certification with the semi-annual report.
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),the Permittee shall keep a certified product data sheet for each coating
and contact adhesive used.
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR 40
CFR 63.807(c) and 40 CFR 63.804(h). The compliance certification
shall state that low-formaldehyde coatings and contact adhesives, as
applicable, have been used each day in the semiannual reporting
period or should otherwise identify the periods of noncompliance and
the reasons for noncompliance. An affected source is in violation of
the standard whenever a coating or contact adhesive that is not low- =—
formaldehyde, as demonstrated by records or by a sample of the
coating or contact adhesive, is used. Use of a noncompliant coating or
contact adhesive is a separate violation for each day the noncompliant
coating or contact adhesive is used. The compliance certification shall
be signed by a responsible official of the company that owns or
operates the affected source.
13. GENERALLY AVAILABLE CONTROL TECHNOLOGY-For Boiler 5 (ID No. ES-515),
the Permittee shall comply with all applicable provisions, including the notification,testing,
and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111, as promulgated in 40 CFR 63, Subpart JJJJJJ, "National
Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial,
and Institutional Boilers", including Subpart A "General Provisions."
a. Compliance Dates (40 CFR 63.11196) - The owner or operator of an existing source
is required to comply with the tune-up and the energy assessment requirements no
later than March 21, 2014.
Permit No. 01755R22
Page 12
b. Compliance Requirements -As required by 15A NCAC 2D .I 111, the Permittee
shall comply with the following requirements:
i. General Duty Clause (40 CFR 63.11205(a)) -At all times the Permittee shall
operate and maintain any affected source,including associated air pollution
control equipment and monitoring equipment, in a manner consistent with
safety and good air pollution control practices for minimizing emissions.
ii. Boiler Tune-up (40 CFR 63.11223) -An initial boiler tune-up is required by
March 21, 2014. If the unit is not operating on the required date for a tune-up,
the tune-up must be conducted within thirty days of startup. The Permittee
shall comply with the following with respect to the tune-up:
A. Periodic tune-ups: A biennial tune-up is required and shall be
conducted no more than 25 months after the previous tune-up. The
following units are only required to conduct a tune-up every five
years: seasonal boilers (shutdown for 7 consecutive months or 210
consecutive days each 12-month period due to seasonal conditions;
only biomass or oil), limited-use boilers, and units with oxygen trim
systems, as defined in 40 CFR 63.11237. Each five-year tune-up must
be conducted within 61 months of the previous tune-up.
B. Fuel required for'the tune-up: The Permittee shall conduct the tune-up
while burning the type of fuel (or fuels in the case of boilers that
routinely burn two types of fuels at the same time) that provided the
majority of the heat input to the boiler over the 12 months prior to the,
tune-up.
C. As applicable, inspect the burner, and clean or replace any
components of the burner as necessary. The Permittee may delay the
burner inspection until the next scheduled unit shutdown, but must
inspect each burner at least once every 36 months (72 months for 5-
year tune-ups).
D. Inspect the flame pattern, as applicable, and adjust the burner as
necessary to optimize the flame pattern. The adjustment should be
consistent with the manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio, as applicable, and -
ensure that it is correctly calibrated and functioning properly. The
Permittee may delay the air to fuel ratio inspection until the next
scheduled unit shutdown, but must conduct the inspection at least
once every 36 months (72 months for 5-year tune-ups).
F. Optimize total emissions of carbon monoxide. This optimization
should be consistent with the manufacturer's specifications, if
available, and with any nitrogen oxide requirement to which the unit
is subject.
Permit No. 01755R22
Page 13
G. Measure the concentrations in the effluent stream of carbon monoxide
in parts per million, by volume, and oxygen in volume percent, before
and after the adjustments are made (measurements may be either on a
dry or wet basis, as long as it is the same basis before and after the
adjustments are made). Measurements may be taken with a portable
CO analyzer.
c. Notification and Reporting Requirements - In addition to the notification and
reporting requirements of the Environmental Protection Agency(EPA), the
Permittee is required to prepare a Compliance Report. This report shall be prepared
by March 1 of every year starting March 1 the year following the first periodic tune-
up,and submitted upon request. If the source experiences any deviations from the
applicable requirements then the report must be submitted by March 15. The report
must meet the requirements of 40 CFR 63.11225(b)(1-4). -
d. Recordkeeping Requirements - In addition to any other recordkeeping requirements
of the EPA,the Permittee shall maintain the following records as defined under 40
CFR 63.11225(c):
i. Copies of all required notifications.
ii. Maintain the following records to document conformance with the work
practices, emission reduction measures, and management practices:
A. Tune-up records -records must identify each boiler,the date of tune-
up,the procedures followed for tune-up, the manufacturer's
specifications to which the boiler was tuned, and the following: _—
I. The concentrations of CO-in the effluent stream in parts per
million, by volume, and oxygen in volume percent, measured
at high fire or typical operating load,before and after the tune-
up of the boiler.
2. A description of any corrective actions taken as a part of the
tune-up of the boiler.
3. The type and amount of fuel used over the 12 months prior to
the tune-up of the boiler but only if the unit was physically
and legally capable of using more than one type of fuel during
that period. Units sharing a fuel meter may estimate the fuel
use by each unit.
B. A copy the Energy Assessment required by 40 CFR 63.11214(c).
C. Seasonal boilers - For each boiler that meets the definition of seasonal
boiler, you must keep records of days of operation per year.
D. Records of non-waste determinations per 40 CFR 63.11225(c)(2)(ii).
Permit No. 01755R22
Page 14
iii. Malfunction Records - Records of the occurrence and duration of each
malfunction of the boiler, or of the associated air pollution control and
monitoring equipment. Records of actions taken during periods of
malfunction to minimize emissions in accordance with the general duty to
minimize emissions in 40 CFR 63.11205(a), including corrective actions to -
restore the malfunctioning boiler, air pollution control, or monitoring
equipment to its normal or usual manner of operation.
iv. Record Retention-You must keep each record for 5 years following the date
of each recorded action.
14. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating -
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
15.LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee, facility-wide
emissions shall be less than the following:
Pollutant Emission Limit
( (Tons per consecutive 12-month period)
PM10 100
SOZ 100
VOC 100
individuallIAI?sl. 10 -
j Total HAPs 25
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. The amount of woodwaste combusted in the boiler(ID No.ES-515) shall be
less than 10,159 tons per consecutive 12-month period.
ii. The amount of coal combusted in the boiler(ID No. ES-515) shall be less
than 626 tons per consecutive 12-month period. -
iii. The sulfur content of the coal shall be limited to 0.88% sulfur by weight.
iv. If multiple fuels are used, emissions should be determined using the sum of
the individual emissions rates.
b. Inspection and Maintenance Requirements
i. Bagfilter Requirements - Particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions of
Permit No. 01755R22
Page 15
this permit and ensure that emissions do not exceed the regulated limits,the
Permittee shall perform periodic inspections and maintenance (I&M) as
recommended by the manufacturer. In addition, the Permittee shall perform,
at a minimum, an annual internal inspection of each bagfilter system.
ii. Cyclone Requirements - Particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions of
this permit and ensure that emissions do not exceed the regulatory limits,the
Permittee shall perform, at a minimum, an annual inspection of each cyclone
system. In addition, the Permittee shall perform periodic inspections and
maintenance (I&M) as recommended by the manufacturer.
iii. Multi-Cyclone Requirements -Particulate matter emissions shall be
controlled as described in the permitted equipment list. To comply with the -
provisions of this permit and ensure that emissions do not exceed the
regulatory limits,the Permittee shall perform, at a minimum, an annual
internal inspection of the multi-cyclone system. In addition,the Permittee
shall perform periodic inspections and maintenance (I&M)as recommended
by the manufacturer.
c. Recordkeeping Requirements
i. The Permittee shall maintain purchase orders and invoices of materials
containing VOCs. These purchase orders and invoices shall be maintained for
a period of at least three years and be made available to DAQ personnel upon
request.
ii. The Permittee shall record monthly and total annually the following: -_
A. coal and woodwaste combusted;
B. the sulfur content, by weight, of the coal combusted; and
C. the facility-wide VOC, Individual and Total HAPs emissions.
iii. Fuel supplier certification shall be kept on-site and made available to DAQ
personnel upon request.
iv. A log book shall be kept on site for the three bagfilters (ID Nos. CD-219,
CD-501 and CD-507),the three cyclones (ID Nos. CD-203, CD-503 and CD-
506) and one multicyclone (ID No. CD-515), and made available to Division
of Air Quality personnel upon request. The Permittee shall record all
inspection, maintenance and monitoring requirements listed above in the log
book. Any variance from the manufacturer's recommendations shall be
investigated with corrections made and date of actions recorded in the log
book.
d. Reporting Requirements - Within 30 days after each calendar year, regardless of the
actual emissions,the Permittee shall submit the following emissions and/or
Permit No. 01755R22
Page 16
operational data listed below. The data should include monthly and 12 month totals
for the previous 12 month period.
i. the pounds of VOC used during the previous calendar year;
ii. the greatest quantity in pounds of an individual HAP used during the
previous calendar year;
iii. the total pounds of all HAPs used during the previous calendar year;
iv. the amount of woodwaste combusted;
V. the amount of coal combusted;
vi. fuel supplier certification for the load of coal received within the last 12
months with the highest sulfur content; and
vii. the Permittee shall certify all submittals as to the truth, completeness, and
accuracy of all information recorded and reported over the signature of the
appropriate official as identified in rule 15A NCAC 2Q .03040)
"Applications."
16. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - In accordance with 15A NCAC 2Q .0317, to comply with this permit
and avoid applicability of 15A NCAC 21) .0530 "Prevention of Significant Deterioration,"
as requested by the Permittee, volatile organic compound (VOC) emissions shall be limited
as follows:
I Emission Limit(Tons Per
Affected Source(s) Pollutant Consecutive 12-month Period
two dry filter type spray booths I
VOC,total 40
(ES-SBP-2-240 and ES-SBP-2-241)1
Compliance with this regulation is established through the Synthetic Minor recordkeeping
requirements listed in Specific Condition 15 above.
Permit No. 01755R22
Page 17
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR
RENEWAL,AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,NC 28778
828=296-4500
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT- In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT-Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 2Q .0301, a new air permit = -
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions; -
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
Permit No. 01755R22
Page 18
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1),the facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit,no emission source may operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1),this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the -
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605,reports on the operation and maintenance of the -
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to,process weight rates, firing rates,hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials,nor shall any person
obstruct,hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act (RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT- In accordance with 15A NCAC 2Q .0110,the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request,the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r)REQUIREMENTS -Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permit No. 01755R22
Page 19
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants -Prevention of
Accidental Releases - Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces,processes, handles, or stores any amount of a listed
hazardous substance, the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee -
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification,report submittal, and test
results approval.
Permit issued this the 21St of January, 2015. -
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
04,A71
Paul K. Muller, P.E. =-
Regional Supervisor By Authority of the Environmental Management Commission -
Air Permit No. 0 175 5R22
ATTACHMENT to Permit No. 01755R22,January 21, 2015
Insignificant/Exempt Activities
Source of
( Source Exemption Source of E Title V
I Regulation ; TAPsI
g ! Pollutants?
rIES-EBOILER-Natural gas-fired boiler 2Q .0102 yes Yes
.375 million Btu/hr heat in ut ca acrt c 2 B ii__.. _._ _ p capacity) .� )� )� )� )
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 'Emission Rates
Requiring a Permit."