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HomeMy WebLinkAboutAQ_F_0200005_20140417_PRMT_Permit NCDER North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary April 17, 2014 Mr. Steve Bruton Director of Administration Mitchell Gold Company 135 One Comfortable Place Taylorsville,NC 28681 Subject: Air Permit No. 02815R13 Mitchell Gold Company Hiddenite, Alexander County,North Carolina Permit Class: Prohibitory Small Facility ID#0200005 Dear Mr. Bruton: In accordance with your completed application received April 11, 2014,we are forwarding herewith Permit No. 02815RI 3 to Mitchell Gold Company, Hiddenite, Alexander 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 ad judicatory 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. 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. 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 Mooresville Regional Office-Division of Air Quality 610 East Center Avenue,Suite 301,Mooresville,North Carolina 28115 Phone:704-663-1699/FAX:704-663-7579 Internet:www.ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper Steve Bruton April 17, 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. 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 April 17, 2014 until November 30, 2014, 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): • The stipulation for the "furniture" MACT, Subpart JJ, was amended to include several changes such as the type of spray gun that can be used and formaldehyde limits. • The generator GACT, Subpart ZZZZ was removed from the permit.since only an exempt source is subject to it. A condition for 2Q .0102(d) "Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements"will be added to show the facility has an exempt source subject to ZZZZ. • An avoidance condition for the boiler GACT, Subpart JJJJJJ, was added. The facility has chosen to burn No. 2 fuel oil only in times of curtailment in the boiler(ES-B 1). Should you have any questions concerning this matter,please contact Jennifer Womick at (704) 663-1699.. Sincerely, zo Ronald E. Slack, Regiona. Supervisor Division of Air Quality,NCDENR JAW Enclosures c: Mooresville Regional Office G:\AQ\Shared\WPDATA\COUNTIES\Alexander\00005\R 13_PERMIT.doex NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF AIR QUALITY AIR PERMIT NO. 02815R13 Issue Date: April 17,2014 Effective Date: April 17, 2014 Expiration Date: November 30, 2014 Replaces Permit: 02815R12 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, Mitchell Gold Company 1510 Sharpe Lane Hiddenite, Alexander County,North Carolina Permit Class: Prohibitory Small Facility ID# 0200005 (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 ES-B 1 (NSPS) No.2 fuel oil/natural gas-fired boiler(25.2 million Btu per hour N/A N/A maximum heat input) wood furniture finishing operation consisting of: ES-SB 1 (NESHAP), nine(9)dry filter-type spray ES-SB2(NESHAP), booths ES-SB3 (NESHAP), ES-SB4(NESHAP), ES-SB5(NESHAP), N/A N/A ES-SB6(NESHAP), ES-SB7(NESHAP), ES-SB8(NESHAP), ES-SB9(NESHAP) ES-D01 (NESHAP), Itwo(2)steam-heated drying N/A N/A ES-D02(NESHAP) ovens ES-WT1 (NESHAP), two(2)washofftanks _ V N/A wN ES-WT2(NESHAP) ES-GO(NESHAP) gluing operation _ N/A _] N/A Permit No. 02815RI3 Page 2 in accordance with the completed application 0200005.14A received April 11, 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 .0503, 2D .0512, 2D .0516, 2D .0521,2D .0524 (40 CFR 60, Subpart Dc), 2D .0535, 2D .0540, 2D .I 111 (40 CFR 63, Subpart JJ), 2Q .0102, 2Q .0317 (Avoidance) and 2Q .0803. 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 2013 calendar year. 3. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .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) Nel oil/natural gas-fired boiler (25.2 million Btu per hour 0.472 maximum heat input) (ES-B 1) 4. 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. Permit No. 02815R13 Page 3 5. SULFUR DIOXIDE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 6. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from spray booth(ID No. ES-SB5), spray booth(ID No. ES-SB8), spray booth(ID No. ES-SB9), steam-heated drying oven(ID No.ES-DO1), steam-heated drying oven(ID No. ES-D02),boiler(ID No. ES-131), washoff tank (ID No. ES-WT2) and gluing operation(ID No. ES-GO),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. 7. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from spray booth(ID No. ES-SB1), spray booth (ID No. ES-SB2), spray booth(ID No. ES-SB3), spray booth(ID No. ES-SB4), spray booth(ID No. ES-SB6) and spray booth(ID No. ES-SB7), washoff tank(ID No. ES- WTI),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. 8. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS For boiler(ID No. ES-B 1),the Permittee shall comply with all applicable provisions, including the notification,testing,reporting,recordkeeping, 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 Dc, including Subpart A "General Provisions." a. NSPS Reporting Requirements - In addition to any other notification requirements to the Environmental Protection Agency (EPA),the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following: i. The sulfur content of the distillate oil combusted in an affected source shall not exceed 0.5 percent by weight. Within 30 days after each six-month period of the calendar year (by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June),the Permittee must submit in writing to the Regional Supervisor, DAQ, the sulfur content of the distillate oil combusted in an affected source. If fuel supplier certification is used to demonstrate compliance, fuel supplier certification shall include the following information: A. The name of the oil supplier; Permit No. 02815R13 Page 4 B. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil in 40 CFR 60.41(c); and C. A certified statement signed by the owner or operator of an affected source that the records of fuel supplier certification submitted represent all of the fuel combusted during the reporting period. b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping requirements of the EPA,the Permittee is required to maintain records as follows: i. The amounts of each fuel combusted during each month; and ii. All records required under this section shall be maintained for a period of two years following the date of such record. c. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the following permit limits shall not be exceeded: Affected Source(s) Pollutant Emission Limit No. 2 fuel oil/natural gas-fired boiler (25.2 million Btu Sulfur 0.5%by per hour maximum heat input) (ES=B 1) content weight 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. 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. Permit No. 02815R13 Page 5 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. 15A NCAC 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - The wood furniture manufacturing operations spray booth(ID No. ES-SB1), spray booth(ID No. ES-S132), spray booth (ID No. ES-SB3), spray booth(ID No. ES-SB4), spray booth(ID No. ES-SB5), spray booth (ID No. ES-SB6), spray booth(ID No. ES-SB7), spray booth(ID No. ES-SB8), spray booth (ID No. ES-SB9), steam-heated drying oven(ID No. ES-DO1), steam-heated drying oven(ID No. ES-D02), washoff tank(ID No. ES-WT1), washoff tank (ID No. ES-WT2) and gluing operation(ID No. ES-GO) shall comply with all requirements of 15A NCAC 21) .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%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. Permit No. 02815R13 Page 6 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. d. Work Practice Standards - The Permittee shall adhere to the work practice standards as specified by 40 CFR 63.803. e. Recordkeeping_Reguirements -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-Land 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(f); 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(l). f. Reporting Requirements -The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(0(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). Permit No. 02815R13 Page 7 g. Finishing Operations - Per 40 CFR 63.804(a)(4),the Permittee has chosen to use both the compliant coatings and the facility averaging compliance options for the finishing operations spray booths(ID Nos. ES-SB5, ES-SB1, ES-SB7,ES-SB6, ES- SB4, ES-SB8, ES-SB9, ES-SB3 and ES-SB2), drying ovens (ID Nos. ES-DO1 and ES-D02), boiler(ID No. ES-B1), washoff tanks(ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No. ES-GO). Compliance with each of these options is considered a separate ALTERNATIVE OPERATING SCENARIO(AOS) 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)] AOSI: 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 spray booths (ID Nos. ES-SB5, ES-SB1, ES-SB7, ES-SB6,ES-SB4, ES-SB8, ES- SB9, ES-SB3 and ES-SB2), drying ovens(ID Nos. ES-DO1 and ES-D02), boiler (ID No. ES-B1),washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No. ES-GO). All thinners, stains,washcoats, sealers, topcoats,basecoats, and enamels used at the facility shall meet the emission limitations as detailed in the following table: Re ulated Material Emission Limitation Thinners I 10%by weight HAP stains,washcoats, sealers,topcoats,basecoats, 1.0 lb VHAP/lb solids, as and enamels applied coatings - 1.0 lb VHAP/lb washcoat basecoat or enamel formulated onsite solids ' thinners - 3.0%by weight 1 VHAP ii. Compliance Procedures and Monitoring Requirements -Emission sources spray booths (ID Nos. ES-SB5, ES-SB1, ES-SB7, ES-SB6, ES-SB4, ES-SB8, ES-SB9,ES-SB3 and ES-SB2), drying ovens (ID Nos. ES-DO1 and ES- D02), boiler (ID No. ES-B1), washoff tanks (ID Nos. ES-WT1 and ES-WT2) .and gluing operation(ID No. ES-GO) are using both non-continuous and 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) for non-continuous coaters and 40 CFR 63.804(g)(3) for continuous coaters. 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 Permittee shall keep records in- accordance with 40 CFR 63.806(a) following the applicability criteria in 40 Permit No. 02815R13 Page 8 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). v. Reporting_Requirements- The Permittee shall submit the compliance stats report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7) 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)(7).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 vi. 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 spray booths (ID Nos. ES-SB5, ES-SB1, ES-SB7, ES-SB6, ES-SB4,ES-SB8, ES- S139, ES-S133 and ES-S132), drying ovens (ID Nos,ES-DO1 and ES-D02), boiler (ID No. ES-B1), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No. ES-GO). The weighted average VHAP content across all coatings, as applied, shall not exceed 1.0 kg VHAP per kg solids. vii. 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). viii. 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). ix. Recordkeeping Requirements -Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d)5 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). X. Reporting_Requirements - The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7) 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)(7) 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. 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 spray booths (ID Nos. ES-S138, ES-SB4, ES-SB5, ES-SB1, ES-SB6, ES-SB3, ES-SB9, ES-SB7 and ES-SB2), drying ovens (ID Nos. ES-D02 and ES-DO1), washoff tanks (ID Nos. ES-WTI and ES-WT2)and gluing operation(ID No. ES-GO) as detailed in the following table: Permit No. 02815R13 Page 9 Regulated Material Emission Limitation strippable spray booth coatings 0.8 lb VOC per lb solids, as applie 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 Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d), 40 CFR 63.806(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 the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7) 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)(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. Contact Adhesive Operations - L Emission Limits -The Permittee shall comply with all provisions of 40 CFR 63.802(a)(2) and 63.804(b)and (c) as applicable to the contact adhesive operations spray booths (ID Nos. ES-SB8, ES-SB4, ES-SB5, ES-SB1, ES- S136, ES-SB3, ES-SB9, ES-SB7 and ES>SB2), drying ovens (ID Nos. ES- DO2 and ES-DOl), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No. ES-GO) as detailed in the following table: Regulated Material Emission Limitation foam contact adhesives used in products which meet 1.8 lb VHAP flammability requirements per California Technical Bulletin per lb solids, 116, 117, or 133,the Business and Institutional Furniture 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 HAP/lb solids, as applied ii. Compliance Procedures and Monitoring Requirements - When the spray, booths (ID Nos. ES-SB8, ES-SB4, ES-SB5,ES-SB1, ES-SB6, ES-S133, ES- Permit No. 02815R13 Page 10 S139, ES-S137 and ES-S132), drying ovens(ID Nos. ES-DO2 and ES-DO 1), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No. ES-GO) is using foam and other contact adhesives. 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)(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 Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(2), 40 CFR 63.806(h),40 CFR 63.806(i), and 40 CFR 63.8060). V. Reporting Requirements - The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(5) 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)(5) 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). 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. 02815R13 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. 12. Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements Your facility is subject to the following federal and state rules: 40 CFR 63 -NESHAP/MACT -- Subpart ZZZZ-- Reciprocating Internal Combustion Engines which are applicable to some of the emission sources at your facility listed on the "Insignificant/Exempt Activities" list attached to this permit. The purpose of this permit condition is to inform you of your compliance obligations to these applicable rules as they are enforceable. Permit No. 02815R13 Page 12 13. AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ 6J - In accordance with 15A NCAC 2Q .0317,the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ (6J)"Industrial, Commercial, and Institutional Boilers Area Sources." The Permittee is permitted to operate a natural gas/No. 2 fuel oil- fired boiler(ID Nos. ES-B1). Per 40 CFR 63.11195(e),these/this source(s) is/are exempt from this Subpart because they are defined as gas-fired boiler(s) in 40 CFR 63.11237. In order to maintain this exemption, the Permittee is allowed to fire liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid - fuel (periodic testing not to exceed a combined total of 48 hours during any calendar year). a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. b. If the Permittee fires liquid fuel for reasons other than gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel,the Permittee is no longer exempt from Subpart JJJJJJ (6J). As required by 40 CFR 62.11225(g),the Permittee must provide notice within 30 days of the fuel switch. The notification must identify: i. The name of the owner or operator of the affected source,the location of the source,the boiler(s)that have switched fuels, and the date of the notice. ii. The date upon which the fuel switch occurred. As required by 40 CFR 63.11210(h),the Permittee must demonstrate compliance within 180 days of the effective date of the fuel switch. 14. EXCLUSIONARY RULE REQUIREMENTS -Pursuant to 15A NCAC 2Q .0803 "Coating, Solvent Cleaning, and Graphic Arts," potential emissions shall be determined using actual emissions without accounting for any air pollution control devices. a. As required by 15A NCAC 2Q .0803,the facility potential emissions (defined as actual emissions) shall be less than the following: i. 100 tons per year of volatile organic compounds (VOC); ii. 10 tons per year of each hazardous air pollutant(HAP); and iii. 25 tons per year of all HAPs combined. b. As required by 15A NCAC 2Q. .0803,the Permittee shall comply with the following requirements: i. Annual Report Requirement- By March 1 of each year, regardless of the actual emissions, the Permittee shall submit to the Regional Supervisor, DAQ, a report summarizing emissions of VOC and HAPs containing the following: A. the pounds of VOC used during the previous calendar year; Permit No. 02815R13 Page 13 B. the greatest quantity in pounds of an individual HAP used during the previous calendar year; and C. the total pounds of all HAPs used during the previous calendar year. ii. Records Maintenance Requirement - The Permittee shall maintain purchase orders and invoices of materials containing VOC. 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. iii. Notification Requirement-The Permittee shall report to the Regional Supervisor, DAQ, any exceedance of a requirement of rule 15A NCAC 2Q .0803 within one week of occurrence; and iv. Certification Requirement- 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." Compliance with the recordkeeping and reporting requirements contained in this specific condition shall not relieve the Permittee from the requirement to have a Title V permit if the actual emissions from the facility exceed 100 tons per year of VOC, or 10 tons per year of an individual HAP, or 25 tons per year of all HAPs combined. 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 Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville,NC 28115 704-663-1699 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. Permit No. 02815RI3 Page 14 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; 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. Permit No. 02815RI3 Page 15 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. 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 112(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 No. 02815RI3 Page 16 Permit issued this the 17th of April, 2014. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION t, ~Ronald E. Slack L Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 02815RI3 ATTACHMENT to Permit No. 02815R13, April 17, 2014 Insignificant/Exempt Activities Source Exemption Source of Source of Title V Regulation TAPs? Pollutants? IES-1 - diesel-fired pump (220 hp) for the F�c 02 fire suppression system(subject to GACT, B)(v)(III) Yes Yes Subpart ZZZZ) 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."