HomeMy WebLinkAboutAQ_F_1900030_20140729_PRMT_Permit NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
July 29, 2014
Mr. Larry Saunders
Plant Manager
Arclin USA, LLC
790 Corinth Road
Moncure,NC 27559
Subject: Air Permit No. 04162R21
Arclin USA, LLC
Moncure, Chatham County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1900030
Dear Mr. Sanders:
In accordance with your completed application received May 1, 2014, we are forwarding
herewith Permit No. 04162R21 to Arclin USA, LLC, Moncure, Chatham 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 hearii4request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolinabeneral 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. 15013-23, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
150B-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
Raleigh Regional Office-Division of Air Quality
3800 Barrett Drive,Raleigh,North Carolina 27609
Phone:919-791-4200 1 FAX:919-881-2261
Internet:www,ncdenr.aov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper
Larry Sanders
July 29, 2014
Page 2
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
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 July 29, 2014 until June 30, 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):
• Updated stipulation 2D .0202 with the revised expiration date and corresponding emission
inventory calendar year.
• Removed the storage tanks from under grouped headings and organized them
chronologically under one heading labeled "Storage Tanks."
• Added the additional Phenol Storage tank (ES-M-78) controlled by the existing regenerative
thermal oxidizer, RTO (CD-1).
• Replaced three storage tanks (ES-M-20, ES-M-21, and ES-M-26) as like-for-like
replacements.
• Removed No. 2 fuel oil as a fuel option for ID No. ES-13-1. Changed the ID No. from ES-
B-1 to IS-B-1 and moved the source to the insignificant exempt list exempt per 2Q
.0102(c)(2)(B)(ii), since it is now natural gas fired only and the heat input is less than 65
MMBtu/hr.
• Added IS-B-2 natural gas fired boiler to the insignificant/exempt list exempt per 2Q
.0102(c)(2)(B)(ii), since it is natural gas fired only and the heat input is less than 65
MMBtu/hr.
• Deleted the fuel oil tank(ES-M-98) from the permitted equipment list. Renamed ID No.
IES-DFST as IES-M-96 diesel fuel storage tank(2,000 gallon capacity).
• Added two new railcar cleaning stations (ES-RCC-1 and ES-RCC-2) to the Loading and
Unloading Operations section, controlled by the existing RTO (CD-1).
• Added glycerine storage capability to the existing OF Resin tank(ES-M-35).
• Revised stipulations 2D .0524 NSPS Subpart Kb and 2D .1100 Toxic Air Pollutant
Emissions Limitation and Reporting Requirement.
Larry Sanders
July 29, 2014
Page 3
Should you have any questions concerning this matter, please contact Dena Pittman at 919-791-
4200.
Sincerely,
Patrick Butler, P.E., Regional Supervisor
Division of Air Quality, NCDENR
DLP
Enclosures
c: Raleigh Regional Office
Larry Sanders
July 29, 2014
Page 4
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NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 04162R21
Issue Date: July 29, 2014 Effective Date: July 29, 2014
Expiration Date: June 30, 2022 Replaces Permit: 04162R20
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,
Arclin USA, LLC
790 Corinth Road
Moncure, Chatham County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1900030
(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 I Description System ID Description
Methanol-Formaldehyde Conversion Plant No.1 (MF-1)
ES-A-1 formaldehyde absorption system ICP71 Iregenerative thermal oxidizer
Methanol-Formaldehyde Conversion Plant No.2 (MF-2)
ES-A-2 absorber column(M-F plant no.2) CD-2 thermal oxidizer
(NSPS)
ES-A-3 absorber column(M-F plant no.2)
(NSPS)
Resin Kettles
ES-K-1 resin kettle with a vapor condenser system CD-1 regenerative thermal oxidizer
ES-K-2 resin kettle with a vapor condenser system
ES-K-3 resin kettle with a vapor condenser system
ES-K4 resin kettle with a vapor condenser system'
ES-K-S resin kettle with a vapor condenser system
ES-K-6 resin kettle with a vapor condenser system
I
Permit No. 04162R21
Page 2
Emission Emission Source Control Control System
Source ID Description System ID Description
(Loading and Unloading Operations
ES-TR-I formaldehyde truck loading and unloading CD-1 regenerative thermal oxidizer
area
r ES-RC-1 phenol and caustic railcar unloading area i
ES-RC-3 methanol unloading/formaldehyde
loading railcar area
ES-P-5 lurea unloading pit r— N/A r—�— N/A
IES-RCC-1 Irailcar cleaning operation
CD-1 regenerative thermal oxidizer
ES-RCC-2 railcar cleaning operation
Miscellaneous Sources ~
ES-FUG `iFugitive emissions from MF-2 Plant F N/A
Solid Raw Material Storage
ES-WT-3 urea weigh tank CD-BH-3 bagfilter(602 square feet of filter area)
ES-WT-4 urea weigh tank CD-BH-4 bagfilter(602 square feet of filter area)
ES-WT-5 i urea weigh tank CD-BH-S lbagfilter(602 square feet of filter area)
ES-WTI urea weigh tank CD-BH-1-A, bagfilter(183 square feet of filter area)
CD-BH-1-B (CD-BH-1-A)in parallel with bagfilter
(183 square feet of filter area)(CD-
BH-1-B)
ES-MS-6 melamine storage silo(100 ton storage CD-BH-6 bagfilter(165 square feet of filter area)
capacity)
ES-SB-I Isalt bin CD-BH-7 bagfilter(125 square feet of filter area)
Storage Tanks
ES-M-I( urea formaldehyde storage tank(50,000 CD-1 regenerative thermal oxidizer
gallon storage capacity)
ES-M-14 formaldehyde storage tank(10,000 gallon
storage capacity)
ES-M-IS ^�urea-formaldehyde pre-polymer storage
Ftank(250,000 gallon capacity)
ES-M-16 urea formaldehyde polymer storage tank
1(250,000 gallon storage capacity)
ES-M-17 ` formaldehyde storage tank(125,000
gallon storage capacity)
ES-M-18 formaldehyde storage tank(125,000
gallon storage capacity)
ES-M-20 urea formaldehyde resin storage tank (� ^
(50,000 gallon storage capacity) N/A I N/A T
ES-M-21 urea formaldehyde resin storage tank N/A N/A _
(50,000 gallon storage capacity)
ES-M-22 urea formaldehyde resin storage tank r v
(50,000 gallon storage capacity) N/A N/A
ES-M-23 urea formaldehyde resin storage tank N/A I N/A
(50,000 gallon storage capacity)
Permit No. 04162R21
Page 3
Emission Emission Source FSystem
l Control System
Source ID Description ID Description
ES-M-24 ^urea formaldehyde resin storage tank N/A N/A
(50,000 gallon storage capacity)
ES M-25 urea formaldehyde resin storage tank N/A N/A
_.:.
'(50,000 gallon storage,capacity) j
urea formaldehyde resin storage tank N/A N/A
:(50,000 gallon storage capacity)
[___E:M_-26
ES-M-27 urea formaldehyde resin storage tank ---� N/A N/A
(50,000 gallon storage capacity)
ES-M-28 urea formaldehyde resin storage tank
(27,000 gallon storage capacity) N/A N/A
ES-M-29 urea formaldehyde resin storage tank N/A N/A
1(27,000 gallon storage capacity)
ES-M-30 urea formaldehyde resin storage tank N/A 4 N/A
� (22,000 gallon storage capacity)
ES-M-31 ]phenol storage tank(50,000 gallon storage CD-1 regenerative thermal oxidizer
capacity)
ES-M-34 methanol storage tank(500,000 gallon
N/A N/A
storage capacity)
ES-M-35 phenol formaldehyde resin storage and/or
glycerin storage tank(13,000 gallon N/A N/A
storage capacity)
ES-M-36 �(20,000
ea formaldehyde resin storage tank N/A N/A
�^ gallon storage capacity)
ES-M-37 urea formaldehyde resin storage tank
(NSPS) (17,500 gallon storage capacity) N/A N/A
ES-M-39 urea formaldehyde resin storage tank N/A N/A
(NSPS) 1(17,500 gallon storage tank)
ES-M-45 urea or phenol-formaldehyde resin
(NSPS) storage tank(23,000 gallon storage N/A N/A
capacity)
ES-M-46 urea or phenol-formaldehyde resin storage N/A N/A^
(NSPS) tank(23,000 gallon storage capacity)
ES-M-49 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
ES-M-50 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
[ —1
ES-M-51 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
IES-M-52 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
IES-M-53 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(23,000 gallon storage capacity)
IES-M-54 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
� ES-M-55 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
Permit No. 04162R21
Page 4
Emission Emission Source Control Control System
Source ID Description [System ID Description
ES-M-5 A N/A
(NSPS) tank(33,000 gallon storage capacity) —F
i urea or phenol-formaldehyde resin storage N/
IES-M-57 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(30,000 gallon storage capacity)
ES-M-58 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(33,000 gallon storage capacity)
ES-M-59 urea or phenol-formaldehyde resin storage N/A F
� N/A
�(NSPS) tank(33,000 gallon storage capacity) 1''
ES-M-61 phenol formaldehyde storage tank(15,000 CD-1 regenerative thermal oxidizer
-^u gallon storage capacity)
ES-M-63 urea formaldehyde storage tank(19,000
gallon storage tank)
ES-M-64 urea or phenol formaldehyde resin storage N/A ( N/A
(NSPS) tank(35,000 gallon storage capacity)
ES-M-65 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(35,000 gallon storage capacity)
ES-M-66 �uireaor phenol-formaldehyde resin storage N/A N/A
(NSPS) ank(34,000 gallon storage capacity)
ES-M-67 ^urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(34,000 gallon storage capacity)
ES-M-68 urea or phenol-formaldehyde resin storage N/A I N/A
(NSPS) tank(34,000 gallon storage capacity)
urea or phenol-formaldehyde resin storage N/A
I(NSES-M-69
PS) tank(34,000 gallon storage capacity)
� ES-M-70 urea or phenol-formaldehyde resin storage
(NSPS) tank(34,000 gallon storage capacity) FN/A I N/A
ES-M-71 urea or phenol-formaldehyde resin storage
(NSPS) tank(34,000 gallon storage capacity) -F-1-
N/A N/A
ES-M-72 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(34,000 gallon storage capacity) ����
[u—
ES-M-73rea or phenol-formaldehyde resin storage(NSPS) ank(34,000 gallon storage capacity) N/A _ N/A
ES-M-74 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(34,000 gallon storage capacity)
IES-M-75 urea or phenol-formaldehyde resin storage N/A N/A _
(NSPS) tank(27,500 gallon storage capacity)
ES-M-76 urea or phenol formaldehyde resin storage
(NSPS) tank(27,500 gallon storage capacity) N/A N/A
ES-M-77 urea or phenol-formaldehyde resin storage N/A N/A
(NSPS) tank(41,000 gallon storage capacity)
ES-M-78 phenol storage tank(41,454 gallon storage CD-1 regenerative thermal oxidizer
((NSPS) _ capacity)
ES-M-94 methanol distillate storage tank(20,000 N/A N/A
(NSPS) gallon storage capacity)
Permit No. 04162R21
Page 5
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-M-95 methanol distillate storage tank(20,000 N/A N/A
NSPS) gallon storage capacity)
ES-M-99 formaldehyde resin/washwater storage N/A N/A
(NSPS) tank(20,000 gallon storage capacity)
7
ES-M-100 formaldehyde storage tank(75,000 gallon CD-1 regenerative thermal oxidizer
(NSPS) storage capacity)
ES M-101 formaldehyde storage tank(75,000 gallon
(NSPS) Istorage capacity)
ES-M-102 formaldehyde storage tank(75,000 gallon
(NSPS) storage capacity)
ES-M-103 formaldehyde storage tank(75,000 gallon
(NSPS) storage capacity)
in accordance with the completed application 1900030.11A received May 1, 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.
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 .0515, 2D .0521, 2D .0524 (40 CFR 60, Subpart III, Subpart Kb, and Subpart
VV), 2D .0535, 2D .0540, 2D .0611, 2D .0948, 2D .0949, 2D .0958, 2D .1100, 2D .1806,
2Q .0315 and 2Q .0317 (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 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the emission sources shall not exceed allowable emission rates. The allowable emission rates
are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be
Permit No. 04162R21
Page 6
determined by the following equation(s), where P is the process throughput rate in tons per
hour(tons/hr) and E is the allowable emission rate in pounds per hour(lbs/hr).
E=4.10 * (P) 1,61 for P <= 30 tons/hr, or
E = 55 * (P) "1 - 40 for P >30 tons/hr
4. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
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 .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
5. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For the
methanol-formaldehyde conversion plant (ID No. MF-2) consisting of two formaldehyde
absorbers (ID Nos. ES-A-2 and ES-A-3) the Permittee shall comply with all applicable
provisions, including the notification, testing, reporting, record keeping, and monitoring
requirements contained in Environmental Management Commission Standard 15A NCAC
2D .0524, "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60,
Subpart III [Standards of Performance for Volatile Organic Compound (VOC) Emissions
From the Synthetic Organic Chemical Manufacturing Industry (SOCMI) Air Oxidation Unit
Processes], and including Subpart A "General Provisions".
a. NSPS Emissions Limitations - As required by 15A NCAC 2D .0524 and 40 CFR
Part 60.612, the following permit limits shall not be exceeded:
i. The thermal oxidizer (ID No.CD-2) installed on the formaldehyde absorbers
(ID nos. ES-A-2 and ES-A-3) shall reduce emissions of total organic
compounds or TOC (minus methane and ethane) by 98 weight percent or to a
TOC (minus methane and ethane) concentration of 20 ppmv on a dry basis
corrected to 3 percent oxygen, whichever is less stringent.
b. NSPS Monitoring of Emissions and Operations - As required by 15A NCAC 2D
.0524 and 40 CFR Part 60.613, the following requirements shall be met:
i. The Permittee shall install, calibrate, maintain, and operate according to
manufacturer's specifications the following equipment:
A. A temperature monitoring device equipped with a continuous recorder
and having an accuracy of plus or minus one percent of the temperature
being monitored expressed in degrees Celsius, or plus or minus 0.5
degrees Celsius, whichever is greater.
B. A flow indicator that provides a record of vent stream flow to the
incinerator at least once every hour for each affected facility. The flow
Permit No. 04162R21
Page 7
indicator shall be installed in the vent stream from each affected facility
At a point closest to the inlet of the incinerator and before being joined
with any other vent stream.
C. NSPS Reporting and Record keeping Requirements - As required by 15A NCAC 2D
.0524 and 40 CFR Part 60,615, the following requirements shall be met:
i. The Permittee shall keep up-to-date, readily accessible records of the
following data measured during each performance test; and also include the
following data in the report of the initial performance test required under 40
CFR Part 60.8.
A. The average temperature of the firebox measured at least every 15
minutes and averaged over the same time period of the performance
testing.
B. The percent reduction of TOC determined as specified in 40 CFR Part
60.614(b) achieved by the incinerator, or the concentration of TOC
(ppmv, by compound) determined as specified in 40 CFR Part
60.614(b) at the outlet of the control device on a dry basis corrected to
3 percent oxygen.
ii. The Permittee shall keep up-to-date, readily accessible continuous records of
the equipment operating parameters specified to be monitored under 40 CFR
Part 60.613(a) as well as up-to-date, readily accessible records of periods of
operation during which the parameter boundaries established during the most
recent performance test are exceeded. The Regional Supervisor, DAQ, may
at any time require a report of these data. For the incinerator,the periods of
operation during which the parameter boundaries established during the most
recent performance test are exceeded are defined as follows:
A. All 3-hour periods of operation during which the average combustion
temperature is more than 28 degrees C (50 degrees F)below the
average combustion temperature during the most recent performance
test at which compliance with 40 CFR Part 60.612(a) was determined
iii. The Permittee shall keep up-to-date, readily accessible records of all periods
when the vent stream is diverted from the control device or has no flow rate.
iv. The Permittee shall submit to the Regional Supervisor, DAQ, semiannual
reports of the following information as specified in 40 CFR Part 60.6150)
A. Exceedances of monitoring parameters recorded above in paragraph
c.ii above, and in 40 CFR Part 60.615(c).
Permit No. 04162R21
Page 8
B. All periods recorded above in paragraph c.iii above, and in 40 CFR
Part 60. 615(d), when the vent stream is diverted from the control
device or has no flow rate.
6. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For the
equipment in the process unit described as the methanol-formaldehyde conversion plant (ID
No.MF-2), the Permittee shall comply with all provisions, including the notification, testing,
and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as
promulgated in 40CFR60, Subpart VV, Standards of Performance for Equipment Leaks in
the Synthetic Organic Chemicals Manufacturing Industry.
a. STANDARDS - The Permittee shall comply with the requirements of the leak
standards in 60.482-1 through 60.482-10 as applicable for all equipment in the
affected facility.
The Permittee may elect to comply with the alternative standards for valves in
60.483-1 and 2 and/or request a determination of equivalence of a means of emission
limitation as provided in 60.484.
b. RECORDKEEPING REQUIREMENTS - The Permittee shall comply with the
recordkeeping requirements in 60.486(a) through (h).
Affected facilities applying for exemptions from this subpart per 60.480(d) must
comply with the recordkeeping requirements in 60.486(i).
All records shall be kept in a log in a readily accessible location.
C. REPORTING REQUIREMENTS - The Permittee shall submit semiannual reports to
the Air Quality Regional Supervisor, Division of Air Quality.
All semiannual reports shall include a summary of the recordkeeping requirements
detailed in 60.486.
If electing to comply with the provisions in 60.483-1 and 60.483-2 the Permittee
shall notify the Air Quality Regional Supervisor, Division of Air Quality of the
alternative standard selected 90 days before implementing either of the provisions.
7. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For storage
tanks listed in the table below, the Permittee shall comply with all applicable provisions,
including the notification, testing, reporting, record keeping, and monitoring requirements
contained in Environmental Management Commission Standard 15A NCAC 2D .0524,
"New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart Kb,
including Subpart A "General Provisions."
RECORDKEEPING REQUIREMENTS - Per 40 CFR 60.116b(a) and (b), the Permittee
shall keep records showing the dimension of each storage vessel and an analysis showing
the capacity of each storage vessel readily accessible for the life of the source.
Permit No. 04162R21
Page 9
No. ID No. No. ID No. No. ID No. No. ID No.
1 ES-M-37 11 ES-M-55 21 ES-M-69 31 ES-M-94
2 ES-M-39 12 ES-M-56 22 ES-M-70 32 ES-M-95
3 ES-M-45 13 ES-M-57 23 ES-M-71 33 ES-M-99
4 ES-M-46 14 ES-M-58 24 ES-M-72 34 ES-M-100
5 ES-M-49 15 ES-M-59 25 ES-M-73 35 ES-M-101
6 ES-M-50 16 ES-M-64 26 ES-M-74 36 ES-M-102
7 ES-M-51 17 ES-M-65 27 ES-M-75 37 1 ES-M-103
8 ES-M-52 18 ES-M-66 28 ES-M-76
9 ES-M-53 19 ES-M-67 29 ES-M-77
10 ES-M-54 20 ES-M-68 30 ES-M-78
8. 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.
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.
9. 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
Permit No. 04162R21
Page 10
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).
10. FABRIC FILTER REQUIREMENTS includin cage filters, baghouses, and other dry
filter particulate collection devices - As required by 15A NCAC 2D .0611, particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform, at a minimum, an annual (for each 12 month period following the
initial inspection) internal inspection of each bagfilter system. In addition, the
Permittee shall perform periodic inspections and maintenance as recommended by
the equipment manufacturer.
b. Recordkeeping Requirements - The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook.
The logbook (in written or electronic format) shall be kept on-site and made
available to DAQ personnel upon request.
11. VOC EMISSIONS FROM TRANSFER OPERATIONS - As required by 15A NCAC 2D
.0948 "VOC Emissions from Transfer Operations," the Permittee shall not load in any one
day more than 20,000 gallons of volatile organic compounds with a vapor pressure of 1.5
pounds per square inch or greater under actual conditions into any tank-truck, trailer or
railroad tank car from any loading operation unless the loading operation uses submerged
loading through boom loaders that extend down into the compartment being loaded or by
other methods that are at least as efficient based on source testing or engineering
calculations.
12. STORAGE OF MISCELLANEOUS VOLATILE ORGANIC COMPOUNDS- As required
by 15A NCAC 2D .0949 "Storage of Miscellaneous Volatile Organic Compounds," the
Permittee shall not place, store, or hold in any stationary tank, reservoir, or other container
with a capacity greater than 50,000 gallons, any liquid volatile organic compound that has a
vapor pressure of 1.5 pounds per square inch or greater under actual storage conditions
unless such tank, reservoir, or other container:
a. is a pressure tank capable of maintaining working pressures sufficient at all times to
prevent vapor gas loss into the atmosphere; or
b. is designed and equipped with one of the following vapor loss control devices:
Permit No. 04162R21
Page 11
i. a floating pontoon, double deck type floating roof or internal pan type
floating roof equipped with closure seals to enclose any space between the
cover's edge and compartment wall; this control equipment shall not be
permitted for volatile organic compounds with a vapor pressure of 11.0
pounds per square inch or greater under actual storage conditions; all tank
gauging or sampling devices shall be gas-tight except when tank gauging or
sampling is taking place;
ii. a vapor recovery system or other equipment or means of air pollution control
that reduces the emission of organic materials into the atmosphere by at least
90 percent by weight; all tank gauging or sampling devices shall be gas-tight
except when tank gauging or sampling is taking place.
13. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. As required by 15A NCAC 2D .0958(c), for all sources at facilities that use volatile
organic compounds (VOC)as solvents, carriers, material processing media, or
industrial chemical reactants, or in similar uses.that mix, blend, or manufacture
volatile organic compounds, or emit volatile organic compounds as a product of
chemical reactions; the Permittee shall adhere to the following required work
practices:
i. The Permittee shall store all VOC-containing material not in use (including
waste material) in containers covered with a tightly fitting lid that is free of
cracks, holes, or other defects.
ii. The Permittee shall clean up spills as soon as possible following proper
safety procedures.
iii. The Permittee shall store wipe rags in closed containers.
iv. The Permittee shall not clean sponges, fabric, wood,paper products, and
other absorbent materials.
v. The Permittee shall drain solvents used to clean supply lines and other
coating equipment into closable containers and close containers immediately
after each use.
vi. The Permittee shall clean mixing, blending, and manufacturing vats and
containers by adding cleaning solvent, closing the vat or container before
agitating the cleaning solvent.
vii. The Permittee shall pour spent cleaning solvent into closable containers and
close containers immediately after each use.
b. When cleaning parts with a solvent containing a volatile organic compound, the
Permittee shall:
Permit No. 04162R21
Page 12
i. flush parts in the freeboard area,
ii. take precautions to reduce the pooling of solvent on and in the parts,
iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for
drying or until all dripping has stopped, whichever is longer,
iv. not fill cleaning machines above the fill line,
V. not agitate solvent to the point of causing splashing. [15A NCAC 2D
.0958(d)]
14. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT _Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration, the
following permit limits shall not be exceeded:-
Emission Sources Formaldehyde Phenol Emission
Emission Limits Limits(pounds per
ounds erhour hour
Regenerative thermal oxidizer ID No. CD-1 4.33 5.62
Thermal oxidizer ID No.CD-2 3.28 N/A
ES-M-45,46 and 53 5.74E-05(each) 2.84E-03 (each)
ES-M-49,50,51,52,54, 55 and 57 6.74E-05(each) 3.34E-03 (each)
ES-M-56,58 and 59 7.45E-05(each) 3.69E-03 (each)
ES-M-64 and 65 7.37E-05(each) 3.65E-03 (each)
ES-M-66 Through 71 8.39E-05(each) 4.16E-03 each)
ES-M-99 1.81E-06 3.12E-03
ES-M-72 and 73 6.36E-05(each) 3.28E-03 (each)
ES-M-74 9.29E-05 4.46E-03
ES-M-75 and 76 6.61E-05 (each) 3.28E-03 (each)
ES-M-77 9.00E-05 4.46E-03
ES-M-78 N/A 0.004
ES-M-20 through 27 3.43E-06(each) 5.90E-03 (each)
ES-M-28 and 29 2.02E-06(each) 3.47E-03 (each)
ES-M-30 1.75E-06 3.02E-03
ES-M-36 5.28E-05 2.79E-03
Phenol formaldehyde resin storage tank ID No. 4.1E-05 2.03E-02
ES-M-35
Urea formaldehyde resin storage tanks ES-M-37 4.69E-05 (each) 2,48E-03 (each)
and 39
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following operating restrictions (scenarios) shall apply during control device(s)
maintenance downtime. All sources at facility may operate as requested in the
application during control device(s) maintenance downtime except as described
below:
Sceria�'io Air- 'Scenar�oB�� �;��S�en$rio L��-�x '�`�`cen�rio 1D ,. :,$cenario E •°
RTO down RTO down RTO in RTO in RTO down
(0%DRE) (0%DRE) operation at operation at (0%DRE)
operating at operating at gas flow of gas flow of operating at
as flow of gas flow of 6,000 acfin 6,000 acfin gas flow of
Permit No. 04162R21
Page 13
6,000 acfm 6,000 acfm (minimum) (minimum) 6,000 acfm
(minimum) (minimum) minimum
TO down TO down TO down
(exhausting TO in (exhausting TO in (exhausting
through bypass operation at through bypass operation at through bypass
stack)with gas gas flow of stack)with gas gas flow of stack)with gas
flow of 7,324 26,201 acfm flow of 7,324 26,201 acfm flow of 7,324
acfrn (minimum) acfm (minimum) acfm
(minimum) (minimum) (minimum)
Only one OF Only one OF Only one OF Only one OF
resin kettle in resin kettle in resin kettle in resin kettle in Six kettles in
operation operation operation operation operation, not
during the during the during the during the during the
vacuum step vacuum step vacuum step vacuum step vacuum step
Plant MF-1 not Plant MF-1 not
in operation I in operation
b. Recordkeeping Requirements -During periods of control device(s) maintenance
downtime,the Permittee shall record:
i. the flow rates to the RTO and TO hourly;
ii. the number of process kettles producing urea-formaldehyde resin operating in
the vacuum strip step;
Records in i. and ii. shall be recorded in a log book. The logbook (in written or
electronic form) shall be kept on-site and made available to DAQ personnel upon
request.
15. 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.
16. LIMITATION TO AVOID 15A NCAC 20 .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 air
pollutant emissions shall be less than the amounts tabulated below per consecutive 12-month
period.
Volatile Organic Compounds (VOCs) 100 tons
Carbon Monoxide 100 tons
Formaldehyde and Methanol 10 tons each
Sum of all Hazardous Air Pollutants (HAPs) 25 tons total
Permit No. 04162R21
Page 14
a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the
following restrictions shall apply:
i. Carbon monoxide, formaldehyde, methanol, total VOC and total HAP emissions
shall be controlled by the regenerative thermal oxidizer (ID No. CD-1) and
thermal oxidizer (ID No. CD-2) as described in the equipment list with downtime
allowances as described in section X(d)(iv)below.
b. Recordkeeping Requirements - The Permittee shall record monthly and total annually
the following:
i. the facility-wide carbon monoxide, formaldehyde, methanol, total VOC and total
HAP emissions.
The Permittee shall keep each record on file for a minimum of three years.
c. Reporting Requirements - Within 30 days after each calendar year, regardless of the
actual emissions, the Permittee shall submit the following to the Regional Supervisor,
DAQ, in writing:
i. the monthly carbon monoxide, formaldehyde, methanol,total VOC and total
HAP emissions for the previous 12 months; and
ii. the total carbon monoxide, formaldehyde, methanol, total VOC and total HAP
emissions for the previous 12 months.
d. REGENRATIVE THERMAL OXIDIZER(RTO) AND THERMAL OXIDIZER (TO)
REQUIREMENTS - Carbon monoxide, formaldehyde, methanol, total VOC and total
HAP emissions shall be controlled by the regenerative thermal oxidizer (ID No. CD-1)
and thermal oxidizer(ID No. CD-2) as described in the equipment list with downtime
allowances as described in paragraph(d)(v) below.
i. Inspection and Maintenance Requirements - To comply with the provisions of
this permit and ensure that emissions do not exceed the regulatory limits, the
Permittee shall perform periodic inspection and maintenance (I&M) as
recommended by the manufacturer. As a minimum, the Permittee shall perform
an annual internal inspection of the primary heat exchanger and associated
inlet/outlet valves to ensure structural integrity.
ii. RecordkeepingRequirements - The results of all inspections and any variance
from manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions
recorded in a logbook. Records of all maintenance and monitoring activities
shall be recorded in the logbook. The logbook (in written or electronic form)
shall be kept on-site and made available to DAQ personnel upon request.
Permit No. 04162R21
Page 15
iii. RTO Monitoring Requirements - The Permittee shall ensure the proper
performance of the RTO (ID No. CD-1) by monitoring the following operational
parameters:
A. The Permittee shall record the maximum temperature measured inside the
unit but in the second half of the oxidizer(away from the flame zone)
monthly. The allowable range is between 1,400 and 1,700 degrees
Fahrenheit.
B. The Permittee shall record the gas flowrate to the RTO daily. The maximum
allowable flowrate is 11,800 standard cubic feet per minute, except during
periods of thermal oxidizer maintenance downtime.
iv. TO Monitoring Requirements - The Permittee shall ensure the proper
performance of the TO (ID No. CD-2)by monitoring the following operational
parameters:
A. The Permittee shall record the maximum temperature measured inside the
unit but in the second half of the oxidizer (away from the flame zone)
monthly. The minimum temperature is 1,280 degrees Fahrenheit.
B. The Permittee shall record the gas flowrate to the TO daily. The maximum
allowable flowrate is 11,414 standard cubic feet per minute, except during
periods of maintenance downtime.
V. RTO and TO Downtime Allowance - As requested by the Permittee, emission
sources listed in the permit equipment list controlled by the RTO (ID No. CD-1)
or TO (ID No.CD-2) may operate uncontrolled according to the conditions listed
below. This provision for operation of emission sources without their associated
control equipment is limited only to satisfying maintenance requirements of the
RTO and/or TO. However, under no circumstances shall facility-wide emissions
exceed the Synthetic Minor limitations set forth above.
A. Control Device Downtime Recordkeeping Requirements -The Permittee
shall keep records of the dates and number of hours for each maintenance
downtime of the RTO and/or the TO. Included with these records shall be
calculations for emissions resulting from each RTO and/or TO downtime and
12-month facility-wide totals for the Synthetic Minor pollutants (carbon
monoxide, formaldehyde, methanol, total VOCs and total HAPs).
B. Control Device Downtime Reporting Requirements -The Permittee shall
provide a written report to the Regional Supervisor, Division of Air Quality,
within 7 days of conclusion of each control device maintenance downtime.
This report shall contain a summary of all RTO and/or TO maintenance
downtime over the previous twelve- month period and calculations showing
facility-wide emissions of all Synthetic Minor pollutants over the previous
12-month period.
Permit No. 04162R21
Page 16
17. 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 the applicability of 15A NCAC 2D .0530 "Prevention of Significant
Deterioration," as requested by the Permittee, emissions shall be limited as follows:
Affected Emission Limit(Tons Per
Source(s) Pollutant Consecutive 12-month Period)
Facility Wide ICO 100
Facility Wide [photochemically
OC (Meeting Federal Definition as F10
reactive)
B. GENERAL CONDITIONS AND LIMITATIONS
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
Raleigh Regional Office
3800 Barrett Drive
Raleigh,NC 27609
919-791-4200
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 -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 - 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-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;
Permit No. 04162R21
Page 17
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. 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 granted have changed, or violations of conditions
contained in this permit have occurred. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and.appurtenances.
7. This permit is nontransferable by the Permittee. Future owners and operators must obtain a
new air permit from the DAQ.
8. 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. 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. 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. The Permittee must comply 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.
i
Permit No. 04162R21
Page 18
14. PERMIT RETENTION REQUIREMENT - 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 I I2(r) of the Federal Clean Air Act, then the
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 29`h of July, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
0004
Patrick Butler, P.E.
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 04162R21
ATTACHMENT to Permit No. 04162R21, July 29, 2014
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
IES-M-40 -potassium hydroxide storage 2Q .0102
tank(10,000 gallon storage capacity) (c)(1)(D)(iii) No Yes
IES-QCL - Quality control laboratory 2Q 2Q .0(C)102(iv) YesF Yes
IES-M-96 - diesel fuel storage tank (2,000 2Q .0102
gallon capacity) (c)(1)(D)(i) Yes Yes
IS-B-1 -natural gas fired boiler(25 2Q .0102
million Btu per hour maximum heat input Yes Yes
rate) (c)(2)(B)(ii)
IS-B-2 -natural gas fired boiler(20.08 2Q .0102
million Btu per hour maximum heat input Yes Yes
rate) (c)(2)(B)(ii)
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."