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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."