HomeMy WebLinkAboutAQ_F_0800044_20130606_PRMT_Permit NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
.tune 6, 2013
Dr.David M.Peele,Ph.D.
President
Avoca Incorporated j
P.O. Box 129
Merry Hill, North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T40
Facility ID: 0800044
Avoca Incorporated
Merry Hill,Bertie County, North Carolina
Fee Class: Title V
Dear Dr. Peele:
In accordance with your completed Air Quality Permit Application for a significant modification to
your Title V permit under 15A NCAC 02D .0516 received April 12, 2013, we are forwarding herewith Air
Quality Permit No. 01819T40 to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, North Carolina,
authorizing the construction and operation, of the emission source(s) and associated air pollution control
device(s) specified herein. Additionally, any emissions activities determined from your Air Quality Permit
Application as being insignificant per 15A North Carolina Administrative Code 2Q.0503(8) have been listed
for informational purposes as an "ATTACHMENT." Please note the requirements for the annual compliance
certification are contained in General Condition P in Section 3. The current owner is responsible for
submitting a compliance certification for the entire year regardless of who owned the facility during the year.
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q .0504 for
the SFr operations on or before 12 months after commencing operation.
As the designated responsible official it is your responsibility to review, understand, and abide by all of
the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition of
the attached permit reviews, understands, and abides by the condition(s) of the attached permit that are
applicable to that particular emission source.
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If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit,
identifying the specific issues to be contested. This hearing request must be in the form of a written petition,
conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division of
Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form
Permitting Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
217 West Jones Street,Raleigh,North Carolina 27603
Phone:919-707-84051 Fax:919.715.0717
Internet:www.neair,ora
An Equal Opportunity 4 Alfirmative Action Employer—Made in part by Recycled Paper
Mr.David M.Peele,Ph.D.
June 6,2013
Page 2
for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative
Hearings. Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing.
Unless a request for a hearing is made pursuant to NCGS 15013-23, this Air Quality Permit shall be final and
binding 30 days after issuance.
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
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 this Air Quality Permit will
become final and binding regardless of a request for informal modification unless a request for a hearing is
also made under NCGS 15013-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of GS 143-215-108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure to
receive an Air Quality Permit or written approval prior to commencing construction is a violation of GS
143-215.108A and may subject the Permittee to civil or criminal penalties as described in GS 143-
215.114A and 143-215.114B.
This Air Quality Permit shall be effective from June 6, 2013 until July 31, 2015, is nontransferable to
future owners and operators, and shall be subject to nditions and limitations as specified therein.
Should you have any questions conc5ald
lease c ntact Kevin Godwin at(919)707-8480.
yo s,
. van der Vaart, Ph.D., P.E., J.D.
Chief
Enclosure
c: Rob Fisher, Supervisor, Washington Regional Office
Heather Ceron,EPA Region 4
Central Files
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Insignificant Activities under 15A NCAC 2Q.0503(S)
Emission Control Device Control Device
Source ID No. Emission Source Description ID No. Description
IWWTP-ET1 Wastewater treatment plant equalization tank NIA NIA
No. 1 65,500 anon capacity)
1WWTP-ET2 Wastewater treatment plant equalization tank NIA NIA
No. 2(65,500 gallon capacity)
l W WTP-AT2 Wastewater treatment plant aeration tank No.2 NIA NIA
(63,500 gallon capacity)
Wastewater treatment plant aeration tank No.3
IWWTP-AT3 (63,500 gallon capacity)
NIA NIA
IWWTP-CLR Wastewater treatment plant clarifier(1,310 NIA NIA
gallon capacity)
ITK9238 No. 2 fuel ail storage tank(50,000 gallon NIA NIA
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
TfK102 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
1TKI03 No.
c fiicl oil storage tank(495 gallon NIA NIA
capa
ITKFP No.2 fuel oil storage tank(270 gallon NIA NIA
capacity)
One water spray fume
CD-Z-9215 scrubber(0.5 gallons
per minute minimum
water injection rate)
IECS ECS process: batch preparation of venting to
ethylenediamine/copper sulfate solution CD-Z-9216
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable
requirement or that the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement.
2. When applicable, einissions from stationary source activities identified above shall be included in
determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100
"Control of Toxic Air Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and N ACT ZZZZ see the NC DAQ
website: http://daq.state.nc.us/toxics/areasources/.
The following table provides a summary of the changes in Permit No.01 S 19T40.
Condition .
FGlo
No. Description of Change(s)
Global Removed reference to Iime injection for bagfilter(ID No. CD-BB1BH)
Table of
4 Emission Updated SFG ID numbers per Table 2.1 of the application.
Sources
25 2.2 A Removed reference to state-only toxic air pollutants(TAP).
Table
Old page 2.2 A 2 Removed TAP condition pertaining to 15A NCAC 02D .1100.
26
Old page 2.2 A.4. Removed condition pertaining to 15A NCAC 02Q .0705 and .0711.
26
New page 2.2 A 3 Included condition requiring a TAP evaluation for increases from non-
26 NESHAP sources.
43 2.2 C. Updated SFG ID numbers per Table 2.1 of the application.
50 2.2 C.2. Included PSD avoidance condition limiting VOC emissions from SFG
operations to 95.29 tons per 12 month rolling period.
50 2.2 C.3. Included condition for MON Group 1 batch process vent avoidance.
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State of North Carolina, A14 • •
Department of Environment,
and Natural Resources NCDENR
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T40 01819T39 June 6, 2013 July 31, 2015
Until such time as this permit expires or is modified or revoked, the below named Permittee is authorized to
construct and operate the emission source(s) and associated air pollution control device(s) specified herein, in
accordance with the terms, conditions, and limitations within this permit. This permit is issued under the
provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and Title 15A North
Carolina Administrative Codes(15A NCAC),Subchapters 2D and 2Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission
source(s) or air pollution control device(s) without having first submitted a complete Air Quality Permit
Application to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Avoca, Inc.
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County,State, Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.O.Box 129
City, State, Zip: Merry Hill,NC 27957
Application Number: 0800044.13A
Complete Application Date: April 12,2013
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington,NC 27889
CIBB ;ority
ed this the 6`h ay of June, 2013.
va rVaart, Ph.D., P.E., J.D., Chief, Air Permits Section
of the Environmental Management
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Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing,monitoring, recordkeeping, and reporting
requirements)
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring, recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACIIMENTS
ATTACHMENT 1 List of Acronyms
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Permit 01819T40
Page 3
SECTION 1 - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances:
Emisslon Source Control Device Control Device
ID No. Emission Source Description ID No. Description
Rotocel Operations
CD-31209 One chilled water
condenser venting to
ES-1 00l-2-1-P l
PSD Rotocel extractor,desolventizer,and CD-1001-2-S-1 One packed tower
CAM solvent separation/recovery scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
CD-1001-2-C-1 One chilled water
condenser venting to
ES-1001-2-1-1`2
PSD Two solvent recycle process tanks CD-1001-2-S-1 ' One packed tower
CAM scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-2-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-2-1-
WW Rotocel Operations wastewater stream NA NA
PSD
MACT FFFF
Recovery Operations j
CD-1001-1-3 One chilled water
condenser venting to
ES-1001-1-1-P1
PSD CD-1001-2-S-1 ' One packed tower
CAM Arcon process tank M-1 scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-1-1-P2 CD-1001-1-TSB One chilled water
PSD Stripper T-5 and receiver M-21 condenser venting to
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
ES-1001-1-1-P scrubber(8 gallons per3 Seven process tanks of various capacities minute minimum
PSD and one fixed roof methanol storage tank
MACT FFFF (7,050 gallon capacity) mineral oil injection
rate)
Permit 01819T40
Page 4
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Descri tion
ES-1001-1-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-1-1-
WW Recovery Operations wastewater stream NA NA
PSD
MACT FFFF
Concrete Operations
ES-1001-1-2-P One chilled water
PSD Six process tanks of various capacities CD-1001-1-2 condenser
MACT FFFF
HB-1 One stearn-heated hot box NA NA
MACT FFFF
14B-2 One steam-heated hot box NA NA
MACT FFFF
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HB-3 One steam-heated hot box NA NA
MACT FFFF
HB-4 One steam-heated hot box NA NA
MACT FFFF
ES-1001-1-2-F process equipment leaks NA NA
MACT FFFF
ES-1001-1-2-
W W Concrete Operations wastewater stream NA NA
MACT FFFF
Sclareol Recrystallization (SFG) Operations"
T-3001 One hexane storage tank(6,700 gallon
NA NA
MACT FFFF capacity)T-3002 through Four process tanks(2,500 gallons capacity NA NA
MACT FFFF each)
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ES-1003-10-F
MACT FFFF Process equipment leaks NA NA
C-3001 One centrifuge NA NA
MACT FFFF
R-3001 One reactor equipped with a chilled water
MACT FFFF process condenser(EX-3001)
R-3002 One reactor equipped with a chilled water CD-3001 One chilled water
MACT FrrF process condenser(ES-3003) condenser
D-3001
MACT FFFF One steam-heated dryer
E ACT. FFF
MACT FFFF SFG Process wastewater stream NA NA
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Biological Conversion Equipment for Purification of Sclareolide
ES-1001-1-3-P Twelve process tanks of various capacities NA NA
MACT FFFF
Permit 01819T40
Page 5
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description___
G-17 One centrifuge NA NA
MACT FFFF
ES-1001-1-3-F process equipment leaks NA NA
MACT FFFF
D-1202
MACT FFFF One steam-heated dryer NA NA
A-2 One distillation column(6 gallons per NA NA
MACT FFFF minute noininal process rate
ES-1001-1-3- Biological conversion equipment for
WW purification of sclareolide wastewater NA NA
MACT FFFF stream
Sclareolide(SDF) Operations
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ES-1001-1-4-P
MACT I'I'FI' Four process tanks of various capacities NA NA
FFFF
M-20 One acetic acid storage tank(10,135 gallon NA NA
MACT FFFF capacity)
ES-1001-1-4-F process equipment leaks NA NA
MACT FFFF
M-10
MACT FFFF One batch reactor
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M-10A One venturi-type wet
MACT FFFF One batch reactor CD-M-34 scrubber(10 gallons
D-1231A per minute minimum
MACT FFFF One batch reactor liquid injection rate)
D-1231B One batch reactor
MACT FFFF
ES-1001-1-4-
WW SDE Operations wastewater stream NA NA
MACT FFFF
Plant Nutrient Extraction (PNE) Operations
EX2203 One chilled water
condenser venting to
CD-Z-9215 2 One water-spray fume
scrubber(0.5 gallons
D31214 per minute minimum
MACT FFFF One product extract reactor water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate
Permit 01819T40
Page 6
Emission Source Control Device Control Device
ID No. Emission Source Descriptiozi . ID No. Description
EX2205 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons
D31211 One waste solids separator vessel (1,333 per minute minimum
MALT FFFF gallon capacity)
water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
ES-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
ES-1 003-2-1-
WW PNE process wastewater stream NA NA
MACT FFFF
CD-Z-9215 2 One water spray fume
ES-1003-2-1-P scrubber(0.5 gallons
MACT FFFF Seven process tanks of various capacities
per minute minimum
water injection rate)
venting to �
CD-Z-92]6 2
C-31203 One centrifuge One water spray fume
MACT FFFF scrubber(0.5 gallons
per minute minimum
water injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
D-2202 CD-Z-9215 One water spray fume
MACT FFFF One reactor scrubber(0.5 gallons
D-1215 One reactor per minute minimum
MACT FFFF water injection rate)
D-1218 One reactor venting to
MACT FFFF CD-Z-9216
One water spray fume
D-1201 scrubber(0.5 gallons
One steam-heated dryer
MACT FFFF per minute minimum
water injection rate)
ES-1003-2-2-F Process equipment leaks NA NA
MACT FFFF
ES-1003-2-2-
WW EVG Operation wastewater stream NA NA
MACT FFFF
Botanical Extraction Operations
Permit 01819T40
Page 7
Emission Source Emission Source Descri tion. Control Device Control Device
ID No. p ID No. Description
CD-1001-11- One chilled water
Immersion extractor Z-1001, EX1002 condenser venting to
ES-i001-11-P desolventizer Z-1002,
PSD day tank 90024(6,000 gallon capacity), One cryogenic
CAM first-stage evaporator EX-1012, CD-1001-1 l- (nitrogen)condenser
MACT FFFF second-stage evaporator EX-1013, EX1003 system (40 °F
distillation column EX-90008,and maximum 24-hour j
nine process tanks of various capacities average outlet
tem erature)
ES-1001-11-F
PSD Process equipment leaks NA NA
MACT FFFF
One plant material grinder(1,011 pounds One bagfi[ter(244
MHZ•-1002 per hour nominal feed rate) CD-1003-4-1 square feet of filter
area)
ES-1001-11-WW Botanical extraction operation wastewater
PSD
MACT FFFF Stream NA NA
Biomass Extraction Operations
One cartridge filter
PEA-D1004-1 Biomass extraction debagging CD-1004-1-FF1 (6.7:1 maximum air-to-
cloth ratio)
ES-1004-2-F Process equipment leaks NA NA
PSD
ES-1004-2-WW Biomass extraction operation wastewater NA NA
PSD stream
Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
desolventizer Z-41002, condenser venting to
day tank 490025 (9,953 gallon capacity),
ES-1004-2-P isohexane storage tank 490024 (13,536 CD-1004-2EX1003 One cryogenic
PSD gallon capacity), (nitrogen)condenser
CAM first stage evaporator EX-41012, system(40°F
second stage evaporator EX-41013, maximum 24-hour
distillation column EX-490008, and average outlet
nine process tanks of various capacities temperature)
One bagfilter(254
ES-1004-2Silo Biomass silo loadou( CD-1004-2-FF2 square feet of filter
area)
Miscellaneous Operations
H-101 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- Btu per hour maximum heat input ra(e) NA NA
by-case MACT
H-102 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- Btu per horn•maximum heat input rate) NA NA
by-case MACT
Permit 01819T40
Page 8
Emission Source Control Device Control Device
l TID No. Emission Source Description ED No. Description
H-103 One No. 2 fuel oil-fired boiler(25.2 million
2D .1109 case- NA NA
by-ease MACT Btu per hour maximum heat input rate)
ES-BB 1 and ES- One simple cyclone
BB2* (114 inches in
NSPS—Subpart Two biomass/bio-based solids-fired boilers diameter) in series with
Dc (18.6 million Btu per hour maximum heat CD-BB I and CD- one bagfilter(8,900
MACT— input rate) BB1BH Square feet of filter
Subpart area)
DDDDD
ES-RD* One No. 2 fuel oil-fired rotary dryer(6.0
million Btu per hour maximum heat input NIA NIA
rate)
ES-PkGenl One No. 2 fuel oil-fired limited use One catalytic oxidizer
MACT ZZZZ emergency generator(2,935 kilowatt CD-CatOX1 (695-°F minimum inlet
maximum rated power output) temperature)
WWW WTP-AT1
Wastewater treatment plant aeration tankPSD NA NA
MACT FFFF No. l
E101 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (587 horsepower maximum rated power NIA NIA
output)
E102 One No.2 fuel oil-fined emergency generator
MACT ZZZZ (760 horsepower maximum rated power NIA NIA
output)
E103 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (603 horsepower maximum rated power NIA NIA
output) j
FP One No.2 fuel oil-fired emergency fire
MACT ZZZZ water pump(285 horsepower maximum NIA NIA
rated power output)
The Permittee is permitted to operate sources ES-1001-2-1-P2, ES-1001-1-1-P1, ES-1001-1-1-P2, and ES-1001-1-1-P3
without the shnultaneous operation of scrubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 B.1.d and e,below.
2 Operation of water spray fiime scrubber CD-Z-9215 and water spray Mme scrubber CD-Z-9216 shall only be required for
control of emissions from the PNE Operations if that source is utilizing ethyl acetate as a solvent.
These emission sources and control devices(ID Nos. ES-BB1, ES-BB2,ES-RD, CD-BB IC and CD-BB IBH) are listed as a
15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality Permit Application on or before 12
months after commencing operation in accordance with General Condition NN.1. The permit shield described in General
Condition R does not apply and compliance certification as described in General Condition P is not required.
**The emission sources in the SFG operation are listed as a 15A NCAC 2Q .0501(c)(2)modification. The Permittee shall
file a Title V Air Quality Permit Application on or before 12 months after commencing operation in accordance with
General Condition NN.I. The permit shield described in General Condition R does not apply and compliance
certification as described in General Condition P is not required.
Permit 01819T40
Page 9
SECTION 2 — SPECIFIC LIITATIONS AND CONDITIONS
2.1 - Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Three No.2 fuel oil-fired boilers (ID Nos.H-101,H-102, and H-103)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regu]Htion
Particulate inatter 0.37 pounds per million Btu heat input 15A NCAC 2D .0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 2D .0521(d)
Visible emissions
40 percent opacity: H-101 and H-102 15A NCAC 2D .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 2D .1109
Control Technology [1120)Case-by-Case MACT]
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 21)
.0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.1 A.La, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0503.
Monitoring/Recordkeeping/ReportinE [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for particulate emissions from the firing of No.2
fuel oil in boilers 11-101,11-102, or H-103.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be
included when determining compliance with this standard. [15A NCAC 21) .0516]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 213 .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.1 A.2.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 21)
.0516.
Permit 01819T40
Page 10
Monitoring/Recordlceeping/Repor tin g[15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in boilers H-101, H-102,or H-103.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers H-101 and H-102 shall not be more than 40 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 40 percent not
more than once in any hour and not more than four times in any 24-hour period. hi no event shall the
six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler H-103 shall not be more than 20 percent opacity when averaged over a
six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q,0508(f)]
c. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.3.a or b, above, as applicable, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0521.
Moeiitoriu IRecordlcee in IRe ortin [15A NCAC 2Q .0508(f)]
d. No monitoring, record keeping, or reporting is required for visible emissions from the firing of No. 2
firel oil in boilers H-1 01,H-102, or H-103.
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4. 15A NCAC 2D .1109: 112(J) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 1120)- Case-by-Case MACT for Boilers &Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers H-101, H-102, and
H-103. The initial compliance date for this work practice standard and the associated monitoring,
recordkeeping, and reporting requirements is August 17 2013. These conditions need not be included
on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance, the Permittee shall perforin an annual boiler inspection and maintenance on
boilers as recommended by the manufacturer, or as a minimum, the inspection and maintenance
requirement shall include the following:
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Permittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement. The Permittee shall be deemed in noncompliance with 15A NCAC
2D .1109 if the affected boilers are not inspected and maintained as required above.
Recor[lkee in [15A NCAC 2Q .0508(f)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a log
(written or electronic format) on-site and made available to an authorized representative upon request.
The log shall record the following:
i. The date and time of each recorded action;
Permit 01819T40
Page I I
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Reyortine[I5A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-P1cGen1) and one associated catalytic
oxidizer(ID No. CD-CatOX1)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regi.ilation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 213 .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
15A NCAC 21) .1111
Hazardous Air Pollutants Maximum Achievable Control Technology [40 CFR Part 63, Subpart
zzzz]
Nitrogen Oxides(NOx) Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator ES-PkGen1 shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard. [15A NCAC 21)
.0516]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.l.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 21)
.0516.
_Monitoring/Recordkeeping/Reportin [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in limited use generator ES-PkGenl.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator ES-PkGenl shall not be more than 20 percent opacity
when averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period. In no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 21) .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 21)
Permit 01 819T40
Page 12
.0521.
Monitorin IRecordkee iir /Re ortiu [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in limited use generator ES-PkGenl.
3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
[40 CFR Part 63,Subpart ZZZZ]
Applicability [40 CFR§63.6580 and §63.65851
a. Limited use generator ES-PkGenl shall comply with all applicable requirements of 15A NCAC 2D
1111 "Maximum Achievable Control Technology" pursuant to 40 CFR Part 63, Subpart ZZZZ
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines(RICE)"including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR§63.6590(b)(1)(ii)and §63.66751
b. In accordance with 40 CFR §63.6590(a)(2)(i) this source is considered an existing Limited Use source
for purposes of Subpart ZZZZ. To qualify as such,the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
MonitorinE[15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations, on limited use generator ES-PkGenl. The Permittee shall conduct monthly
monitoring of hours of operation for this source as measured by the non-resettable hour meter. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring is not
performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGcnl, as measured by the non-resettable hour meter, in a log (written or electronic format) on-site
and made available to an authorized representative upon request.
i
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring, recordkeeping, or reporting is required for hazardous air pollutant emissions from
limited use generator ES-PkGenl.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator ES-PkGenl shall discharge into the atmosphere less than 40 tons of nitrogen
oxides per consecutive 12-month period [15A NCAC 2D .05301.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.4.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Operational Limitation [15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 B.4.a, above, the operation of limited
Permit 01819T40
Page 13
use generator ES-PkGenl shall not exceed 1,500 horns in a consecutive 12-month period. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitorina/Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not
conducted, these records are not maintained, or if the rolling total hours of operation for the limited use
generator exceed 1,500 hours per consecutive 12-month period.
Renortin [15A NCAC 2Q .0508(f)]
e. The Perinittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. The report must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months;
and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period
ending during the reporting period.
C. Rotocel Operations, including:
• Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No. CD-1001-2-S-1);
• Two solvent recycle process tanks (ID No. ES-1001-2-1-T) and one associated chilled water j
condenser (ID No. CD-1001-2-C-1) venting to one packed tower scrubber (ID No. CD-1001-2-
S-1). **
• Process equipment leaks (ID No.ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser
(ID No. CD-1001-1-3) venting to one packed tower scrubber(ID No. CD-1001-2-S-1); **
• One chilled water condenser (ID No. CD-1001-1-T5B) venting to packed tower scrubber (ID
No. CD-1001-2-S-1)controlling emissions from: **
o Stripper T-5 and receiver M-21 (ID No.ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(ID No.ES-1001-1-1-P3);
• Process equipment leaks (ID No.ES-1001-1-1-h); and
• Recovery Operations wastewater stream (ID No.ES-1001-1-1-WW)
** The Permittee may operate sources ES-1001-2-1-P1 and ES-1001-1-1-P1,-P2, and -P3 without the simultaneous
operation of scrubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 B.Ld and e,below.
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Staudards Applicable Regulation
Volatile organic Best Available Control Technology 15A NCAC 2D .0530
compounds See Sections 2.2 B.1 and 2.2 B.2
Permit 0 t 819T40
Page 14
Regulated Pollutant Limits/Standards Applicable Regulation
Compliance Assurance Monitoring 15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Maximum Achievable Control Technology 15A NCAC 2D .I I I I
Hazardous Air Pollutants See Section 2.2 C.1 [40 CFR Part 63, Subpart
FFFF]
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3
Toxic Air PollutantsState-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 AA 15A NCAC 2D .1100
i
1. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CFR Part
64 and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic
compound (VOC) emission litnits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this
permit.
Control RepuiremeutslParameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the rtocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (ID No. ES-1001-2-1-T), accon process tank M-1 (fD
No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight process and
storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower scrubber(1D
No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.l.d and e, below. In addition, the
Permittee shall maintain a daily average mineral oil temperature at the inlet of scrubber CD-1001-2-S-1
of less than or equal to 100 degrees Fahrenheit (100 °F) whenever the associated sources are
operational.
Monitoring[15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.l.c.i
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 C.l.cJ through iii, below, are not
performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral oil packed tower scrubber
CD-1001-2-S-1 at least once each day that the sources listed in Section 2.1 C.l.b,above,operate;
ii. The Permittee shall inspect, maintain,and operate mineral oil packed tower scrubber CD-1001-2-S-
1 in accordance with Section 2.2 B.1 j, below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gaugc associated with
mineral oil packed tower scrubber CD-1001-2-S-1 in accordance with Section 2.2 13.11, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if mineral oil packed tower scrubber CD-1001-2-S-1 operates
under conditions qualifying as an excursion for more than 5 percent of the operational time of the
sources listed in Section 2.1 C.1.b,above, during a consecutive 6-month period,then the Permittee shall
develop a Quality Improvement Plan(QIP) in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed
Pennit 01819T40
Page 15
tower scrubber- CD-1001-2-S-1 with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.l.b, above, while the associated emission sources are operating, except as allowed
pursuant to Sections 2.2 B.l.d and e, below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request.The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
inlet mineral oil temperature of packed tower scrubber CD-1001-2-5-1;
iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber CD-
1001-2-5-1 or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
ReRe�or_ting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must
be clearly identified.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator
EX-1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process
tanks of various capacities (ID No. ES-1001-11-1-P) and one associated chilled water
condenser(ID No. CD-1001-11-EX1002) venting to one cryogenic(nitrogen) condenser system
(ID No. CD-1001-11-EX1003);
• Plant Material Grinder (ID No. MHZ-1002) and one associated bagfilter (ID No.CD-1003-4-
1);
• Process equipment leaks (ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream (ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debagging (ID No. ES-1004-1) and one associated cartridge filter (ID No.
CD-1004-1-FF1);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, isohexane storage
tank 490024, first-stage evaporator EX-41012,second stage evaporator EX-41013,distillation
column EX-490008 and nine process tanks of various capacities (ID No.ES-1004-2-P) and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen) condenser system (ID No. CD-1004-2EX1003);
• Process equipment leaks (ID No. ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
• Biomass extraction operations wastewater stream (ID No.ES-1003-10-WW); and
• Biomass silo loadout (ID No. ES-1004-2Silo) and one associated bagfilter(ID No. CD-1004-2-
FF2)
The following table provides a summary of limits and standards for the emission source(s)described above:
Permit 01819T40
Page 16
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder, biomass extraction
debagging,and biomass silo loadout:
Particulate matter E=4.1Op0.61 15A NCAC 2D .0515
Where:E=allowable emission rate in pounds per
hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0 53 0
See Sections 2.2 B.I and 2.2 B.2
Volatile organic Comp]lance Assurance Monitoring 15A NCAC 2D .0614
compounds
Work practice standards
See Section 2.2 A.1 15A NCAC 2D A958
Odorous emissions state-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
15A NCAC 2D .I I I I
Hazardous Air Pollutants Maximum Achievable Control Technology 40 CFR Part 63, Subpart
See Section 2.2 C.1 (Botanical extraction only) FFFF
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .I 100
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (1D No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
i
E=4.10xPa.61
Where: E=allowable emission rate in pounds per hour; and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(t)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition 11 found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.La, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.05I5.
Monitoring/Recordkee ing [15A NCAC 2Q .0508(t)]
c. Particulate matter emissions from the plant material grinder, the biomass extraction debagging
operation, and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a
cartridge filter (ID No. CD-1004-1-FFI), and a bagfilter (ID No. CD-1004-2-FF2), respectively. To
assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
Permit 01819T40
Page 17
and maintenance requirement shall include the following:
i. A monthly visual inspection of the system duchvork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and maintained.
d. The results of inspections and maintenance shall be maintained in a log (written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any maintenance performed on the cartridge filter and bagfilters; and
iv. Variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not
maintained.
RenortinE[15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December and July 30 of each calendar year for the preceding six-month period between
January and June. All instances of deviations from the requirements of this permit must be clearly
identified.
2. 1.5A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the botanical extraction operations and the biomass extraction operations shall
not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [15A NCAC
2D .0521(d)]
i
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0521.
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources
for any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly
observation must be made while the associated source is operating.If a source does not operate during a
monthly period, then a record documenting such non-operational status will satisfy this monitoring
requirement for that source. If visible emissions from a source are observed to be above normal, the
Permittee shall either:
i. Take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2601 (Method 9)for 12 minutes is below the limit given in Section 2.1 D.2.a,
Permit 01819T40
Page 18
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordlceeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 26 .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
I
Applicability[15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks (ID No,
ES-1001-11-1-P) and the immersion extractor Z-4100I, desolventizer Z-41002, day tank 490025,
isohexane storage tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013,
distillation column EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P),the
Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this source
complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D3 of this permit.
Control Reg uirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P)
shall be controlled by the associated cryogenic condenser system(ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system(ID No. CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40
degrees Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003
whenever the associated sources are operational; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F
for cryogenic condenser system CD-1004-2EX1003 whenever the associated sources are
operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.c.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D.3.c.i through iv, below, are• not
performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1001-11-
EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
Permit 01819T40
Page 19
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above,operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1004-
2EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above, operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems CD-1001-11-
EX1003 and CD-1004-2EX1003 in accordance with Section 2.2 B.l.h, below; and
iv. The Permittee shall install, maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems CD-1001-11-EX1003 and CD-1004-2EX1003 in accordance with
Section 2.2 B.l.i, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system CD-1001-11-EX1003 or CD-
1004-2EX1003 operate under conditions qualifying as an excursion for more than 5 percent of the
operational time of their associated sources listed in Section 2.1 D.3.b, above, during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of cryogenic condenser
system CD-1001-11-EX1003 or CD-1004-2EX1003 with a 12-hour average outlet temperature that
exceeds the associated limit cited in Sections 2.1 D.3.1b.i and ii, above, while the associated emission
sources are operating.
_Recordkeeping [15A NCAC 2Q .0508(o]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request. The log shall record the following:
L The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
outlet temperature of cryogenic condenser system CD-1001-11-EX 1003 or CD-1 004-2EX1003;
iii. The results of any inspections or maintenance performed on cryogenic condenser system CD-1001-
11-EX1003,cryogenic condenser system CD-1004-2EX1003, or the associated temperature gauges;
and
iv. Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reportinsz [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must
be clearly identified.
Permit 01819T40
Page 20
E. Two biomass boilers (ID Nos. ES-BRI and ES-BB2) controlled by a cyclone (ID No. CD-131131C)
in series with a bagfilter (ID No. CD-1113113H) and associated No. 2 fuel oil-fired rotary dryer
(ID No.ES-RD)
The following table provides a summary of lunits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Boners(ID Nos. ES-BBI an(!BB2):
Particulate 15A NCAC 02D .0503
matter 0.33 pounds per million Btu heat input
Rotary dryer(ID No.ES-RD):
Particulate 067 15A NCAC 02D .0515
matter E=4.10(P)
Sulfur 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
dioxide
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 02D .0521
emissions period
NIA Initial notification requirements, 15A NCAC 02D .0524
Notification of boiler size and fbel combusted,and NSPS—Subpart Dc
Record and maintain amount of each fuel combusted
during each calendar month.
,HCI, Per Subpart 15ANCAC 02Q.1111
PM
PM,H MACT Subpart DDDDD
DioxinslFura
ns
1. Testin [15A NCAC 02Q .0508(f)
Under the provisions of North Carolina General Statute 143-215.108, in order to verify emission factors used
for calculating CO (0.54 lb/MMBtu)and NOx(0.22 Ib/MNIBtu)emissions the Permittee shall perform a stack
test on one of the boilers for CO and NOx within 60 days after start-up. The testing shall be conducted in
accordance with a testing protocol (using testing protocol submittal form) approved by the Division of Air
Quality. Details of emission testing requirements can be found in Section 3—General Condition JJ. If testing
shows emissions greater than the emission factors used, the Permittee must notify the Regional Office
Supervisor, in writing,no later than 60 days following the stack test date.
2. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos.ES-BBI and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
heat input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A. 1. a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Perrnit 01819T40
Page 21
Monitoring [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the boi ler shall be controlled by a cyclone in series with a bagfilter.
To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. monthly external inspection of the ductwork,cyclone, and bagfilter noting the structural
integrity; and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone, bagfilter,
and ductwork is not inspected and maintained.
Recordlicepin [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a log(written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i. the date and time of each recorded action;
ii.the results of each inspection;
iii. a report of any maintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made. j
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall submit a report of any
maintenance performed on the cyclone and bagfilter.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the rotary dryer(ID No. ES-RD)shall not exceed an allowable emission rate
as calculated by the following equation: [15A NCAC 2D .0515(a)]
E=4.10 x P 0.67 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing[15A NCAC 2Q .0508(1)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 E.2.a. above,the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0515.
MonitoringlRccordkeepingy[15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour,as specified by the
formulas contained above(or the formulas contained in 15A NCAC 2D.0515)can be derived,and shall make
these records available to a DAQ authorized representative upon request.The Permittee shall be deemed in
noncompliance with 15A NCAC 213.0515 if the production records are not maintained or the types of materials
and finishes are not monitored.
Permit 01819T40
Page 22
4. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes,ores,and other substances shall be
included when determining compliance with this standard. [15A NCAC 2D .0516]
Testing [I5A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ
found in Section 3. If the results of this test are above the limit given in Section 2.1 A.l.a. above,the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
5. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(ID Nos.ES-BB1, ES-BB2,and ES-RD)shall not
be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [I5A
NCAC 2D .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E. 3. a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 21) .0521.
For boilers (ID Nos. ES-BBI and ES-BB2):
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a day the Permittee shall observe the emission points of the boilers (ID
Nos. ES-BB 1 and ES-BB2)for any visible emissions above normal. The daily observation must be
made for each day of the calendar year period to ensure compliance with this requirement.The
Permittee shall be allowed three(3)days of absent observations per semi-annual period.The Permittee
shall establish"normal"for the boilers in the first 30 days following the effective date of the permit. If
visible emissions from this source are observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 21) .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 E.3. a.
above.
If the above-normal emissions are not corrected per(i) above or if the demonstration in(ii)above
cannot be made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordlzeepin [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log(written or electronic format)on-site and
made available to an authorized representative upon request. The log shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 21) .0521 if these records are not
maintained.
Permit 01819T40
Page 23
Renortin>x [1 SA NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer (ID No. ES-RD):
Monitorinrr/Recordlceenine/Reporting [1 SA NCAC 2Q .0508(f)]
f. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel
oil in the rotary dryer(11)No. ES-RD).
6. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
fecordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 21) .0524 "New Source Performance Standards (NSPS) as promulgated in 40
CFR Part 60 Subpart Dc, including Subpart A "General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUIREMENTS-In addition to any other required by 40 CFR 3 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 3 60.7)or reconstruction(40 CFR:) 60.15)of an affected facility is
commenced,postmarked no later than 30 days after such date,and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Recordkeeping [15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR ❑ 60.48c or recordkeeping requirements of
the EPA, the Permittee shall record and maintain records of the amounts of each fuel fired during each
day. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these records are
not maintained.
7. 15A NCAC 02D .1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers(11)Nos. ES-BBl and ES-13132)are subject to 40 CFR Part 63, Subpart DDDDD.
F. Three emergency generators and fire water pump (ID Nos. E101, E102, E103, and FP)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible 20 percent opacity 15A NCAC 02D.0521
emissions
NIA NIA 15A NCAC 021).1111--
Subpart ZZZZ
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Dtu heat input. Sulfur dioxide
formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining
Permit 01819T40
Page 24
compliance with this standard. [15A NCAC 2D .0516]
Testlrrg[15A NCAC 2Q.0508(0]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. if the results of this test are above the limit given in Section 2.1 A.La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 213.0516.
c. No monitoring/recordkeeping/ is required for sulfur dioxide emissions from the firing of No. 2 fuel oil in these
sources.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four tines in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
[15A NCAC 21).0521 (d)]
Testing[15A NCAC 2Q .0508(o]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 F. 2. a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D.0521.
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in these
sources.
3. 15A NCAC 2D.1111 [40 CFR Part 63 Subpart ZZZZ]:
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Standard 15A NCAC 21) .I111,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,
Subpart ZZZZ,"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines",by December 13,2004.
Mon itorina/Recordkeening/Reportina[l5A NCAC 2Q.0508(f)]
b. No monitoring/recordkeeping/reporting requirements.
i
I
Permit 01819T40
Page 25
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources fall permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101, H-102, and H-1031
The following table provides a summary of limits and standards for the emission source(s)describe above:
i
i
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 213 .0958
Odorous emissions state-Enforceable Only 15A NCAC 2D .1806
Odorous emissions must be controlled
L 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D .0958, for all sources that use volatile organic compounds (VOC) as
solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that
mix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a
product of chemical reactions,the Permittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, when not
in use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety
procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile
organic compounds, j
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other
coating equipment into closable containers and close such containers immediately after each use, or
transfer such solvents to closed tanks, or to a treatment facility regulated under section 402 of the
Clean Water Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank
or a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 2D
.0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush pants 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 Ionger,
iv. Not fill cleaning machines above the fill Iine,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 2D .0958(d)]
MonitorinE [15A NCAC 2Q .0508(f)]
c. To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum,perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations. If the required inspections are not
conducted the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0958.
Permit 01819T40
Page 26
Recordkeeniug [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with
rule 15A NCAC 2D .0958.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 02D.1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NES14AP source, any increase in toxic air pollutants must be evaluated.
I
Permit 01819T40
Page 27
B. Three No.2 fuel oil-fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. W WTP-ATI)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
(VOC)
1. 15A NCAC 2D .0530: PREVENTION OF SIGNI[+ICANT DETERIORATION
a. The following Best Available Control Technology(BACT) limits shalt not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tons per Condenser CD-31209
desolventizer,and solvent VOC 10.8 pounds consecutive
separation/recovery per hour 12-month and packed tower
(ID No. ES-1001-2-1-P1) period
scrubber CD-1001-2-5-1
When Rotocel Operating: Condenser CD-1001-2-
0.94 pounds per hour and 4.11 C-1 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-S-1
period,combined total
i
Rotocel solvent recycle tanks When Rotocel is NOT Condenser CD-1001-2-
(ID No. E S-100 1-2-1-P2) VOC Operating and Recovery C-1
Process is processing
Concrete:
0.47 pounds per hour and 0.19
tons per consecutive 12-month
period, combined total
Rotocel equipment leaks VOC Leak detection and
(ID No. ES-100 1-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(ID No.ES-1001-2-1-WW) VOC wastewater treatment
tanks
Pennit 01819T40
Page 28
Emission Source Pollutant BACT Emission Limits Conh of Technology
When Rotocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-1 When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete:
8.76 pounds per hour and 0.63
tons per consecutive 12-month
period
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-S-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-1001-1-
receiver M-21 VOC Operating and Recovery T5B
(ID No. ES-1001-1-1-P2) Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC Fixed roofs
(ID No. ES-1001-1-1-P3)
Recovery equipment leaks VOC WAR
(ID No. ES-1001-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting wastewater treatment
(1D No. ES-1001-1-1-WW) tanks and biological
of methanol-wash
treatment
Botanical extraction
immersion extractor,
61.76 tons per
desolventizer, first and 14.1 pounds consecutive Condenser CD-1001-11-
second stage evaporators, VOC per hour 12-month EX1002 and condenser distillation column, day tank, period CD-1001-11-EX1003
and multiple process tanks
(ID No. ES-1001-11-P)
Botanical extraction
equipment leaks(ID No.ES- VOC MAR
1001-11-F)
(Fugitive)
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC wastewater treatment
ES-1001-11-WW) tanks
Permit 01819T40
Page 29
Emission Source Pollutant BACT Emission Limits Control Technology
Biomass extraction
immersion extractor,
desolventizer, day tank, 61.8 tons per
isohexane storage tank, first Condenser CD-1004-
and second stage VOCs 14.1 pounds consecutive per hour 12-month 2EX1002 and condenser
evaporators,distillation period CD-1004-2EX1003
column,and multiple process
tanks
(1D No.ES-1004-2-P)
Biomass extraction
equipment leaks(ID No. ES- VOCs LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs wastewater treatment
ES-1004-2•-WW) tanks
No.2 firel-oil fired boilers
(ID Nos.H-101,H-102,H- VOC 0.2 pounds per 1,000 gallons Combustion control
11 103)
Testing [I SA NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.2 B.La, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall only fill the Rotocel solvent recycle tanks (1D No. ES-1001-2-1-P2) from tanker
trucks when source ES-1001-2-1-P1 is operating.
d. The Permittee shall limit the operation of the rotocel solvent recycle tanks (1D No. ES-1001-2-1-P2),
recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and recovery stripper T-5 and receiver M-21 (1D
No. ES-1001-1-1-P2) while source ES-1001-2-1-P1 is not operating to no greater than 34 days in any
consecutive 12-month period.
e. The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-PI) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises)while source ES-1001-2-1-P1 is not operating to no greater than 6 days in
any consecutive 12-month period.
£ The Permittee shall implement the leak detection and repair (LDAR) program of 40 CFR Part 63,
Subpart UU, as per the requirements Section 2.2 B.2, below. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530, if the LDAR program requirements are not implemented.
g. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant (i.e. Wastewater Treatment Plant Aeration Tank No. 1; ID No. WWTP-
AT 1)for volatile organic compounds (VOC), when the wastewater stream consisting of methanol-wash
from the recovery operations(ID No. ES-1001-1-1-WW) is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VOC is not
determined every week or if the mass removal efficiency is less than 95%.
h. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 13.1.a,
Pennit 01819T40
Page 30
above, shall be controlled by the associated condensers. To assure compliance, the Permittee shall
perform periodic inspections and maintenance as recommended by the equipment manufacturer. In
addition, the Permittee shall perform an annual inspection of each condenser system, including the
following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is udder positive gauge pressure, leakage of the
contaminated gas stream. In order to monitor leakage of the coolant, the condensate shall be
inspected for the presence of coolant; and
ii. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
i. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.l.a,above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The
temperatures output from the sensors shall be continuously monitored and hourly values used to
determine the 24-hour average temperature at the condenser outlets. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the outlet temperatures of the condensers are not
maintained below the limits in the table below; or the condensers are not equipped with sensors to
continuously measure the outlet temperatures; or if those sensors are not inspected and maintained.
Emission Source Condenser ID No. Rewired Outlet Temperature
Rotocel solvent recycle tanks
(ID No. ES-100 1-2-1-P2) CD-1001-2-C-1
45°F,24-hour average,when
Recovery arcon tank M-1 CD-1001-1-3 source ES-100 1-2-1-P 1 is not
(ID No. ES4001-1-I-P1) operating and the tanks are used
Recovery stripper T-5 and for concrete processing in the
receiver M-21 (ID No. ES-1001- CD-1001-1-T513 recovery operation
1-1-P2)
Botanical extraction operations CD-i001-11-EX 1003 -40°F,24-hour average
(11)No. ES-1001-11-P)
Biomass extraction operations CD-1004-2EX1003 -40°F, 24-hour average
(ID No. ES-1004-2-P)
J Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.l.a,
above, shall also be controlled by the associated packed tower scrubber (ID No. CD-1001-2-S-1),
except as allowed pursuant to Sections 2.2 B.l.d and e, above. To assure compliance, the Permittee
shall perform periodic inspections and maintenance as recommended by the equipment manufacturer.
In addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system (if so
equipped), and perform maintenance and repair when necessary to assure proper operation of the
packed tower scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
Permit 01819T40
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The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the packed tower
scrubber is not inspected and maintained.
k. The Permittee shall install, maintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor, and an emission stream inlet temperature sensor for packed tower
scrubber CD-1001-2-5-1 in accordance with manufacturer's recommendations. The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530 if the flow meter and temperature sensors are not
installed, maintained, and calibrated, or if, except as allowed pursuant to Sections 2.2 B.l.d and e,
above:
L The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
I The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeeping [15A NCAC 2Q .0508(f)]
1. The Permittee shall maintain the following records:
i. VOC emissions for each calendar month,and for the consecutive 12-month period ending with each
calendar month,from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2,and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2, and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the
recovery process is processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations(ID No.ES-I 004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through k, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall be updated at least
monthly and record the following:
(A)The date and time of each recorded action;
(B) The operational status of source ES-1001-2-1-P1 during the filling of the rotocel solvent
recycle tanks(ID No. ES-1001-2-1-P2) from tanker trucks;
(C) The actual hours of operation of the rotocel solvent recycle tanks (ID No. ES-1001-2-1-P2),
recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and recovery stripper T-5 and receiver M-
21 (ID No. ES-1001-1-1-P2),when source ES-1001-2-1-P1 is not operating;
(D)The actual hours of operation of recovery arcon tank M-1 (1D No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and
source ES-1001-2-1-P1 is not operating;
(E) The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
WWTP-ATI) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(F) The 24-hour average outlet temperature of the associated condenser(s) listed in Section 2.2
B.Li,above:
(1) When source ES-1001-2-1-P1 is not operating and the Concrete Operations tanks (1D No.
ES-1001-1-2-P)are used for concrete processing in the recovery operation;
(2) When the biomass extraction operations(ID No. ES-1004-2-P) is operating;and/or
(3) When the botanical extraction operations(ID No.ES-1001-2-1-P2) is operating.
(G)The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream
inlet temperature of scrubber CD-1001-2-S-I at least once each day that source ES-1001-2-1-P1
operates;
(H)The results of maintenance performed on the condensers and scrubber listed in Section 2.2
Permit 01819T40
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B.La, above, and the associated temperature sensors and flow rate gauges; and
(1) Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
m. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.l.a, above.
u. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January
and June. All instances of deviations from the requirements of this permit must be clearly identified. In
addition, the semiannual reports shall also contain the following:
L The monthly VOC emissions from each of the following sources for each of the previous 17
months; and
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-100 1-2-1-P2, ES-1001-I.1-P1,
ES-1001-1-1-P2,and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2, and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the
recovery process is processing concrete;
(C) Botanical extraction operations(ID No. ES-1001-11-P); and
(D)Biomass extraction operations(ID No. ES-1004-2-P).
ii. Tile cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.n.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D .0530: Prevention of Significant Deterioration]
Eguipment identification [I SA NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified. Identification of the equipment does not require
physical tagging of the equipment. For example,the equipment may be identified on a plant site plan, in
log entries, by designation of process unit or affected facility boundaries by some form of weatherproof
identification, or by other appropriate methods. In addition to the above, the following equipment shall
be specifically identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe manner to perform monitoring;
(Connectors creed not be individually identified if all connectors in a designated area or length of
pipe are identified as a group, and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rupture disk upstream of the pressure device;
iii. Valves, pumps, and connectors that are designated unsafe-to-monitor (i.e., Permittee has
determined that monitoring personnel would be exposed to an immediate danger as a consequence
of complying with the monitoring requirements); and
iv. Valves that are difficult-to-monitor (i.e., Permittee has determined that the valve cannot be
monitored without elevating the monitoring personnel more than seven feet above a support surface
or it is not accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-
to-monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
Permit 01819T40
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explanation why the equipment is unsafe or difficult-to-monitor. These records must be kept at the plant
and he available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times, but not more frequently than the periodic monitoring
schedule otherwise applicable, and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment
at least once per calendar year and repair of the equipment if a leak is detected.
c. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process
unit shutdown. The identity of connectors designated as unsafe-to-repair and an explanation why the
connector is unsafe-to-repair shall be recorded.
Instrument and sensoiy monitoring for leaks [I5A NCAC 2Q .0508(f)]
d. Instrument monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak
to the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60,appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2, paragraph(a)of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis. The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there
is no instrument commercially available that will meet the performance criteria specified above, the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid,calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures
specified in Method 21 of 40 CFR part 60, appendix A.
iv. Calibration gases shall be zero air (Iess than 10 parts per million of hydrocarbon in air); and the
gases shall be mixtures of methane in air at a concentration no more than 2,000 parts per million
greater than the leak definition concentration of the equipment monitored. If the monitoring
instrument's design allows for multiple calibration scales, then the lower scale shall be calibrated
with a calibration gas that is no higher than 2,000 parts per million above the concentration
specified as a leak, and the highest scale shall be calibrated with a calibration gas that is
approximately equal to 10,000 parts per million. A calibration gas other than methane in air may be
used if the instrument does not respond to methane or if the instrument does not meet the
performance criteria specified Method 21 of 40 CFR part 60, appendix A. In such cases, the
calibration gas may be a mixture of one or more of the compounds to be measured in air.
v. Monitoring shall be performed when the equipment is in VOC service.
g. The Permittee may elect to adjustor not to adjust the instrument readings for background.
i. If the Permittee elects not to adjust instrument readings for background, the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,
above. In such cases, all instrument readings shall be compared directly to the applicable leak
definition for the monitored equipment to determine whether there is a leak or to determine
compliance with operational standards for pressure relief devices.
ii. If the Permittee elects to adjust instrument readings for background,the Permittee shall
Pet-nit 01819T40
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(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B)Determine the background level using the procedures in Method 21 of 40 CFR part 60,
appendix A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored
equipment to determine whether there is a leak or to determine compliance operational
standards for pressure relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at
the time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair. The written procedures may be included as part of the startup, shutdown,
and malfunction plan, or may be part of a separate document that is maintained at the plant
site. In such cases, reasons for delay of repair may be documented by citing the relevant
sections of the written procedure(i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts, there must be documentation
that the spare parts were sufficiently stocked on-site before depletion and the reason for
depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
i. The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar- days
after it is detected, except as provided for in delay of repair and/or unsafe to repair connectors. A first
attempt at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at
repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring that
the seal flush is operating at design pressure and temperature. First attempt at repair for valves includes,
but is not limited to,tightening the bonnet bolts, and/or replacing the bonnet bolts,and/or tightening the
packing gland nuts,and/or injecting lubricant into the lubricated packing.
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring.
Identification that has been placed on equipment determined to have a leak, except for a valve or for a
connector in gas/vapor or Iight liquid service, may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and, where appropriate, why the repair was
technically infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical, but no later than the end of the next
process unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed
for a valve if valve assembly replacement is necessary during the process unit shutdown, and valve
assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked
Permit 01819T40
Page 35
before the supplies were depleted. Delay of repair beyond the second process unit shutdown will
not be allowed unless the third process unit shutdown occurs sooner than six months after the first
process unit shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if.
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair,and
(B) When repair procedures are effected, the purged material can not be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a quality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg, below) will provide better performance, or the repair is completed as
soon as practical, but not later than 6 months after the leak was detected and one of the following is
used;
(A)A dual mechanical seal system;
(B)A pump that meets has no external shaft penetrating the pump housing;or
(C)A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNanor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines
a leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak,the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with
less than one percent leaking valves.
(B)The Permittee may elect to monitor each valve once every form quarters for process units with
less than 0.5 percent leaking valves.
(C)The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the
monitoring frequency provisions to each subgroup. If the Permittee subdivides the valves in the group
of process units, then the following provisions apply.
L The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup. Valves with less
than one year of monitoring data or valves not monitored within the last twelve inonths must be
placed initially into the most frequently monitored subgroup until at least one year of
monitoring data have been obtained.
(B)Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
Permit 01 S 19T40
Page 36
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to
a less frequently monitored subgroup provided that the valves to be reassigned have not leaked
for the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the
valve or group of valves is to be reassigned to a subgroup being monitored annually). Non-
repairable valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so
indicate the performance in the next periodic report. If the overall performance of total valves in the
applicable process unit or group of process units is two percent leaking valves or greater, the 1
Permittee shall no longer subgroup and shall revert to the program required in Section 2.2 B.2.p. for
that group of process units. The Permittee can again elect to comply with the valve subgrouping
procedures if future overall performance of total valves in the process unit or group of process units
is again less than two percent.The overall performance of total valves in the applicable process unit
or group of process units shall be calculated as a weighted average of the percent leaking valves of
each subgroup according to following equation:
(%VL' x V;}
%V —
Lo - H
V;
Where: %VLO Overall performance of total valves in the applicable process unit or group of
process units
%VLi =Percent leaking valves in subgroup i,most recent value
V; =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee shall maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for each subgroup for each monitoring period;
(C) Which valves are reassigned, the last monitoring result prior to reassignment, and when they
were reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next
monitoring period of the decision to subgroup valves. The notification shall identify the
participating process units and the number of valves assigned to each subgroup, if applicable, and
may be included in the next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for each process group (i.e., botanical extraction,
biomass extraction, and Rotocelhecovery) for comparison with the sub grouping criteria specified in
Section 2.2 B.2.m, above, and the percent leaking valves for each monitoring period for each process
unit or valve subgroup shall be calculated using the following equation:
%V1 = V x 100
T
Where: %VL = Percent leaking valves.
Permit 0 1 819T40
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Vu, = Number of valves found leaking,excluding non-repairable valves and including those
valves found whose repair was not confirmed with both post leak repair monitoring
and periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly, or semiannual monitoring frequencies, the percent leaking valves shall be the arithmetic
average of the percent leaking valves from the last two monitoring periods. When determining
monitoring frequency for each process unit or valve subgroup subject to annual or biennial (once every
2 years) monitoring frequencies, the percent leaking valves shall be the arithmetic average of the
percent Ieaking valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time
the valve is identified as leaking and non-repairable. Otherwise, a number of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in
regulated material service at a process unit or affected facility, the number of non-repairable valves
exceeding one percent of the total number of valves in regulated material service shall be included
in the calculation of percent leaking valves.
p. If a leak is determined, then the leak shall be repaired. After a leak has been repaired,the valve shall be
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and
first attempt at repair. The monitoring shall be conducted to determine whether the valve has
resumed leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides
with the time specified. Alternatively, other monitoring may be performed to satisfy the
requirement regardless of whether the timing of the monitoring period for periodic monitoring
coincides with the time above.
iii. If a leak is detected by monitoring that is conducted after leak repair,the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) If the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy the
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1, above, and the Permittee shall monitor the valve according to the
written plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
permit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that
is designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b,above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal.The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection,the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of
2,000 parts per million (ppm) or greater it shall be repaired using the procedures in Sections 2.2
B.2A through 2.2 B.2.k, above; or
Permit 01819T40
Page 38
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly
visual inspection provided that each pump is visually inspected as often as practical and at least
monthly.
t. If, when calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak, the Permittee
shall implement a quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.99,
below. The Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except
that pumps found leaking in a continuous process unit within one month after start-up of the pump
shall not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
I
%P1. _ —PS}—PS x100
P.1.
Where: %PL=Percent leaking pumps
PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current
monitoring period.
P1. =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in gas and vapor service and in lip-lit liquid service standards [15A NCAC 2Q .0508(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater than or equal to 500 parts per million is
measured, a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this
requirement and shall be monitored and inspected according to the written plan specified in Section 2.2
B.2.b,above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but
less than 0.5 percent, then monitor within four yearns. The Permittee may comply with this
requirement by monitoring at least 40 percent of the connectors within two years of the start of the
monitoring period, provided all connectors have been monitored by the end of the four year
monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical, but within the next six months, all connectors that have not yet
been monitored during the monitoring period if the percent leaking connectors is greater than or
equal to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new
monitoring period shall be started based on the percent leaking connectors of the total
monitored connectors.], or
(B)Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
Permit 01819T40
Page 39
iv. If, during the monitoring, a connector is found to be leaking, it shall be re-aonitored once within 90
days after repair to confirm that it is not leaking.
v. The Permittee shall Keep a record of the start date and end date of each monitoring period under
this section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows:
%CL = Cr x 100
C7.
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
C, = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried, insulated in a manner that prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
v. Not able to be accessed in a safe manner to perform monitoring
are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory,or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [15A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below, each pressure relief device in gas and vapor service
shall be operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of
less than 500 parts per million, as soon as practical, but no later than five calendar days after each
pressure release, except as provided for in delay of repair provisions of this permit;
ii. The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background, and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during
the monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar
days after each pressure release, except as provided for in delay of repair.
Quality improvement program for pumps [15A NCAC 2Q .0508(f)]
bb. If, on a 6-month rolling average, at least the greater of either 10 percent of the pumps in a process unit
or three pumps in a process unit leak, tine Permittee shall implement a quality improvement plan until
the number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in
the process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t,above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program. The data may be collected and the records may be
maintained on a process unit, affected facility, or plant site basis.
Permit 01819T40
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i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design (e.g., external shaft, flanged body); materials of construction;
if applicable, barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. The maximum instrument readings observed in each monitoring observation before repair,response
factor for the stream if appropriate, instrument model number,and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site) remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seal failures and were
removed from the process unit due to leaks. The inspection shall determine the probable cause of the
pump seal failure or of the pump leak and shall include recommendations, as appropriate, for design
changes or changes in specifications to reduce leak potential.
cc. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above,to determine the services, operating or maintenance practices, and pump or pump seal designs or
technologies that have poorer than average emission performance and those that have better than
average emission performance. The analysis shall determine if specific trouble areas can be identified
on the basis of service, operating conditions or maintenance practices, equipment design, or other
process-specific factors.
i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the service(s), operating conditions, or pump or pump seal
designs associated with poorer than average emission performance. A superior performing pump or
pump seal technology is one with a leak frequency of less than 10 percent for specific applications
in the process unit. A candidate superior performing pump or pump seal technology is one
demonstrated or reported in the available literature or through a group study as having low emission
performance and as being capable of achieving less than 10 percent Ieaking pumps in the process
unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process
unit due to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site, a company,
or a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The
quality assurance program may establish any number of categories, or classes, of pumps as needed to
distinguish among operating conditions and services associated with poorer than average emission
performance as well as those associated with better than average emission performance. The quality
assurance program shall be developed considering the findings of the data analysis required under
paragraph Section 2.2B.2.ee, above, and the operating conditions in the process unit. The quality
I
Perinit 01819T40
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assurance program shall be updated each year as long as the process unit has the greater of either 10
percent or more leaking pumps or has three leaking pumps.
L The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage,or other applicable identified critical parameters.
(B) Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C)Provide for an audit procedure for quality control of purchased equipment to ensure
conformance with purchase specifications.
(D)Detail off-line pump maintenance and repair procedures. These procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program.
gg. Three years after the start of the quality improvement program, the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
been identified as superior emission performance technology and that comply with the quality
assurance standards for the pump category. Superior emission performance technology is that category
or design of pumps or pump seals with emission performance that when combined with appropriate
process, operating, and maintenance practices, will result in less than 10 percent leaking pumps for
specific applications in the process unit. Superior emission performance technology includes material
or design changes to the existing pump, pump seal, seat support system, installation of multiple
mechanical seals or equivalent,or pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number
of pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero
integer value. The minimum number of pumps or pump seals shall be one. Pump replacement shall
continue until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above,
are pumps determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the
next planned process unit shutdown, provided the number of pump seals and pumps replaced is
equivalent to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shalt maintain records for the period of the quality improvement program for the process
unit prescribed below.
L When using a pump quality improvement program, the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B)Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,
above, and any recommendations for design or specification changes to reduce leak frequency;
and
(C)The beginning and ending dates while meeting the duality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak,the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream, the operating conditions and maintenance practices.
iv. All records documenting the quality assurance program for pumps as specified in the quality
assurance program, including records indicating that all pumps replaced or modified during the
period of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg, above.
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Recordkeening requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not
physically tagged and the Permittee is electing to identify the equipment through written documentation
such as a log or other designation.
jj. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
mm. For valves, the Permittee shall maintain the monitoring schedule for each process unit and the
valve subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pump visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service, the Permittee shall keep records of
the dates and results of monitoring following a pressure release.
qq. For a pump QIP program, the Permittee shall maintain the following records:
L hzdividual pump records as specified in Section 2.2 B.2.cc, above;
ii. Quality assurance program documentation as specified in Section 2.2 13.2.ff, above; and
iii. Quality improvement program records as specified in Section 2.2 B.2.hh,above.
Reporting requirements [15ANCAC 2Q .0508(f)]
rr. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January
and June. The report shall contain in summary format by equipment type(i.e., valves in gas/vapor/light
liquid service, Pumps in light liquid service, and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves,pumps and connectors,and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired, and for valves
and connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
tt. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection
instrument reading of less than 500 parts per million, report the results of all monitoring to show
compliance conducted within the semiannual reporting period.
vv. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report, if applicable,the initiation of a quality improvement program for pumps.
Permit 01819T40
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C. Sclareolide (SDE) Operations, including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity;ID No. M-20);
• Process equipment leaks (ID No. ES-1001-1-4-F);
• Four batch reactors (ID Nos. M-10, M-10A,D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate; ID No. CD-M-34); and
• SDE Operations wastewater stream (ID No. ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide, including:
• Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks(ID No.ES-1001-1-3-F);
• One distillation column (6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for sclareolide purification wastewater stream (ID No. ES-1001-
1-3-W W)
Ethyl Vanillin Glucoside (EVG) Operations, including:
• One water spray fuine scrubber (0.5 gallon per minute minimum water injection rate; ID No.
CD-Z-9215) venting to one water spray fume scrubber (0.5 gallon per minute minimum water
injection rate; ID No. CD-Z-9216) controlling emissions from:
o Three reactors (ID Nos.D-2202,D-1215, and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks (ID No.ES-1003-2-2-F); and
• EVG Operations wastewater stream (ID No.ES-1003-2-2-WW)
Sclareol Reciystallization (SFG) Operations, including:
• Four process tanks (2,500 gallons capacity each; ID Nos.T-3002 through 3005);
• One hexane storage tank(6,700 gallon capacity; ID No.T-3001);
• One centrifuge(ID No. C-3001);
• One chilled water condenser(ID No. CD-3001)controlling emissions from:
- One reactor(ID No.R-3001)equipped with a process chilled water condenser(EX-3001)
- One reactor(ID No.R-3002)equipped with a process chilled water condenser(EX-3003)
- One steam heated dryer(ID No.D-3001)
• Process equipment leaks (ID No.ES-1003-10-F);
• SFG Operations wastewater stream (ID No.ES-1003-10-WW)
Plant Nutrient Extraction (PNE) Operations, including one water spray fume scrubber (0.5
gallon per minute minimum water injection rate; ID No. CD-Z-9215) venting to one water
spray fume scrubber (0.5 gallon per minute minimum water solution injection rate; ID No.
CD-Z-9216) controlling emissions from:
• One product extract reactor(ID No. D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities (ID No. ES-1003-2-1-P);
• One centrifuge(ID No. C-31203);
• Process equipment leaks(ID No.ES-1003-2-1-F);
• One waste solids separator vessel (1,333 gallon capacity; ID No. D31211) and one associated
chilled water condenser(ID No.EX2205); and
• PNE Process wastewater stream (ID No.ES-1003-2-1-WW)
Permit 01819T40
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Concrete Operations,including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and HB-4);
• Process equipment leaks (H)No.ES-1001-1-2-F);
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser(ID No. CD-1001-1-2); and
• Concrete Operations wastewater stream (ID No.ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-ATI)
The following table provides a sununary of limits and standards for the emission sources describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Maximum Achievable Control 15A NCAC 2D .1111
Hazardous Air Pollutants (HAP) Technology [40 CFR Part 63, Subpart
FFFF]
1. 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63,Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF, including Subpart A "General Provisions". For convenience, some of the
relevant definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435,
63.2440, 63.2445(b),and 63.25501
Group I batch process veal means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions from all of the batch process vents are greater than or equal to
10,000 Ib/yr at an existing source or grater than or equal to 3,000 lb/yr at a new source.
Group 2 batch process vent means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group I continuous process vent means a continuous process vent for which the flow rate is greater
than or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b), is less than or equal to 1.9 at an existing source and less than or
equal to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not ineet the definition of
a Group 1 continuous process vent.
Group I storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group I wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria for Group 1 status in §63.2485(c)for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in§63.132(d)for compounds in Table 8 to subpart G of this part 63.
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group i wastewater stream.
Pei7nit 01819T40
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In organic HAP service means that a piece of equipment either contains or contacts a fluid (liquid or
gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions
of§63.180(d). The provisions of§63.180(d) also specify how to determine that a piece of equipment is
not in organic HAP service.
Miscellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in §63.2435(b). For
the purposes of this subpart, process includes any, all or a combination of reaction, recovery,
separation, purification, or other activity, operation, manufacture, or treatment which are used to
produce a product or isolated intermediate.
Nonslandaral batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch. A nonstandard batch may be necessary as a result of a malfunction, but j
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of
an MCPU as described by records specified in §63.2525(b).
Point of determination means each point where process wastewater exits the MCPU or control device.
Slandard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions fi-om a standard batch ate based on the operating
conditions that result in highest emissions. The standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Requirements/Limitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.I.b.i through v, below:
i. The Permittee must submit a Notice of Compliance Status Report for the SDE Operations, the
Concrete Operations, and/or the PNE Operations prior to the operation of those operations in
organic HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63,
Subpart FFFF apply to those operations,pursuant to 40 CFR§63.2520(d).
ii. Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to
avoid unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. If a Group 2 emission point becomes a Group I emission point, the Permittee must be in
compliance with the Group I requirements beginning on the date the switch occurs. An initial
compliance demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within
150 days after the switch in group status occurs. The Permittee shall be deemed in non-compliance
with 15A NCAC 2D .I I II if the Permittee does not meet these requirements. [40 CFR
§63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR §63.6(e) for the affected sources. The Permittee is not, however, required to
address equipment Ieaks (except for control devices) or Group 2 emission points in the SSM Plan.
The SSM Plan must describe, in detail, procedures for operating and maintaining the affected
sources during periods of startup, shutdown, and malfunction; and corrective actions for
malfunctioning process, control,and monitoring equipment used to comply with Subpart FFFF. The
SSM Plan does not need to address any scenario that would not cause an affected source to exceed
an applicable emission Iimit in Subpart FFFF. The SSM Plan must be maintained on site and made
available for inspection by authorized personnel. [40 CFR§§63.6(e)(3)and 63.25250)]
The Permittee shall be deemed in non-compliance with I5A NCAC 2D A I I I if it does not meet the
requirements of Sections 2.2 C.l.b.i through v,above.
Permit 01819T40
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Monitoring Requirements [I SA NCAC 2Q .0508(f)]
c. The Permittee shall comply with the specific requirements of Sections 2.2 C.l.c.i through vii, below:
L Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.i(A)and (B), below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.h through k,
above.
(B) For continuous process vent associated with the Botanical Extraction Operations, the Permittee
shall perform the monitoring found in Sections 2.2 B.1.h and i, above.
ii. Batch process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.ii(A)through (C), below,for the affected batch process vents:
(A)For the batch process vents associated with the SFG Operations, the EVG Operations, and the
Biological conversion equipment for purification of sclareolide, the Permittee shall comply
with the requirements of 40 CFR §63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF. To
maintain Group 2 classification for these emission sources the organic HAP emissions must be
less than 10,000 pounds per consecutive 365-day period, each source. The Permittee shall
monitor the organic HAP emissions from each of these emission sources,monthly, as follows:
(1) Organic HAP emissions from the SFG Operations shall calculated using the following
equation:
ornrdsl 11outrds) ,, rotttrdsOrganic HAP= 37.89 pxBtf + [11.45(polfflds xBregJ+[15.03(P xB �+L9.75(P )xB,,
J J
tan tll batch batch batch
Where: B,,g — The number of regular batches processed in the SFG Operations; and
Bf,C The number of recrop batches processed in the SFG Operations
Btc = The number of third crop batches processed in the SFG Operations; and
Btf = The number of hexane tank(T-3001) fills.
(2) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 1.0 pounds x B
( batch
Where: B — The number of batches processed in the EVG Operations
(3) Organic HAP emissions from the Biological conversion equipment for purification of
sclareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x B
batch
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B) The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.l.c.ii(A)(1)through(3), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations, the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of
40 CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,
combined. The Permittee shall monitor the organic HAP emissions from these batch process vents,
monthly, as follows:
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:
Permit 01 S 19T40
Page 47
(pounds poundsOrganicHAP= 11.3 hatch )x B,�g +[31.8(( batch )X B,,,
Where: Bfeg = The number of regular batches processed in the EVG Operations; and
B,,, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.I.c.iii(A), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(i i).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Pertnittee shall comply
with the requirements of 40 CFR§63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair
(LDAR) program found in Section 2.2 B.2, above, for the equipment associated with the affected
sources.
vi. Wastewater streams: For the wastewater streams associated with the affected miscellaneous
organic chemical manufacturing processes (MCPU), the Permittee shall comply with the
requirements of 40 CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca,
Inc. facility;and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2, unless the conditions of Section 2.2 C.Lb.iv, above, have been
met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR§63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will
be used to detect leaks of process fluids into cooling water. This plan shall require monitoring
of one or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more
process parameters or other conditions that indicate a leak. The plan shall include the
following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s) or conditions(s) that shall constitute a leak. This shall be
documented by data or calculations showing that the selected levels or conditions will
reliably identify leaks. The monitoring must be sufficiently sensitive to determine the range
of parameter levels or conditions when the system is not leaking. When the selected
parameter level or condition is outside that range, a Ieak is indicated;
(3) The monitoring frequency which shall be no Iess frequent than monthly for the first 6
months and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after
discovery of the leak.
(C)The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded, retain the most recent superseded plan at least until 5 years from
the date of its creation.
Pennit 01819T40
Page 48
(D)If a leak is detected in any heat exchanger system, it shall be repaired as soon as practical but
not later than 45 calendar days after the Permittee receives results of monitoring tests indicating
a leak, unless the Permittee demonstrates that the results are due to a condition other than a
leak. Once the leak has been repaired, the owner or operator shall confirm that the heat
exchange system has been repaired within 7 calendar days of the repair or startup, whichever is
later, except where the Permittee appropriately applies the delay of repair provisions found in
Section 2.2 C.i.c.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the j
process. Delay of repair is also allowed if repair is technically infeasible without a shutdown
and any one of the conditions listed in 40 CFR§63.104(e)(1)through(2) is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.eA through vii,above.
Record1weying Requirements[15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.l.d.i through v,below:
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B)An identification of related process vents (including associated emissions episodes),
wastewater points of determination(PODS),and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents, the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of
operating and/or testing conditions for any associated control device;
(E) The process vents, wastewater POD, transfer racks, and storage tanks (including those from
other processes)that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G)Calculations and engineering analyses required to demonstrate compliance.
iii. For each affected MPCU with a Group 2 process vent, the Permittee shall retain the following
records:
(A)A record of the day each batch was completed;
(B)A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a
non-standard batch; and
(D)Records of the daily 365-day rolling summations of emissions, or alternative records that
correlate to the emissions(e.g.,number of batches), calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream,the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds listed in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw), including documentation of the methodology used to determine concentration; and,
(D)Stream flow rate(in litershnin).
v. For each affected heat exchanger system, the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak, the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan, including the date the leak was discovered;
(C)The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .l 111 if the Permittee does not
Permit 01819T40
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meet the requirements of Sections 2.2 C.l.d.i through v, above.
Renortin [15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR§63.2460(b)(6) and 40 CFR§63.2520(e)(10).
f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and December, and July 30 of
each calendar year for the preceding six-month period between January and June. The report shall
contain the following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard
specified in this subpart, include a statement that there were no deviations from the emission limits,
operating limits,or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period;and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable),as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered
by the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary format by equipment type, the number of
components for which leaks were detected and for valves,pumps and connectors show the percent .
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required, and for valves and connectors, identify the number
of components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized, report that delay of repair has occurred and report
the number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report, if applicable,the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair,
include the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s)for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired, the expected date of repair.
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2. 15A NCAC 2Q.0317: AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the SFG operations shall discharge into the atmosphere
less than 95.29 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]
MonitoringMecordlccening,[15A NCAC 2Q .0508 (f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
L The monthly VOC emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
3. LIMITATION TO AVOID BEING CLASSII+IED AS A MON GROUP 1 BATCH PROCESS VENT
a. In order to remain classified as a Group 2 batch process vent for hazardous air pollutants(HAP)under
40 CFR 63, Subpart PFFF, uncontrolled HAP emissions from the SFG operations shall be less than
10,000 pounds per year. The Permittee shall be deemed a Group I batch process vent if the HAP
emissions exceed this limit.
Monitorinu/Recordkeepintl Requirements [15A NCAC 2Q ,0508(l)]
b. Maintain monthly calculations of HAP emissions. The Permittee shall be deemed a Group 1 batch
process vent if the records are not maintained.
Reporting Reauh-ements [15A NCAC 2Q .0508(f)]
c. Submit to the Regional Supervisor, Division of Air Quality, semiannually, a report summarizing HAP
emissions from SFG operations containing the following:
L greatest quantity in pounds of an individual hazardous air pollutant used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average;
ii. pounds of all hazardous air pollutants used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average.
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SECTION 3 GENERAL CONDITIONS (version 3.6)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions[NCGS 143-215 and 15A NCAC 2Q,0508(i)(16)]
1.Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2.The terms,conditions,requirements, limitations,and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B,including assessment of civil and/or criminal penalties.Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3.This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the
facility which are not addressed in this permit.
4.This permit does not relieve the Permittee fiom liability for harm or injury to human health or welfare,animal or plant
life,or property caused by the construction or operation of this permitted facility,or fiom penalties therefore,nor does
it atlow the Pennittee to cause pollution in contravention of state laws or rules,unless specifically authorized by an
order from the North Carolina Environmental Management Commission.
5.Except as identified as state-only requirements in this permit,all terms and conditions contained herein shall be
enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal Clean Air Act.
6.Any stationary source of air pollution shall not be operated,maintained,or modified without the appropriate and valid
permits issued by the DAQ,unless the source is exempted by rule. The DAQ may issue a permit only after it receives
reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements.
A permitted installation may only be operated,maintained,constructed,expanded,or modified in a manner that is
consistent with the terms of this permit.
B. Permit Availability[15A NCAC 2Q.0507(k)and.0508(i)(9)(B)]
The Pennittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit teen
one complete copy of the application and any information submitted in support of the application package. The permit and
application shall be made available to an authorized representative of Department of Environment and Natural Resources
upon request.
C. Severability Clause[15A NCAC 2Q.0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid,the
provisions in this permit are severable so that all requirements contained in the permit,except those held to be invalid,shall
remain valid and must be complied with.
I
D. Submissions[15A NCAC 2Q .0507(e)and 2Q.0508(i)(16)]
Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,notifications,request j
for renewal,and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer
to the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems(CEMS)
reports,continuous opacity monitoring systems(COMS)reports,quality assurance(QA)/quality control(QC)reports,acid
rain CEM certification reports,and NOx budget CEM certification reports,one copy shall be sent to the appropriate
Regional Office and one copy shalt be sent to:
Supervisor,Stationary Source Compliance
North Carolina Division ofAir Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
E. Duty to Comply[15A NCAC 2Q.0508(i)(3)]
Tire Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in this permit.
Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a violation of
Permit 01819T40
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the Federal Clean Air Act. Noncompliance with any pen-nit condition is grounds for enforcement action,for pen-nit
termination,revocation and reissuance,or modification,or for denial of a permit renewal application.
F. Circumvention-STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner 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 pollution control device(s)and appurtenances.
G. Permit Modifications
1.Administrative Permit Amendments[I5A NCAC 2Q.0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with I5A NCAC 2Q
.0514.
2.Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q.0524 and 2Q.0505]
The Perrnittee shall submit an application for an ownership change in accordance with 15A NCAC 2Q.0524 and 2Q
.0505.
3.Minor Permit Modifications [I5A NCAC 2Q.0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q .0515.
4.Significant Permit Modifications[15A NCAC 2Q.0516]
The Permittee shall submit an application for a significant pen-nit modification in accordance with 15A NCAC 2Q
.0516.
5.Reopening for Cause[I5A NCAC 2Q.0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q.0517.
H. Changes Not Rea uirina Permit Modifications
1.Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in Section 1
must be reported to the Regional Supervisor,DAQ:
a. changes in the infonnation submitted in the application;
b. changes that modify equipment or processes;or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit
conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations
specified herein.
2.Section 502(b)(10)Changes[I 5A NCAC 2Q.0523(a)]
a. "Section 502(b)(10)changes"means changes that contravene an express permit tern or condition.Such changes
do not include changes that would violate applicable requirements or contravene federally enforceable permit
terms and conditions that are monitoring(including test methods),recordkeeping,reporting,or compliance
certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Pennittee notifies the Director and EPA with written notification at least seven days before the change
is made;and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions;and
iv. any pennit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10)changes shall be made in the permit the next time that the pennit is revised or renewed,
whichever comes first.
3.Off Permit Changes[15A NCAC 2Q.0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
i
Permit 01819T40
Page 53
a. the change affects only insignificant activities and the activities remain insignificant after the change;or
b. the change is not covered under any applicable requirement.
4.Emissions Trading[15A NCAC 2Q.0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D,including subsequently adopted maximum
achievable control technology standards,emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 2Q.0523(c).
I.A.Reporting Requirements for Excess Emissions and Permit Deviations
[15A NCAC 2D.0535(f)and 2Q.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard allowed by any
rule in Sections.0500,.0900,.1200,or.1400 of Subchapter 21);or by a permit condition;or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q.0700. (Note:Definitions of excess emissions cinder 2D.I I 10 and 2D
.1111 shall apply where defined by cwle.)
"Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and conditions of
this penuit including those attributable to upset conditions as well as excess emissions as defined above lasting less than
four hours.
Excess Emissions
1.If a source is required to report excess emissions under NSPS(15ANCAC 2D.0524),NESHAPS(15A NCAC 2D
.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of excess emissions,reporting
shall be performed as prescribed therein.
2.If the source is not subject to NSPS(15A NCAC 2D.0524),NESHAPS(15A NCAC 2D.I I 10 or.1111),or these ru les
do NOT define"excess emissions,"the Permittee shall report excess emissions hi accordance with 15A NCAC 2D
.0535 as follows:
a. Pursuant to 15A NCAC 2D.0535,if excess emissions last for more than four hours resulting from a malfunction,
a breakdown of process or control equipment,or any other abnormal condition,the owner or operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m.Eastern Time of the
Division's next business day of becoming aware of the occun•ence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration;and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished;and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC
2D.0535(f)(3).
Permit Deviations
3.Pursuant to 15A NCAC 2Q .0508(f)(2),the Permittee shall report deviations fiorn permit requirements(terms and
conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from pen-nit requirements not covered under
15A NCAC 2D.0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of
such deviation and any connective actions or preventative actions taken. The responsible official shall certify all
deviations from permit requirements.
I.B. Other Requirements under 15A NCAC 2D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D.0535,including 15A
NCAC 2D.0535(c)as follows:
1.Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the appropriate
rule unless the owner or operator of the sources demonstrates to the Director,that the excess emissions are a result of a
malfunction. Tyre Director shall consider,along with any other pertinent information,the criteria contained in 15A
NCAC 2D.0535(c)(1)through(7).
2. 15A NCAC 2D.0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
Permit 01819T40
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J. Enteraency Provisions[40 CFR70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1.An emergency means any situation arising fi•om sudden and reasonably unforeseeable events beyond the control of the
facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitation under the permit,due to unavoidable
increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment,lack of preventive maintenance,careless or improper operation,or operator
error.
2.An emergency constitutes an aflinnative defense to an action brought for noncompliance with such technology-based
emission limitations if the conditions specified in 3.below are met.
3.The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating togs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the pennit;and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency,steps
taken to mitigate emissions,and corrective actions taken.
4.In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the burden of
proof.
5.This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal[15A NCAC 2Q.0508(e)and 2Q.0513(b)]
This I5A NCAC 2Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its term.
Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 2Q .0500 renewal application is
submitted at least nine months before the date of permit expiration. If the Permittee or applicant has complied with 15A
NCAC 2Q .0512(b)(1), this 15A NCAC 2Q .0500 permit shall not expire until the renewal permit has been issued or
denied. Permit expiration under 15A NCAC 2Q .0400 terminates the facility's right to operate unless a complete 15A
NCAC 2Q .0400 renewal application is submitted at least six months before the date of permit expiration for facilities
subject to 15A NCAC 2Q .0400 requirements. In either of these events, all terns and conditions of these permits shall
remain in effect until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense[15A NCAC 2Q.0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information)[15A NCAC 2Q.0508(i)(9)]
1.The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director may request in
writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to
determine compliance with the permit.
2.Tile Permittee shalt furnish the DAQ copies of records required to be kept by the permit when such copies are requested
by the Director.For information claimed to be confidential,the Permittee may furnish such records directly to the EPA
upon request along with a claim of confidentiality.
N. Duty to Supplement[15A NCAC 2Q.0507(f)]
The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the
permit application,shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee
shall also provide additional information as necessary to address any requirement that becomes applicable to the facility
after the date a complete permit application was submitted but prior to the release of tine draft permit.
O. Retention of Records[15A NCAC 2Q.0508(f)and 2Q.0508(I)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five
Permit 01819T40
Page 55
years from the date of the monitoring sample,measurement,report,or application. Supporting information includes al
calibration and maintenance records and all original strip-chart recordings for continuous monitoring information,and
copies of all reports required by the permit. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. Any records required by the conditions of this permit shall be kept on site and made
available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 21).0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,bl Forsyth
Street,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for the preceding calendar year)
by a responsible official with a1I federally-enforceable terms and conditions in the permit, including emissions limitations,
standards,or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the
entire year regardless of who owned the facility during the year. The compliance certification shall comply with additional
requirements as may be specified under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance
certification shall specify:
1.the identification of each term or condition of the permit that is the basis of the certification;
2.the compliance status(with the terms and conditions of the permit for the period covered by the certification);
3.whether compliance was continuous or intermittent;and
4.the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Resnonsible Official[15A NCAC 2Q.0520]
A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after
reasonable inquiry,the statements and information in the document are true,accurate,and complete.
R. Permit Shield for Applicable ReQuirements[15A NCAC 2Q.0512]
1.Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the permit as of the date of permit
issuance.
2.A permit shield shall not alter or affect:
a. the power of the Commission,Secretary of the Department,or Governor under NCGS 143-215.3(a)(12),or EPA
under Section 303 of the Federal Clean Air Act; j
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective j
date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV;or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3.A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made j
under 15A NCAC 2Q.0523.
4.A permit shield does not extend to minor permit modifications made under 15A NCAC 21).0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 2Q.0519]
The Director may terminate,modify,or revoke and reissue this permit if:
1.the information contained hi the application or presented in support thereof is determined to be incorrect;
2.the conditions under which the pennit or permit renewal was granted have changed;
3.violations of conditions contained in the permit have occurred;
4.the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or
5.the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to carry out the
purpose ofNCGS Chapter 143,Article 21B.
T. Insignificant Activities f 15A NCAC 2Q.0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or that the owner or operator of the source is exempted fi•om demonstrating compliance with
any applicable requirement. The Permittee shall have available at the facility at all times and made available to an
authorized representative upon request,documentation,including calculations,if necessary,to demonstrate that an
emission source or activity is insignificant.
Permit 01819T40
Page 56
U. Property Rights[15A NCAC 2Q.0508(i)(8)]
This permit does not convey any proper rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry[15A NCAC 2Q.0508(1)and NCGS 143-215.3(a)(2)]
1.Upon presentation of credentials and other documents as may be required by law,the Permittec shall allow the DAQ,or
an authorized representative,to perform the following:
a. enter the Pennittee's premises where the permitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions of the permit;
b. have access to and copy,at reasonable tunes,any records that are required to be kept under the conditions of the
permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring
and air pollution control equipment),practices,or operations regulated or required under the permit;and
d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under
Section 114 or other provisions of the Federal Clean Air Act.
2.No person shall refirse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment[15A NCAC 2Q.0508(i)(10)]
1.The Pennittee shall pay all fees in accordance with 15A NCAC 2Q.0200.
2.Payment of fees may be by check or money order made payable to the N.C.Department of Environment and Natural
Resources. Annual permit fee payments shall refer to the permit number.
3.If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate action to terminate
the permit under 15A NCAC 2Q.0519.
X. Annual Emission Inventory Requirements[15A NCAC 2Q.0207]
The Permittee shall report by.Tune 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q
.0207(a)from each emission source within the facility during the previous calendaryear. The report shall be in or on such
form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the
facility.
Y. Confidential Information[15A NCAC 2Q.0107 and 2Q.0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107,the
Pennittee may also submit a copy of all such urfannation and claim directly to the EPA upon request. All requests for
confidentiality must be in accordance with 15A NCAC 2Q.0107.
Z. Construction and Operation Permits[15A NCAC 2Q.0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or
emission source which is not exempted from having a permit prior to the beginning of construction or modification,in
accordance with all applicable provisions of 15A NCAC 2Q.0100 and.0300.
AA.Standard Application Form and Required Information[15A NCAC 2Q.0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 2Q
.0505 and .0507.
BB.Financial Responsibility and Complianee History[15A NCAC 2Q.0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
CC.Refrigerant Requirements(Stratospheric Ozone and Climate Protection)[15A NCAC 2Q.0501(c)]
1.if the Pennittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or 11
Permit 0 1 819T40
Page 57
ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40
CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment
according to the work practices,personnel certification requirements,and certified recycling and recovery equipment
specified in 40 CFR Pail 82 Subpart F.
2.The Permittee shall not knowingly vent or otherwise release any Class I or 11 substance into the environment during the
repair,servicing,maintenance,or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3.The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR❑ 82.166. Reports shall be
submitted to the EPA or its designee as required.
DD.Prevention of Accidental Releases-Section 112(r)[15A NCAC 2Q.0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r)of the
Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
FF. Prevention of Accidental Releases General Duty Clause-Section 112(r)(1)-
FEDERALLY-ENFORCEABLE ONLY
Although a risk management plan may not be required,if the Permittee produces,processes,handles,or stores any amount
of a listed hazardous substance,the Pennittee has a general duty to take such steps as are necessary to prevent the
accidental release of such substance and to minimize the consequences of any release.
FF. Title I Allowances [t5A NCAC 2Q.0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not use
allowances as a defense to noncompliance with any other applicable requirement. The Permittec's emissions may not
exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG.Ali-Pollution Emergency Episode[15A NCAC 2D.0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to operate in
accordance with the Permittee's previously approved Emission Reduction Plan or,in the absence of an approved plan,with
the appropriate requirements specified in 15A NCAC 2D.0300.
HH.Re istration of Air Pollution Sources[15A NCAC 2D.0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to
register a source of air pollution,this registration and required information will be in accordance with 15A NCAC 2D
.0202(b).
II. Ambient Air Quality Standards[15A NCAC 2D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,any source
of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 2D.0400 to be exceeded at any point beyond the premises on which the source is located. When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of
the ambient air quality standards or are required to create an offset,the permit shall contain a condition requiring these
controls.
JJ. General Emissions Testing and Reporting Requirements[15A NCAC 2Q.0508(i)(16)]
Emission compliance testing shall be by the procedures of Section.2600,except as may be otherwise required in Rules
.0524,.0912, .1110, .11 l 1,or.1415 of Subchapter 2D.If emissions testing is required by this permit or the DAQ or if the
Permittee submits emissions testing to the DAQ to demonstrate compliance,the Permittee shall perform such testing in
accordance with 15A NCAC 213.2600 and follow the procedures outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing.Testing protocols are not required to be pre-approved by the Director prior to
air pollution testing.The Director shall review air emission testing protocols for pre-approval prior to testing if
requested by the owner or operator at least 45 days before conducting the test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard shall
notify the Director at least 15 days before beginning the test so that the Director may at his option observe the test.
3.The owner or operator of the source shall arrange for controlling and measuring the production rates during the
period of air testing.The owner or operator of the source shall ensure that the equipment or process being tested is
Permit 01819T40
Page 58
operated at the production rate that best fulfills the purpose of the test.The individual conducting the emission test
shall describe the procedures used to obtain accurate process data and include in the test report the average
production rates determined during each testing period.
4.Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after sample
collection unless otherwise specified in the specific conditions. The owner or operator may request an extension to
submit the final test report.The Director shall approve an extension request if he fmds that the extension request is
a result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the validity of
the compliance test. The Director may:
(1) Allow deviations fi•om a method specified under a rule in this Section if the owner or operator of the
source being tested demonstrates to the satisfaction of the Director that the specified metliod is
inappropriate for the source being tested.
(2)Prescribe alternate test procedures on an individual basis when he finds that the alternative method is
necessary to secure more reliable test data.
(3)Prescribe or approve methods on an individual basis for sources or pollutants for which no test method is
specified in this Section if the methods can be demonstrated to determine compliance of permitted
emission sources or pollutants.
b.The Director may authorize the Division of Air Quality to conduct independent tests of any source subject to a
rule in this Subchapter to determine the compliance status of that source or to verify any test data submitted
relating to that source.Any test conducted by the Division of Air Quality using the appropriate testing
procedures described in Section 2D.2600 has precedence over all other tests.
KK.Reopening for Cause[15A NCAC 2Q.0517]
L A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three or more
years;
b. additional requirements(including excess emission requirements)become applicable to a source covered by Title
1V;
c. the Director or EPA finds that the pennit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards or other terms or conditions of the pennit;or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2.Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is
promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit term
unless the term of the permit was extended pursuant to 15A NCAC 2Q.0513(c).
3.Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 2Q.0507,.0521,or
.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the permit is reopened,the
procedures in 15A NCAC 2Q.0300 shall be followed. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4.The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,except in
cases of imminent threat to public health or safety the notification period may be less than 60 days.
5.Within 90 days,or 180 days if the EPA extends the response period,after receiving notification firm the EPA that a
permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the EPA a proposed
determination oftennination,modification,or revocation and reissuance,as appropriate.
LL. Reporting Requirements for Non-Operating Equipment[15A NCAC 2Q.0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken 11-om
and placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the
permit shall be unplemented within the monitoring period.
MM.Fugitive Dust Control Reguirennent[15A NCAC 2D.0540]-STATE ENFORCEABLE ONLY
As required by l 5A 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
boundary.If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the
property y P g� • n' Y
property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
Permit 01819T40
Page 59
operator may be required to submit a fugitive dust plan as described in 2D.0540(f).
"Fugitive dust emissions"means particulate matter from process operations that does not pass through a process stack or
vent and that is generated within plant property boundaries from activities such as:unloading and loading areas,process
areas stockpiles,stock pile working,plant parking lots,and plant roads(including access roads and haul roads).
NN.Specific Permit Modifications[I5A NCAC 2Q.0501 and.0523]
1.For modifications made pursuant to 15A NCAC 2Q.0501(c)(2),the Permittee shall file a Title V Air Quality Permit
Application for the air emission source(s)and associated air pollution control device(s)on or before 12 months
after commencing operation.
2.For modifications made pursuant to 15A NCAC 2Q .0501(d)(2),the Permittee shal I not begin operation of the air
emission sources)and associated air pollution control device(s)until a Title V Air Quality Permit Application is
filed and a construction and operation permit following the procedures of Section .0500(except for Rule .0504 of
this Section)is obtained.
3.For modifications made pursuant to 502(b)(10), in accordance with I5A NCAC 2Q .0523(a)(1)(C),the Permittee
shall notify the Director and EPA(EPA-Air Planning Branch,61 Forsyth St., Atlanta,GA 30303)in writing at
least seven days before the change is made. The written notification shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions;and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement,with the next significant modification or Air Quality Permit renewal,
the Permittee shall submit a page"ES"of the application forms signed by the responsible official verifying that the
application For the 502(b)(10)change./modification, is true,accurate,and complete. Further note that
modifications made pursuant to 502(b)(10)do not relieve the Permittee fi-om satisfying preconstruction
requirements.
00.Third Party Participation and EPA Review[15A NCAC 2Q.0521,.0522 and .0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency(EPA), EPA's
decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party
petition,the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit.
The time period available to submit a public petition pursuant to 15A NCAC 2Q .0518 begins at the end of the 45-day
EPA review period.
i
I
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CAA Clean Air Act
CAIR Clean Air Interstate Rule
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
MCPU Miscellaneous Organic Chemical Manufacturing Process Units
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PMrp Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
SIC Standard Industrial Classification
SIP State Implementation Plan
S02 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
.tune 6, 2013
Dr.David M.Peele,Ph.D.
President
Avoca Incorporated j
P.O. Box 129
Merry Hill, North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T40
Facility ID: 0800044
Avoca Incorporated
Merry Hill,Bertie County, North Carolina
Fee Class: Title V
Dear Dr. Peele:
In accordance with your completed Air Quality Permit Application for a significant modification to
your Title V permit under 15A NCAC 02D .0516 received April 12, 2013, we are forwarding herewith Air
Quality Permit No. 01819T40 to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, North Carolina,
authorizing the construction and operation, of the emission source(s) and associated air pollution control
device(s) specified herein. Additionally, any emissions activities determined from your Air Quality Permit
Application as being insignificant per 15A North Carolina Administrative Code 2Q.0503(8) have been listed
for informational purposes as an "ATTACHMENT." Please note the requirements for the annual compliance
certification are contained in General Condition P in Section 3. The current owner is responsible for
submitting a compliance certification for the entire year regardless of who owned the facility during the year.
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q .0504 for
the SFr operations on or before 12 months after commencing operation.
As the designated responsible official it is your responsibility to review, understand, and abide by all of
the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition of
the attached permit reviews, understands, and abides by the condition(s) of the attached permit that are
applicable to that particular emission source.
i
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit,
identifying the specific issues to be contested. This hearing request must be in the form of a written petition,
conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division of
Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form
Permitting Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
217 West Jones Street,Raleigh,North Carolina 27603
Phone:919-707-84051 Fax:919.715.0717
Internet:www.neair,ora
An Equal Opportunity 4 Alfirmative Action Employer—Made in part by Recycled Paper
Mr.David M.Peele,Ph.D.
June 6,2013
Page 2
for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative
Hearings. Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing.
Unless a request for a hearing is made pursuant to NCGS 15013-23, this Air Quality Permit shall be final and
binding 30 days after issuance.
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
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 this Air Quality Permit will
become final and binding regardless of a request for informal modification unless a request for a hearing is
also made under NCGS 15013-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of GS 143-215-108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure to
receive an Air Quality Permit or written approval prior to commencing construction is a violation of GS
143-215.108A and may subject the Permittee to civil or criminal penalties as described in GS 143-
215.114A and 143-215.114B.
This Air Quality Permit shall be effective from June 6, 2013 until July 31, 2015, is nontransferable to
future owners and operators, and shall be subject to nditions and limitations as specified therein.
Should you have any questions conc5ald
lease c ntact Kevin Godwin at(919)707-8480.
yo s,
. van der Vaart, Ph.D., P.E., J.D.
Chief
Enclosure
c: Rob Fisher, Supervisor, Washington Regional Office
Heather Ceron,EPA Region 4
Central Files
I
Insignificant Activities under 15A NCAC 2Q.0503(S)
Emission Control Device Control Device
Source ID No. Emission Source Description ID No. Description
IWWTP-ET1 Wastewater treatment plant equalization tank NIA NIA
No. 1 65,500 anon capacity)
1WWTP-ET2 Wastewater treatment plant equalization tank NIA NIA
No. 2(65,500 gallon capacity)
l W WTP-AT2 Wastewater treatment plant aeration tank No.2 NIA NIA
(63,500 gallon capacity)
Wastewater treatment plant aeration tank No.3
IWWTP-AT3 (63,500 gallon capacity)
NIA NIA
IWWTP-CLR Wastewater treatment plant clarifier(1,310 NIA NIA
gallon capacity)
ITK9238 No. 2 fuel ail storage tank(50,000 gallon NIA NIA
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon NIA NIA
capacity)
TfK102 No.2 fuel oil storage tank(495 gallon NIA NIA
capacity)
1TKI03 No.
c fiicl oil storage tank(495 gallon NIA NIA
capa
ITKFP No.2 fuel oil storage tank(270 gallon NIA NIA
capacity)
One water spray fume
CD-Z-9215 scrubber(0.5 gallons
per minute minimum
water injection rate)
IECS ECS process: batch preparation of venting to
ethylenediamine/copper sulfate solution CD-Z-9216
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable
requirement or that the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement.
2. When applicable, einissions from stationary source activities identified above shall be included in
determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100
"Control of Toxic Air Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and N ACT ZZZZ see the NC DAQ
website: http://daq.state.nc.us/toxics/areasources/.
The following table provides a summary of the changes in Permit No.01 S 19T40.
Condition .
FGlo
No. Description of Change(s)
Global Removed reference to Iime injection for bagfilter(ID No. CD-BB1BH)
Table of
4 Emission Updated SFG ID numbers per Table 2.1 of the application.
Sources
25 2.2 A Removed reference to state-only toxic air pollutants(TAP).
Table
Old page 2.2 A 2 Removed TAP condition pertaining to 15A NCAC 02D .1100.
26
Old page 2.2 A.4. Removed condition pertaining to 15A NCAC 02Q .0705 and .0711.
26
New page 2.2 A 3 Included condition requiring a TAP evaluation for increases from non-
26 NESHAP sources.
43 2.2 C. Updated SFG ID numbers per Table 2.1 of the application.
50 2.2 C.2. Included PSD avoidance condition limiting VOC emissions from SFG
operations to 95.29 tons per 12 month rolling period.
50 2.2 C.3. Included condition for MON Group 1 batch process vent avoidance.
I
I
i
State of North Carolina, A14 • •
Department of Environment,
and Natural Resources NCDENR
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T40 01819T39 June 6, 2013 July 31, 2015
Until such time as this permit expires or is modified or revoked, the below named Permittee is authorized to
construct and operate the emission source(s) and associated air pollution control device(s) specified herein, in
accordance with the terms, conditions, and limitations within this permit. This permit is issued under the
provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and Title 15A North
Carolina Administrative Codes(15A NCAC),Subchapters 2D and 2Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission
source(s) or air pollution control device(s) without having first submitted a complete Air Quality Permit
Application to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Avoca, Inc.
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County,State, Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.O.Box 129
City, State, Zip: Merry Hill,NC 27957
Application Number: 0800044.13A
Complete Application Date: April 12,2013
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington,NC 27889
CIBB ;ority
ed this the 6`h ay of June, 2013.
va rVaart, Ph.D., P.E., J.D., Chief, Air Permits Section
of the Environmental Management
I
Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing,monitoring, recordkeeping, and reporting
requirements)
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring, recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACIIMENTS
ATTACHMENT 1 List of Acronyms
I
i
Permit 01819T40
Page 3
SECTION 1 - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances:
Emisslon Source Control Device Control Device
ID No. Emission Source Description ID No. Description
Rotocel Operations
CD-31209 One chilled water
condenser venting to
ES-1 00l-2-1-P l
PSD Rotocel extractor,desolventizer,and CD-1001-2-S-1 One packed tower
CAM solvent separation/recovery scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
CD-1001-2-C-1 One chilled water
condenser venting to
ES-1001-2-1-1`2
PSD Two solvent recycle process tanks CD-1001-2-S-1 ' One packed tower
CAM scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-2-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-2-1-
WW Rotocel Operations wastewater stream NA NA
PSD
MACT FFFF
Recovery Operations j
CD-1001-1-3 One chilled water
condenser venting to
ES-1001-1-1-P1
PSD CD-1001-2-S-1 ' One packed tower
CAM Arcon process tank M-1 scrubber(8 gallons per
MACT FFFF minute minimum
mineral oil injection
rate)
ES-1001-1-1-P2 CD-1001-1-TSB One chilled water
PSD Stripper T-5 and receiver M-21 condenser venting to
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
ES-1001-1-1-P scrubber(8 gallons per3 Seven process tanks of various capacities minute minimum
PSD and one fixed roof methanol storage tank
MACT FFFF (7,050 gallon capacity) mineral oil injection
rate)
Permit 01819T40
Page 4
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Descri tion
ES-1001-1-1-F
PSD Process equipment leaks NA NA
MACT FFFF
ES-1001-1-1-
WW Recovery Operations wastewater stream NA NA
PSD
MACT FFFF
Concrete Operations
ES-1001-1-2-P One chilled water
PSD Six process tanks of various capacities CD-1001-1-2 condenser
MACT FFFF
HB-1 One stearn-heated hot box NA NA
MACT FFFF
14B-2 One steam-heated hot box NA NA
MACT FFFF
i
HB-3 One steam-heated hot box NA NA
MACT FFFF
HB-4 One steam-heated hot box NA NA
MACT FFFF
ES-1001-1-2-F process equipment leaks NA NA
MACT FFFF
ES-1001-1-2-
W W Concrete Operations wastewater stream NA NA
MACT FFFF
Sclareol Recrystallization (SFG) Operations"
T-3001 One hexane storage tank(6,700 gallon
NA NA
MACT FFFF capacity)T-3002 through Four process tanks(2,500 gallons capacity NA NA
MACT FFFF each)
I
ES-1003-10-F
MACT FFFF Process equipment leaks NA NA
C-3001 One centrifuge NA NA
MACT FFFF
R-3001 One reactor equipped with a chilled water
MACT FFFF process condenser(EX-3001)
R-3002 One reactor equipped with a chilled water CD-3001 One chilled water
MACT FrrF process condenser(ES-3003) condenser
D-3001
MACT FFFF One steam-heated dryer
E ACT. FFF
MACT FFFF SFG Process wastewater stream NA NA
I
Biological Conversion Equipment for Purification of Sclareolide
ES-1001-1-3-P Twelve process tanks of various capacities NA NA
MACT FFFF
Permit 01819T40
Page 5
Emission Source Control Device Control Device
ID No. Emission Source Description ID No. Description___
G-17 One centrifuge NA NA
MACT FFFF
ES-1001-1-3-F process equipment leaks NA NA
MACT FFFF
D-1202
MACT FFFF One steam-heated dryer NA NA
A-2 One distillation column(6 gallons per NA NA
MACT FFFF minute noininal process rate
ES-1001-1-3- Biological conversion equipment for
WW purification of sclareolide wastewater NA NA
MACT FFFF stream
Sclareolide(SDF) Operations
I
ES-1001-1-4-P
MACT I'I'FI' Four process tanks of various capacities NA NA
FFFF
M-20 One acetic acid storage tank(10,135 gallon NA NA
MACT FFFF capacity)
ES-1001-1-4-F process equipment leaks NA NA
MACT FFFF
M-10
MACT FFFF One batch reactor
I
M-10A One venturi-type wet
MACT FFFF One batch reactor CD-M-34 scrubber(10 gallons
D-1231A per minute minimum
MACT FFFF One batch reactor liquid injection rate)
D-1231B One batch reactor
MACT FFFF
ES-1001-1-4-
WW SDE Operations wastewater stream NA NA
MACT FFFF
Plant Nutrient Extraction (PNE) Operations
EX2203 One chilled water
condenser venting to
CD-Z-9215 2 One water-spray fume
scrubber(0.5 gallons
D31214 per minute minimum
MACT FFFF One product extract reactor water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate
Permit 01819T40
Page 6
Emission Source Control Device Control Device
ID No. Emission Source Descriptiozi . ID No. Description
EX2205 One chilled water
condenser venting to
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons
D31211 One waste solids separator vessel (1,333 per minute minimum
MALT FFFF gallon capacity)
water injection rate)
venting to
CD-Z-9216 2
One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
ES-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
ES-1 003-2-1-
WW PNE process wastewater stream NA NA
MACT FFFF
CD-Z-9215 2 One water spray fume
ES-1003-2-1-P scrubber(0.5 gallons
MACT FFFF Seven process tanks of various capacities
per minute minimum
water injection rate)
venting to �
CD-Z-92]6 2
C-31203 One centrifuge One water spray fume
MACT FFFF scrubber(0.5 gallons
per minute minimum
water injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
D-2202 CD-Z-9215 One water spray fume
MACT FFFF One reactor scrubber(0.5 gallons
D-1215 One reactor per minute minimum
MACT FFFF water injection rate)
D-1218 One reactor venting to
MACT FFFF CD-Z-9216
One water spray fume
D-1201 scrubber(0.5 gallons
One steam-heated dryer
MACT FFFF per minute minimum
water injection rate)
ES-1003-2-2-F Process equipment leaks NA NA
MACT FFFF
ES-1003-2-2-
WW EVG Operation wastewater stream NA NA
MACT FFFF
Botanical Extraction Operations
Permit 01819T40
Page 7
Emission Source Emission Source Descri tion. Control Device Control Device
ID No. p ID No. Description
CD-1001-11- One chilled water
Immersion extractor Z-1001, EX1002 condenser venting to
ES-i001-11-P desolventizer Z-1002,
PSD day tank 90024(6,000 gallon capacity), One cryogenic
CAM first-stage evaporator EX-1012, CD-1001-1 l- (nitrogen)condenser
MACT FFFF second-stage evaporator EX-1013, EX1003 system (40 °F
distillation column EX-90008,and maximum 24-hour j
nine process tanks of various capacities average outlet
tem erature)
ES-1001-11-F
PSD Process equipment leaks NA NA
MACT FFFF
One plant material grinder(1,011 pounds One bagfi[ter(244
MHZ•-1002 per hour nominal feed rate) CD-1003-4-1 square feet of filter
area)
ES-1001-11-WW Botanical extraction operation wastewater
PSD
MACT FFFF Stream NA NA
Biomass Extraction Operations
One cartridge filter
PEA-D1004-1 Biomass extraction debagging CD-1004-1-FF1 (6.7:1 maximum air-to-
cloth ratio)
ES-1004-2-F Process equipment leaks NA NA
PSD
ES-1004-2-WW Biomass extraction operation wastewater NA NA
PSD stream
Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
desolventizer Z-41002, condenser venting to
day tank 490025 (9,953 gallon capacity),
ES-1004-2-P isohexane storage tank 490024 (13,536 CD-1004-2EX1003 One cryogenic
PSD gallon capacity), (nitrogen)condenser
CAM first stage evaporator EX-41012, system(40°F
second stage evaporator EX-41013, maximum 24-hour
distillation column EX-490008, and average outlet
nine process tanks of various capacities temperature)
One bagfilter(254
ES-1004-2Silo Biomass silo loadou( CD-1004-2-FF2 square feet of filter
area)
Miscellaneous Operations
H-101 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- Btu per hour maximum heat input ra(e) NA NA
by-case MACT
H-102 One No. 2 fuel oil-fired boiler(20.3 million
2D .1109 case- Btu per horn•maximum heat input rate) NA NA
by-case MACT
Permit 01819T40
Page 8
Emission Source Control Device Control Device
l TID No. Emission Source Description ED No. Description
H-103 One No. 2 fuel oil-fired boiler(25.2 million
2D .1109 case- NA NA
by-ease MACT Btu per hour maximum heat input rate)
ES-BB 1 and ES- One simple cyclone
BB2* (114 inches in
NSPS—Subpart Two biomass/bio-based solids-fired boilers diameter) in series with
Dc (18.6 million Btu per hour maximum heat CD-BB I and CD- one bagfilter(8,900
MACT— input rate) BB1BH Square feet of filter
Subpart area)
DDDDD
ES-RD* One No. 2 fuel oil-fired rotary dryer(6.0
million Btu per hour maximum heat input NIA NIA
rate)
ES-PkGenl One No. 2 fuel oil-fired limited use One catalytic oxidizer
MACT ZZZZ emergency generator(2,935 kilowatt CD-CatOX1 (695-°F minimum inlet
maximum rated power output) temperature)
WWW WTP-AT1
Wastewater treatment plant aeration tankPSD NA NA
MACT FFFF No. l
E101 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (587 horsepower maximum rated power NIA NIA
output)
E102 One No.2 fuel oil-fined emergency generator
MACT ZZZZ (760 horsepower maximum rated power NIA NIA
output)
E103 One No.2 fuel oil-fired emergency generator
MACT ZZZZ (603 horsepower maximum rated power NIA NIA
output) j
FP One No.2 fuel oil-fired emergency fire
MACT ZZZZ water pump(285 horsepower maximum NIA NIA
rated power output)
The Permittee is permitted to operate sources ES-1001-2-1-P2, ES-1001-1-1-P1, ES-1001-1-1-P2, and ES-1001-1-1-P3
without the shnultaneous operation of scrubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 B.1.d and e,below.
2 Operation of water spray fiime scrubber CD-Z-9215 and water spray Mme scrubber CD-Z-9216 shall only be required for
control of emissions from the PNE Operations if that source is utilizing ethyl acetate as a solvent.
These emission sources and control devices(ID Nos. ES-BB1, ES-BB2,ES-RD, CD-BB IC and CD-BB IBH) are listed as a
15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality Permit Application on or before 12
months after commencing operation in accordance with General Condition NN.1. The permit shield described in General
Condition R does not apply and compliance certification as described in General Condition P is not required.
**The emission sources in the SFG operation are listed as a 15A NCAC 2Q .0501(c)(2)modification. The Permittee shall
file a Title V Air Quality Permit Application on or before 12 months after commencing operation in accordance with
General Condition NN.I. The permit shield described in General Condition R does not apply and compliance
certification as described in General Condition P is not required.
Permit 01819T40
Page 9
SECTION 2 — SPECIFIC LIITATIONS AND CONDITIONS
2.1 - Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Three No.2 fuel oil-fired boilers (ID Nos.H-101,H-102, and H-103)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regu]Htion
Particulate inatter 0.37 pounds per million Btu heat input 15A NCAC 2D .0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 2D .0521(d)
Visible emissions
40 percent opacity: H-101 and H-102 15A NCAC 2D .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 2D .1109
Control Technology [1120)Case-by-Case MACT]
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 21)
.0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.1 A.La, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0503.
Monitoring/Recordkeeping/ReportinE [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for particulate emissions from the firing of No.2
fuel oil in boilers 11-101,11-102, or H-103.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be
included when determining compliance with this standard. [15A NCAC 21) .0516]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 213 .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.1 A.2.a, above, the Permittee shall be deemed in noncompliance with 15A NCAC 21)
.0516.
Permit 01819T40
Page 10
Monitoring/Recordlceeping/Repor tin g[15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in boilers H-101, H-102,or H-103.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers H-101 and H-102 shall not be more than 40 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 40 percent not
more than once in any hour and not more than four times in any 24-hour period. hi no event shall the
six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler H-103 shall not be more than 20 percent opacity when averaged over a
six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q,0508(f)]
c. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 A.3.a or b, above, as applicable, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0521.
Moeiitoriu IRecordlcee in IRe ortin [15A NCAC 2Q .0508(f)]
d. No monitoring, record keeping, or reporting is required for visible emissions from the firing of No. 2
firel oil in boilers H-1 01,H-102, or H-103.
I
4. 15A NCAC 2D .1109: 112(J) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 1120)- Case-by-Case MACT for Boilers &Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers H-101, H-102, and
H-103. The initial compliance date for this work practice standard and the associated monitoring,
recordkeeping, and reporting requirements is August 17 2013. These conditions need not be included
on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance, the Permittee shall perforin an annual boiler inspection and maintenance on
boilers as recommended by the manufacturer, or as a minimum, the inspection and maintenance
requirement shall include the following:
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Permittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement. The Permittee shall be deemed in noncompliance with 15A NCAC
2D .1109 if the affected boilers are not inspected and maintained as required above.
Recor[lkee in [15A NCAC 2Q .0508(f)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a log
(written or electronic format) on-site and made available to an authorized representative upon request.
The log shall record the following:
i. The date and time of each recorded action;
Permit 01819T40
Page I I
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Reyortine[I5A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-P1cGen1) and one associated catalytic
oxidizer(ID No. CD-CatOX1)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regi.ilation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 213 .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
15A NCAC 21) .1111
Hazardous Air Pollutants Maximum Achievable Control Technology [40 CFR Part 63, Subpart
zzzz]
Nitrogen Oxides(NOx) Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator ES-PkGen1 shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard. [15A NCAC 21)
.0516]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.l.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 21)
.0516.
_Monitoring/Recordkeeping/Reportin [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of
No. 2 fuel oil in limited use generator ES-PkGenl.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator ES-PkGenl shall not be more than 20 percent opacity
when averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period. In no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 21) .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 21)
Permit 01 819T40
Page 12
.0521.
Monitorin IRecordkee iir /Re ortiu [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of No. 2
fuel oil in limited use generator ES-PkGenl.
3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
[40 CFR Part 63,Subpart ZZZZ]
Applicability [40 CFR§63.6580 and §63.65851
a. Limited use generator ES-PkGenl shall comply with all applicable requirements of 15A NCAC 2D
1111 "Maximum Achievable Control Technology" pursuant to 40 CFR Part 63, Subpart ZZZZ
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines(RICE)"including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR§63.6590(b)(1)(ii)and §63.66751
b. In accordance with 40 CFR §63.6590(a)(2)(i) this source is considered an existing Limited Use source
for purposes of Subpart ZZZZ. To qualify as such,the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
MonitorinE[15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations, on limited use generator ES-PkGenl. The Permittee shall conduct monthly
monitoring of hours of operation for this source as measured by the non-resettable hour meter. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring is not
performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGcnl, as measured by the non-resettable hour meter, in a log (written or electronic format) on-site
and made available to an authorized representative upon request.
i
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring, recordkeeping, or reporting is required for hazardous air pollutant emissions from
limited use generator ES-PkGenl.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator ES-PkGenl shall discharge into the atmosphere less than 40 tons of nitrogen
oxides per consecutive 12-month period [15A NCAC 2D .05301.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 B.4.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Operational Limitation [15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 B.4.a, above, the operation of limited
Permit 01819T40
Page 13
use generator ES-PkGenl shall not exceed 1,500 horns in a consecutive 12-month period. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitorina/Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not
conducted, these records are not maintained, or if the rolling total hours of operation for the limited use
generator exceed 1,500 hours per consecutive 12-month period.
Renortin [15A NCAC 2Q .0508(f)]
e. The Perinittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. The report must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months;
and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period
ending during the reporting period.
C. Rotocel Operations, including:
• Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No. CD-1001-2-S-1);
• Two solvent recycle process tanks (ID No. ES-1001-2-1-T) and one associated chilled water j
condenser (ID No. CD-1001-2-C-1) venting to one packed tower scrubber (ID No. CD-1001-2-
S-1). **
• Process equipment leaks (ID No.ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser
(ID No. CD-1001-1-3) venting to one packed tower scrubber(ID No. CD-1001-2-S-1); **
• One chilled water condenser (ID No. CD-1001-1-T5B) venting to packed tower scrubber (ID
No. CD-1001-2-S-1)controlling emissions from: **
o Stripper T-5 and receiver M-21 (ID No.ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(ID No.ES-1001-1-1-P3);
• Process equipment leaks (ID No.ES-1001-1-1-h); and
• Recovery Operations wastewater stream (ID No.ES-1001-1-1-WW)
** The Permittee may operate sources ES-1001-2-1-P1 and ES-1001-1-1-P1,-P2, and -P3 without the simultaneous
operation of scrubber CD-1001-2-S-1 under the conditions cited in Sections 2.2 B.Ld and e,below.
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Staudards Applicable Regulation
Volatile organic Best Available Control Technology 15A NCAC 2D .0530
compounds See Sections 2.2 B.1 and 2.2 B.2
Permit 0 t 819T40
Page 14
Regulated Pollutant Limits/Standards Applicable Regulation
Compliance Assurance Monitoring 15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Maximum Achievable Control Technology 15A NCAC 2D .I I I I
Hazardous Air Pollutants See Section 2.2 C.1 [40 CFR Part 63, Subpart
FFFF]
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3
Toxic Air PollutantsState-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 AA 15A NCAC 2D .1100
i
1. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CFR Part
64 and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic
compound (VOC) emission litnits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this
permit.
Control RepuiremeutslParameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the rtocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (ID No. ES-1001-2-1-T), accon process tank M-1 (fD
No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight process and
storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower scrubber(1D
No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.l.d and e, below. In addition, the
Permittee shall maintain a daily average mineral oil temperature at the inlet of scrubber CD-1001-2-S-1
of less than or equal to 100 degrees Fahrenheit (100 °F) whenever the associated sources are
operational.
Monitoring[15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.l.c.i
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 C.l.cJ through iii, below, are not
performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral oil packed tower scrubber
CD-1001-2-S-1 at least once each day that the sources listed in Section 2.1 C.l.b,above,operate;
ii. The Permittee shall inspect, maintain,and operate mineral oil packed tower scrubber CD-1001-2-S-
1 in accordance with Section 2.2 B.1 j, below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gaugc associated with
mineral oil packed tower scrubber CD-1001-2-S-1 in accordance with Section 2.2 13.11, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if mineral oil packed tower scrubber CD-1001-2-S-1 operates
under conditions qualifying as an excursion for more than 5 percent of the operational time of the
sources listed in Section 2.1 C.1.b,above, during a consecutive 6-month period,then the Permittee shall
develop a Quality Improvement Plan(QIP) in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed
Pennit 01819T40
Page 15
tower scrubber- CD-1001-2-S-1 with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.l.b, above, while the associated emission sources are operating, except as allowed
pursuant to Sections 2.2 B.l.d and e, below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request.The log shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
inlet mineral oil temperature of packed tower scrubber CD-1001-2-5-1;
iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber CD-
1001-2-5-1 or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
ReRe�or_ting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must
be clearly identified.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator
EX-1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process
tanks of various capacities (ID No. ES-1001-11-1-P) and one associated chilled water
condenser(ID No. CD-1001-11-EX1002) venting to one cryogenic(nitrogen) condenser system
(ID No. CD-1001-11-EX1003);
• Plant Material Grinder (ID No. MHZ-1002) and one associated bagfilter (ID No.CD-1003-4-
1);
• Process equipment leaks (ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream (ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debagging (ID No. ES-1004-1) and one associated cartridge filter (ID No.
CD-1004-1-FF1);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, isohexane storage
tank 490024, first-stage evaporator EX-41012,second stage evaporator EX-41013,distillation
column EX-490008 and nine process tanks of various capacities (ID No.ES-1004-2-P) and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen) condenser system (ID No. CD-1004-2EX1003);
• Process equipment leaks (ID No. ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
• Biomass extraction operations wastewater stream (ID No.ES-1003-10-WW); and
• Biomass silo loadout (ID No. ES-1004-2Silo) and one associated bagfilter(ID No. CD-1004-2-
FF2)
The following table provides a summary of limits and standards for the emission source(s)described above:
Permit 01819T40
Page 16
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder, biomass extraction
debagging,and biomass silo loadout:
Particulate matter E=4.1Op0.61 15A NCAC 2D .0515
Where:E=allowable emission rate in pounds per
hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0 53 0
See Sections 2.2 B.I and 2.2 B.2
Volatile organic Comp]lance Assurance Monitoring 15A NCAC 2D .0614
compounds
Work practice standards
See Section 2.2 A.1 15A NCAC 2D A958
Odorous emissions state-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
15A NCAC 2D .I I I I
Hazardous Air Pollutants Maximum Achievable Control Technology 40 CFR Part 63, Subpart
See Section 2.2 C.1 (Botanical extraction only) FFFF
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .I 100
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (1D No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
i
E=4.10xPa.61
Where: E=allowable emission rate in pounds per hour; and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(t)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition 11 found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.La, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.05I5.
Monitoring/Recordkee ing [15A NCAC 2Q .0508(t)]
c. Particulate matter emissions from the plant material grinder, the biomass extraction debagging
operation, and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a
cartridge filter (ID No. CD-1004-1-FFI), and a bagfilter (ID No. CD-1004-2-FF2), respectively. To
assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
Permit 01819T40
Page 17
and maintenance requirement shall include the following:
i. A monthly visual inspection of the system duchvork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and maintained.
d. The results of inspections and maintenance shall be maintained in a log (written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any maintenance performed on the cartridge filter and bagfilters; and
iv. Variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not
maintained.
RenortinE[15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December and July 30 of each calendar year for the preceding six-month period between
January and June. All instances of deviations from the requirements of this permit must be clearly
identified.
2. 1.5A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the botanical extraction operations and the biomass extraction operations shall
not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [15A NCAC
2D .0521(d)]
i
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. If the results of this test are above the limit
given in Section 2.1 D.2.a, above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0521.
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources
for any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly
observation must be made while the associated source is operating.If a source does not operate during a
monthly period, then a record documenting such non-operational status will satisfy this monitoring
requirement for that source. If visible emissions from a source are observed to be above normal, the
Permittee shall either:
i. Take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2601 (Method 9)for 12 minutes is below the limit given in Section 2.1 D.2.a,
Permit 01819T40
Page 18
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordlceeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 26 .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
I
Applicability[15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the immersion extractor Z-1001, desolventizer Z-1002, day tank 90024, first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks (ID No,
ES-1001-11-1-P) and the immersion extractor Z-4100I, desolventizer Z-41002, day tank 490025,
isohexane storage tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013,
distillation column EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P),the
Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this source
complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D3 of this permit.
Control Reg uirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P)
shall be controlled by the associated cryogenic condenser system(ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system(ID No. CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40
degrees Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003
whenever the associated sources are operational; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F
for cryogenic condenser system CD-1004-2EX1003 whenever the associated sources are
operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.c.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D.3.c.i through iv, below, are• not
performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1001-11-
EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
Permit 01819T40
Page 19
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above,operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system CD-1004-
2EX1003 at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour, when the associated sources listed in Section 2.1 D.3.b,
above, operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems CD-1001-11-
EX1003 and CD-1004-2EX1003 in accordance with Section 2.2 B.l.h, below; and
iv. The Permittee shall install, maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems CD-1001-11-EX1003 and CD-1004-2EX1003 in accordance with
Section 2.2 B.l.i, below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system CD-1001-11-EX1003 or CD-
1004-2EX1003 operate under conditions qualifying as an excursion for more than 5 percent of the
operational time of their associated sources listed in Section 2.1 D.3.b, above, during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of cryogenic condenser
system CD-1001-11-EX1003 or CD-1004-2EX1003 with a 12-hour average outlet temperature that
exceeds the associated limit cited in Sections 2.1 D.3.1b.i and ii, above, while the associated emission
sources are operating.
_Recordkeeping [15A NCAC 2Q .0508(o]
e. The results of monitoring, inspections,maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a log (written or electronic format) on-site and made
available to an authorized representative upon request. The log shall record the following:
L The date and time of each recorded action;
ii. The results of the monitoring, noting any excursions along with any actions taken to correct the
outlet temperature of cryogenic condenser system CD-1001-11-EX 1003 or CD-1 004-2EX1003;
iii. The results of any inspections or maintenance performed on cryogenic condenser system CD-1001-
11-EX1003,cryogenic condenser system CD-1004-2EX1003, or the associated temperature gauges;
and
iv. Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reportinsz [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must
be clearly identified.
Permit 01819T40
Page 20
E. Two biomass boilers (ID Nos. ES-BRI and ES-BB2) controlled by a cyclone (ID No. CD-131131C)
in series with a bagfilter (ID No. CD-1113113H) and associated No. 2 fuel oil-fired rotary dryer
(ID No.ES-RD)
The following table provides a summary of lunits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Boners(ID Nos. ES-BBI an(!BB2):
Particulate 15A NCAC 02D .0503
matter 0.33 pounds per million Btu heat input
Rotary dryer(ID No.ES-RD):
Particulate 067 15A NCAC 02D .0515
matter E=4.10(P)
Sulfur 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
dioxide
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 02D .0521
emissions period
NIA Initial notification requirements, 15A NCAC 02D .0524
Notification of boiler size and fbel combusted,and NSPS—Subpart Dc
Record and maintain amount of each fuel combusted
during each calendar month.
,HCI, Per Subpart 15ANCAC 02Q.1111
PM
PM,H MACT Subpart DDDDD
DioxinslFura
ns
1. Testin [15A NCAC 02Q .0508(f)
Under the provisions of North Carolina General Statute 143-215.108, in order to verify emission factors used
for calculating CO (0.54 lb/MMBtu)and NOx(0.22 Ib/MNIBtu)emissions the Permittee shall perform a stack
test on one of the boilers for CO and NOx within 60 days after start-up. The testing shall be conducted in
accordance with a testing protocol (using testing protocol submittal form) approved by the Division of Air
Quality. Details of emission testing requirements can be found in Section 3—General Condition JJ. If testing
shows emissions greater than the emission factors used, the Permittee must notify the Regional Office
Supervisor, in writing,no later than 60 days following the stack test date.
2. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos.ES-BBI and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
heat input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A. 1. a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Perrnit 01819T40
Page 21
Monitoring [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the boi ler shall be controlled by a cyclone in series with a bagfilter.
To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if
there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. monthly external inspection of the ductwork,cyclone, and bagfilter noting the structural
integrity; and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone, bagfilter,
and ductwork is not inspected and maintained.
Recordlicepin [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a log(written or electronic format)
on-site and made available to an authorized representative upon request. The log shall record the
following:
i. the date and time of each recorded action;
ii.the results of each inspection;
iii. a report of any maintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made. j
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall submit a report of any
maintenance performed on the cyclone and bagfilter.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the rotary dryer(ID No. ES-RD)shall not exceed an allowable emission rate
as calculated by the following equation: [15A NCAC 2D .0515(a)]
E=4.10 x P 0.67 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing[15A NCAC 2Q .0508(1)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 E.2.a. above,the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0515.
MonitoringlRccordkeepingy[15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour,as specified by the
formulas contained above(or the formulas contained in 15A NCAC 2D.0515)can be derived,and shall make
these records available to a DAQ authorized representative upon request.The Permittee shall be deemed in
noncompliance with 15A NCAC 213.0515 if the production records are not maintained or the types of materials
and finishes are not monitored.
Permit 01819T40
Page 22
4. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes,ores,and other substances shall be
included when determining compliance with this standard. [15A NCAC 2D .0516]
Testing [I5A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ
found in Section 3. If the results of this test are above the limit given in Section 2.1 A.l.a. above,the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
5. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(ID Nos.ES-BB1, ES-BB2,and ES-RD)shall not
be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [I5A
NCAC 2D .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E. 3. a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 21) .0521.
For boilers (ID Nos. ES-BBI and ES-BB2):
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a day the Permittee shall observe the emission points of the boilers (ID
Nos. ES-BB 1 and ES-BB2)for any visible emissions above normal. The daily observation must be
made for each day of the calendar year period to ensure compliance with this requirement.The
Permittee shall be allowed three(3)days of absent observations per semi-annual period.The Permittee
shall establish"normal"for the boilers in the first 30 days following the effective date of the permit. If
visible emissions from this source are observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 21) .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 E.3. a.
above.
If the above-normal emissions are not corrected per(i) above or if the demonstration in(ii)above
cannot be made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordlzeepin [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a log(written or electronic format)on-site and
made available to an authorized representative upon request. The log shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 21) .0521 if these records are not
maintained.
Permit 01819T40
Page 23
Renortin>x [1 SA NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer (ID No. ES-RD):
Monitorinrr/Recordlceenine/Reporting [1 SA NCAC 2Q .0508(f)]
f. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel
oil in the rotary dryer(11)No. ES-RD).
6. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
fecordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 21) .0524 "New Source Performance Standards (NSPS) as promulgated in 40
CFR Part 60 Subpart Dc, including Subpart A "General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUIREMENTS-In addition to any other required by 40 CFR 3 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 3 60.7)or reconstruction(40 CFR:) 60.15)of an affected facility is
commenced,postmarked no later than 30 days after such date,and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Recordkeeping [15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR ❑ 60.48c or recordkeeping requirements of
the EPA, the Permittee shall record and maintain records of the amounts of each fuel fired during each
day. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these records are
not maintained.
7. 15A NCAC 02D .1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers(11)Nos. ES-BBl and ES-13132)are subject to 40 CFR Part 63, Subpart DDDDD.
F. Three emergency generators and fire water pump (ID Nos. E101, E102, E103, and FP)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible 20 percent opacity 15A NCAC 02D.0521
emissions
NIA NIA 15A NCAC 021).1111--
Subpart ZZZZ
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Dtu heat input. Sulfur dioxide
formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining
Permit 01819T40
Page 24
compliance with this standard. [15A NCAC 2D .0516]
Testlrrg[15A NCAC 2Q.0508(0]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. if the results of this test are above the limit given in Section 2.1 A.La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 213.0516.
c. No monitoring/recordkeeping/ is required for sulfur dioxide emissions from the firing of No. 2 fuel oil in these
sources.
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four tines in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
[15A NCAC 21).0521 (d)]
Testing[15A NCAC 2Q .0508(o]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 F. 2. a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D.0521.
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in these
sources.
3. 15A NCAC 2D.1111 [40 CFR Part 63 Subpart ZZZZ]:
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Standard 15A NCAC 21) .I111,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,
Subpart ZZZZ,"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines",by December 13,2004.
Mon itorina/Recordkeening/Reportina[l5A NCAC 2Q.0508(f)]
b. No monitoring/recordkeeping/reporting requirements.
i
I
Permit 01819T40
Page 25
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources fall permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101, H-102, and H-1031
The following table provides a summary of limits and standards for the emission source(s)describe above:
i
i
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 213 .0958
Odorous emissions state-Enforceable Only 15A NCAC 2D .1806
Odorous emissions must be controlled
L 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D .0958, for all sources that use volatile organic compounds (VOC) as
solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that
mix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a
product of chemical reactions,the Permittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, when not
in use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety
procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile
organic compounds, j
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other
coating equipment into closable containers and close such containers immediately after each use, or
transfer such solvents to closed tanks, or to a treatment facility regulated under section 402 of the
Clean Water Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank
or a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 2D
.0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush pants 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 Ionger,
iv. Not fill cleaning machines above the fill Iine,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 2D .0958(d)]
MonitorinE [15A NCAC 2Q .0508(f)]
c. To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum,perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations. If the required inspections are not
conducted the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0958.
Permit 01819T40
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Recordkeeniug [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a log (written or electronic format) on-site and
made available to an authorized representative upon request. The log shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with
rule 15A NCAC 2D .0958.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 02D.1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NES14AP source, any increase in toxic air pollutants must be evaluated.
I
Permit 01819T40
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B. Three No.2 fuel oil-fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. W WTP-ATI)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
(VOC)
1. 15A NCAC 2D .0530: PREVENTION OF SIGNI[+ICANT DETERIORATION
a. The following Best Available Control Technology(BACT) limits shalt not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tons per Condenser CD-31209
desolventizer,and solvent VOC 10.8 pounds consecutive
separation/recovery per hour 12-month and packed tower
(ID No. ES-1001-2-1-P1) period
scrubber CD-1001-2-5-1
When Rotocel Operating: Condenser CD-1001-2-
0.94 pounds per hour and 4.11 C-1 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-S-1
period,combined total
i
Rotocel solvent recycle tanks When Rotocel is NOT Condenser CD-1001-2-
(ID No. E S-100 1-2-1-P2) VOC Operating and Recovery C-1
Process is processing
Concrete:
0.47 pounds per hour and 0.19
tons per consecutive 12-month
period, combined total
Rotocel equipment leaks VOC Leak detection and
(ID No. ES-100 1-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(ID No.ES-1001-2-1-WW) VOC wastewater treatment
tanks
Pennit 01819T40
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Emission Source Pollutant BACT Emission Limits Conh of Technology
When Rotocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-1 When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete:
8.76 pounds per hour and 0.63
tons per consecutive 12-month
period
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-S-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-1001-1-
receiver M-21 VOC Operating and Recovery T5B
(ID No. ES-1001-1-1-P2) Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC Fixed roofs
(ID No. ES-1001-1-1-P3)
Recovery equipment leaks VOC WAR
(ID No. ES-1001-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting wastewater treatment
(1D No. ES-1001-1-1-WW) tanks and biological
of methanol-wash
treatment
Botanical extraction
immersion extractor,
61.76 tons per
desolventizer, first and 14.1 pounds consecutive Condenser CD-1001-11-
second stage evaporators, VOC per hour 12-month EX1002 and condenser distillation column, day tank, period CD-1001-11-EX1003
and multiple process tanks
(ID No. ES-1001-11-P)
Botanical extraction
equipment leaks(ID No.ES- VOC MAR
1001-11-F)
(Fugitive)
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC wastewater treatment
ES-1001-11-WW) tanks
Permit 01819T40
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Emission Source Pollutant BACT Emission Limits Control Technology
Biomass extraction
immersion extractor,
desolventizer, day tank, 61.8 tons per
isohexane storage tank, first Condenser CD-1004-
and second stage VOCs 14.1 pounds consecutive per hour 12-month 2EX1002 and condenser
evaporators,distillation period CD-1004-2EX1003
column,and multiple process
tanks
(1D No.ES-1004-2-P)
Biomass extraction
equipment leaks(ID No. ES- VOCs LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs wastewater treatment
ES-1004-2•-WW) tanks
No.2 firel-oil fired boilers
(ID Nos.H-101,H-102,H- VOC 0.2 pounds per 1,000 gallons Combustion control
11 103)
Testing [I SA NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601
and General Condition JJ found in Section 3 of this permit. if the results of this test are above the limit
given in Section 2.2 B.La, above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.0530.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall only fill the Rotocel solvent recycle tanks (1D No. ES-1001-2-1-P2) from tanker
trucks when source ES-1001-2-1-P1 is operating.
d. The Permittee shall limit the operation of the rotocel solvent recycle tanks (1D No. ES-1001-2-1-P2),
recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and recovery stripper T-5 and receiver M-21 (1D
No. ES-1001-1-1-P2) while source ES-1001-2-1-P1 is not operating to no greater than 34 days in any
consecutive 12-month period.
e. The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-PI) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises)while source ES-1001-2-1-P1 is not operating to no greater than 6 days in
any consecutive 12-month period.
£ The Permittee shall implement the leak detection and repair (LDAR) program of 40 CFR Part 63,
Subpart UU, as per the requirements Section 2.2 B.2, below. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530, if the LDAR program requirements are not implemented.
g. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant (i.e. Wastewater Treatment Plant Aeration Tank No. 1; ID No. WWTP-
AT 1)for volatile organic compounds (VOC), when the wastewater stream consisting of methanol-wash
from the recovery operations(ID No. ES-1001-1-1-WW) is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VOC is not
determined every week or if the mass removal efficiency is less than 95%.
h. Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 13.1.a,
Pennit 01819T40
Page 30
above, shall be controlled by the associated condensers. To assure compliance, the Permittee shall
perform periodic inspections and maintenance as recommended by the equipment manufacturer. In
addition, the Permittee shall perform an annual inspection of each condenser system, including the
following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is udder positive gauge pressure, leakage of the
contaminated gas stream. In order to monitor leakage of the coolant, the condensate shall be
inspected for the presence of coolant; and
ii. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
i. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.l.a,above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The
temperatures output from the sensors shall be continuously monitored and hourly values used to
determine the 24-hour average temperature at the condenser outlets. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the outlet temperatures of the condensers are not
maintained below the limits in the table below; or the condensers are not equipped with sensors to
continuously measure the outlet temperatures; or if those sensors are not inspected and maintained.
Emission Source Condenser ID No. Rewired Outlet Temperature
Rotocel solvent recycle tanks
(ID No. ES-100 1-2-1-P2) CD-1001-2-C-1
45°F,24-hour average,when
Recovery arcon tank M-1 CD-1001-1-3 source ES-100 1-2-1-P 1 is not
(ID No. ES4001-1-I-P1) operating and the tanks are used
Recovery stripper T-5 and for concrete processing in the
receiver M-21 (ID No. ES-1001- CD-1001-1-T513 recovery operation
1-1-P2)
Botanical extraction operations CD-i001-11-EX 1003 -40°F,24-hour average
(11)No. ES-1001-11-P)
Biomass extraction operations CD-1004-2EX1003 -40°F, 24-hour average
(ID No. ES-1004-2-P)
J Volatile organic compound (VOC) emissions from the emission sources listed in Section 2.2 B.l.a,
above, shall also be controlled by the associated packed tower scrubber (ID No. CD-1001-2-S-1),
except as allowed pursuant to Sections 2.2 B.l.d and e, above. To assure compliance, the Permittee
shall perform periodic inspections and maintenance as recommended by the equipment manufacturer.
In addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system (if so
equipped), and perform maintenance and repair when necessary to assure proper operation of the
packed tower scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
Permit 01819T40
Page 31
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the packed tower
scrubber is not inspected and maintained.
k. The Permittee shall install, maintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor, and an emission stream inlet temperature sensor for packed tower
scrubber CD-1001-2-5-1 in accordance with manufacturer's recommendations. The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530 if the flow meter and temperature sensors are not
installed, maintained, and calibrated, or if, except as allowed pursuant to Sections 2.2 B.l.d and e,
above:
L The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
I The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeeping [15A NCAC 2Q .0508(f)]
1. The Permittee shall maintain the following records:
i. VOC emissions for each calendar month,and for the consecutive 12-month period ending with each
calendar month,from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2,and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2, and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the
recovery process is processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations(ID No.ES-I 004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through k, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall be updated at least
monthly and record the following:
(A)The date and time of each recorded action;
(B) The operational status of source ES-1001-2-1-P1 during the filling of the rotocel solvent
recycle tanks(ID No. ES-1001-2-1-P2) from tanker trucks;
(C) The actual hours of operation of the rotocel solvent recycle tanks (ID No. ES-1001-2-1-P2),
recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and recovery stripper T-5 and receiver M-
21 (ID No. ES-1001-1-1-P2),when source ES-1001-2-1-P1 is not operating;
(D)The actual hours of operation of recovery arcon tank M-1 (1D No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and
source ES-1001-2-1-P1 is not operating;
(E) The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
WWTP-ATI) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(F) The 24-hour average outlet temperature of the associated condenser(s) listed in Section 2.2
B.Li,above:
(1) When source ES-1001-2-1-P1 is not operating and the Concrete Operations tanks (1D No.
ES-1001-1-2-P)are used for concrete processing in the recovery operation;
(2) When the biomass extraction operations(ID No. ES-1004-2-P) is operating;and/or
(3) When the botanical extraction operations(ID No.ES-1001-2-1-P2) is operating.
(G)The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream
inlet temperature of scrubber CD-1001-2-S-I at least once each day that source ES-1001-2-1-P1
operates;
(H)The results of maintenance performed on the condensers and scrubber listed in Section 2.2
Permit 01819T40
Page 32
B.La, above, and the associated temperature sensors and flow rate gauges; and
(1) Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
m. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.l.a, above.
u. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January
and June. All instances of deviations from the requirements of this permit must be clearly identified. In
addition, the semiannual reports shall also contain the following:
L The monthly VOC emissions from each of the following sources for each of the previous 17
months; and
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-100 1-2-1-P2, ES-1001-I.1-P1,
ES-1001-1-1-P2,and ES-1001-1-1-P3)when source ES-1001-2-1-P1 is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-2-1-P2, ES-1001-1-1-P1,
ES-1001-1-1-P2, and ES-1001-1-1-P3) when source ES-1001-2-1-P1 is not operating and the
recovery process is processing concrete;
(C) Botanical extraction operations(ID No. ES-1001-11-P); and
(D)Biomass extraction operations(ID No. ES-1004-2-P).
ii. Tile cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.n.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D .0530: Prevention of Significant Deterioration]
Eguipment identification [I SA NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified. Identification of the equipment does not require
physical tagging of the equipment. For example,the equipment may be identified on a plant site plan, in
log entries, by designation of process unit or affected facility boundaries by some form of weatherproof
identification, or by other appropriate methods. In addition to the above, the following equipment shall
be specifically identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe manner to perform monitoring;
(Connectors creed not be individually identified if all connectors in a designated area or length of
pipe are identified as a group, and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rupture disk upstream of the pressure device;
iii. Valves, pumps, and connectors that are designated unsafe-to-monitor (i.e., Permittee has
determined that monitoring personnel would be exposed to an immediate danger as a consequence
of complying with the monitoring requirements); and
iv. Valves that are difficult-to-monitor (i.e., Permittee has determined that the valve cannot be
monitored without elevating the monitoring personnel more than seven feet above a support surface
or it is not accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-
to-monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
Permit 01819T40
Page 33
explanation why the equipment is unsafe or difficult-to-monitor. These records must be kept at the plant
and he available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times, but not more frequently than the periodic monitoring
schedule otherwise applicable, and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment
at least once per calendar year and repair of the equipment if a leak is detected.
c. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process
unit shutdown. The identity of connectors designated as unsafe-to-repair and an explanation why the
connector is unsafe-to-repair shall be recorded.
Instrument and sensoiy monitoring for leaks [I5A NCAC 2Q .0508(f)]
d. Instrument monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak
to the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60,appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2, paragraph(a)of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis. The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there
is no instrument commercially available that will meet the performance criteria specified above, the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid,calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures
specified in Method 21 of 40 CFR part 60, appendix A.
iv. Calibration gases shall be zero air (Iess than 10 parts per million of hydrocarbon in air); and the
gases shall be mixtures of methane in air at a concentration no more than 2,000 parts per million
greater than the leak definition concentration of the equipment monitored. If the monitoring
instrument's design allows for multiple calibration scales, then the lower scale shall be calibrated
with a calibration gas that is no higher than 2,000 parts per million above the concentration
specified as a leak, and the highest scale shall be calibrated with a calibration gas that is
approximately equal to 10,000 parts per million. A calibration gas other than methane in air may be
used if the instrument does not respond to methane or if the instrument does not meet the
performance criteria specified Method 21 of 40 CFR part 60, appendix A. In such cases, the
calibration gas may be a mixture of one or more of the compounds to be measured in air.
v. Monitoring shall be performed when the equipment is in VOC service.
g. The Permittee may elect to adjustor not to adjust the instrument readings for background.
i. If the Permittee elects not to adjust instrument readings for background, the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,
above. In such cases, all instrument readings shall be compared directly to the applicable leak
definition for the monitored equipment to determine whether there is a leak or to determine
compliance with operational standards for pressure relief devices.
ii. If the Permittee elects to adjust instrument readings for background,the Permittee shall
Pet-nit 01819T40
Page 34
(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B)Determine the background level using the procedures in Method 21 of 40 CFR part 60,
appendix A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored
equipment to determine whether there is a leak or to determine compliance operational
standards for pressure relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at
the time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair. The written procedures may be included as part of the startup, shutdown,
and malfunction plan, or may be part of a separate document that is maintained at the plant
site. In such cases, reasons for delay of repair may be documented by citing the relevant
sections of the written procedure(i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts, there must be documentation
that the spare parts were sufficiently stocked on-site before depletion and the reason for
depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
i. The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar- days
after it is detected, except as provided for in delay of repair and/or unsafe to repair connectors. A first
attempt at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at
repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring that
the seal flush is operating at design pressure and temperature. First attempt at repair for valves includes,
but is not limited to,tightening the bonnet bolts, and/or replacing the bonnet bolts,and/or tightening the
packing gland nuts,and/or injecting lubricant into the lubricated packing.
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring.
Identification that has been placed on equipment determined to have a leak, except for a valve or for a
connector in gas/vapor or Iight liquid service, may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and, where appropriate, why the repair was
technically infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical, but no later than the end of the next
process unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed
for a valve if valve assembly replacement is necessary during the process unit shutdown, and valve
assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked
Permit 01819T40
Page 35
before the supplies were depleted. Delay of repair beyond the second process unit shutdown will
not be allowed unless the third process unit shutdown occurs sooner than six months after the first
process unit shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if.
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair,and
(B) When repair procedures are effected, the purged material can not be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a quality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg, below) will provide better performance, or the repair is completed as
soon as practical, but not later than 6 months after the leak was detected and one of the following is
used;
(A)A dual mechanical seal system;
(B)A pump that meets has no external shaft penetrating the pump housing;or
(C)A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNanor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines
a leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak,the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with
less than one percent leaking valves.
(B)The Permittee may elect to monitor each valve once every form quarters for process units with
less than 0.5 percent leaking valves.
(C)The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the
monitoring frequency provisions to each subgroup. If the Permittee subdivides the valves in the group
of process units, then the following provisions apply.
L The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup. Valves with less
than one year of monitoring data or valves not monitored within the last twelve inonths must be
placed initially into the most frequently monitored subgroup until at least one year of
monitoring data have been obtained.
(B)Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
Permit 01 S 19T40
Page 36
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to
a less frequently monitored subgroup provided that the valves to be reassigned have not leaked
for the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the
valve or group of valves is to be reassigned to a subgroup being monitored annually). Non-
repairable valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so
indicate the performance in the next periodic report. If the overall performance of total valves in the
applicable process unit or group of process units is two percent leaking valves or greater, the 1
Permittee shall no longer subgroup and shall revert to the program required in Section 2.2 B.2.p. for
that group of process units. The Permittee can again elect to comply with the valve subgrouping
procedures if future overall performance of total valves in the process unit or group of process units
is again less than two percent.The overall performance of total valves in the applicable process unit
or group of process units shall be calculated as a weighted average of the percent leaking valves of
each subgroup according to following equation:
(%VL' x V;}
%V —
Lo - H
V;
Where: %VLO Overall performance of total valves in the applicable process unit or group of
process units
%VLi =Percent leaking valves in subgroup i,most recent value
V; =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee shall maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for each subgroup for each monitoring period;
(C) Which valves are reassigned, the last monitoring result prior to reassignment, and when they
were reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next
monitoring period of the decision to subgroup valves. The notification shall identify the
participating process units and the number of valves assigned to each subgroup, if applicable, and
may be included in the next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for each process group (i.e., botanical extraction,
biomass extraction, and Rotocelhecovery) for comparison with the sub grouping criteria specified in
Section 2.2 B.2.m, above, and the percent leaking valves for each monitoring period for each process
unit or valve subgroup shall be calculated using the following equation:
%V1 = V x 100
T
Where: %VL = Percent leaking valves.
Permit 0 1 819T40
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Vu, = Number of valves found leaking,excluding non-repairable valves and including those
valves found whose repair was not confirmed with both post leak repair monitoring
and periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly, or semiannual monitoring frequencies, the percent leaking valves shall be the arithmetic
average of the percent leaking valves from the last two monitoring periods. When determining
monitoring frequency for each process unit or valve subgroup subject to annual or biennial (once every
2 years) monitoring frequencies, the percent leaking valves shall be the arithmetic average of the
percent Ieaking valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time
the valve is identified as leaking and non-repairable. Otherwise, a number of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in
regulated material service at a process unit or affected facility, the number of non-repairable valves
exceeding one percent of the total number of valves in regulated material service shall be included
in the calculation of percent leaking valves.
p. If a leak is determined, then the leak shall be repaired. After a leak has been repaired,the valve shall be
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and
first attempt at repair. The monitoring shall be conducted to determine whether the valve has
resumed leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides
with the time specified. Alternatively, other monitoring may be performed to satisfy the
requirement regardless of whether the timing of the monitoring period for periodic monitoring
coincides with the time above.
iii. If a leak is detected by monitoring that is conducted after leak repair,the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) If the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy the
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1, above, and the Permittee shall monitor the valve according to the
written plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
permit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that
is designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b,above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal.The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection,the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of
2,000 parts per million (ppm) or greater it shall be repaired using the procedures in Sections 2.2
B.2A through 2.2 B.2.k, above; or
Permit 01819T40
Page 38
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly
visual inspection provided that each pump is visually inspected as often as practical and at least
monthly.
t. If, when calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak, the Permittee
shall implement a quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.99,
below. The Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except
that pumps found leaking in a continuous process unit within one month after start-up of the pump
shall not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
I
%P1. _ —PS}—PS x100
P.1.
Where: %PL=Percent leaking pumps
PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current
monitoring period.
P1. =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in gas and vapor service and in lip-lit liquid service standards [15A NCAC 2Q .0508(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater than or equal to 500 parts per million is
measured, a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this
requirement and shall be monitored and inspected according to the written plan specified in Section 2.2
B.2.b,above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but
less than 0.5 percent, then monitor within four yearns. The Permittee may comply with this
requirement by monitoring at least 40 percent of the connectors within two years of the start of the
monitoring period, provided all connectors have been monitored by the end of the four year
monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical, but within the next six months, all connectors that have not yet
been monitored during the monitoring period if the percent leaking connectors is greater than or
equal to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new
monitoring period shall be started based on the percent leaking connectors of the total
monitored connectors.], or
(B)Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
Permit 01819T40
Page 39
iv. If, during the monitoring, a connector is found to be leaking, it shall be re-aonitored once within 90
days after repair to confirm that it is not leaking.
v. The Permittee shall Keep a record of the start date and end date of each monitoring period under
this section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows:
%CL = Cr x 100
C7.
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
C, = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried, insulated in a manner that prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
v. Not able to be accessed in a safe manner to perform monitoring
are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory,or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [15A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below, each pressure relief device in gas and vapor service
shall be operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of
less than 500 parts per million, as soon as practical, but no later than five calendar days after each
pressure release, except as provided for in delay of repair provisions of this permit;
ii. The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background, and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during
the monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar
days after each pressure release, except as provided for in delay of repair.
Quality improvement program for pumps [15A NCAC 2Q .0508(f)]
bb. If, on a 6-month rolling average, at least the greater of either 10 percent of the pumps in a process unit
or three pumps in a process unit leak, tine Permittee shall implement a quality improvement plan until
the number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in
the process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t,above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program. The data may be collected and the records may be
maintained on a process unit, affected facility, or plant site basis.
Permit 01819T40
Page 40
i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design (e.g., external shaft, flanged body); materials of construction;
if applicable, barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. The maximum instrument readings observed in each monitoring observation before repair,response
factor for the stream if appropriate, instrument model number,and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site) remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seal failures and were
removed from the process unit due to leaks. The inspection shall determine the probable cause of the
pump seal failure or of the pump leak and shall include recommendations, as appropriate, for design
changes or changes in specifications to reduce leak potential.
cc. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above,to determine the services, operating or maintenance practices, and pump or pump seal designs or
technologies that have poorer than average emission performance and those that have better than
average emission performance. The analysis shall determine if specific trouble areas can be identified
on the basis of service, operating conditions or maintenance practices, equipment design, or other
process-specific factors.
i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the service(s), operating conditions, or pump or pump seal
designs associated with poorer than average emission performance. A superior performing pump or
pump seal technology is one with a leak frequency of less than 10 percent for specific applications
in the process unit. A candidate superior performing pump or pump seal technology is one
demonstrated or reported in the available literature or through a group study as having low emission
performance and as being capable of achieving less than 10 percent Ieaking pumps in the process
unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process
unit due to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site, a company,
or a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The
quality assurance program may establish any number of categories, or classes, of pumps as needed to
distinguish among operating conditions and services associated with poorer than average emission
performance as well as those associated with better than average emission performance. The quality
assurance program shall be developed considering the findings of the data analysis required under
paragraph Section 2.2B.2.ee, above, and the operating conditions in the process unit. The quality
I
Perinit 01819T40
Page 41
assurance program shall be updated each year as long as the process unit has the greater of either 10
percent or more leaking pumps or has three leaking pumps.
L The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage,or other applicable identified critical parameters.
(B) Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C)Provide for an audit procedure for quality control of purchased equipment to ensure
conformance with purchase specifications.
(D)Detail off-line pump maintenance and repair procedures. These procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program.
gg. Three years after the start of the quality improvement program, the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
been identified as superior emission performance technology and that comply with the quality
assurance standards for the pump category. Superior emission performance technology is that category
or design of pumps or pump seals with emission performance that when combined with appropriate
process, operating, and maintenance practices, will result in less than 10 percent leaking pumps for
specific applications in the process unit. Superior emission performance technology includes material
or design changes to the existing pump, pump seal, seat support system, installation of multiple
mechanical seals or equivalent,or pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number
of pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero
integer value. The minimum number of pumps or pump seals shall be one. Pump replacement shall
continue until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above,
are pumps determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the
next planned process unit shutdown, provided the number of pump seals and pumps replaced is
equivalent to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shalt maintain records for the period of the quality improvement program for the process
unit prescribed below.
L When using a pump quality improvement program, the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B)Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,
above, and any recommendations for design or specification changes to reduce leak frequency;
and
(C)The beginning and ending dates while meeting the duality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak,the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream, the operating conditions and maintenance practices.
iv. All records documenting the quality assurance program for pumps as specified in the quality
assurance program, including records indicating that all pumps replaced or modified during the
period of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg, above.
Permit 01819T40
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Recordkeening requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not
physically tagged and the Permittee is electing to identify the equipment through written documentation
such as a log or other designation.
jj. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
mm. For valves, the Permittee shall maintain the monitoring schedule for each process unit and the
valve subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pump visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service, the Permittee shall keep records of
the dates and results of monitoring following a pressure release.
qq. For a pump QIP program, the Permittee shall maintain the following records:
L hzdividual pump records as specified in Section 2.2 B.2.cc, above;
ii. Quality assurance program documentation as specified in Section 2.2 13.2.ff, above; and
iii. Quality improvement program records as specified in Section 2.2 B.2.hh,above.
Reporting requirements [15ANCAC 2Q .0508(f)]
rr. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January
and June. The report shall contain in summary format by equipment type(i.e., valves in gas/vapor/light
liquid service, Pumps in light liquid service, and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves,pumps and connectors,and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired, and for valves
and connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
tt. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection
instrument reading of less than 500 parts per million, report the results of all monitoring to show
compliance conducted within the semiannual reporting period.
vv. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report, if applicable,the initiation of a quality improvement program for pumps.
Permit 01819T40
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C. Sclareolide (SDE) Operations, including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity;ID No. M-20);
• Process equipment leaks (ID No. ES-1001-1-4-F);
• Four batch reactors (ID Nos. M-10, M-10A,D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate; ID No. CD-M-34); and
• SDE Operations wastewater stream (ID No. ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide, including:
• Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks(ID No.ES-1001-1-3-F);
• One distillation column (6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for sclareolide purification wastewater stream (ID No. ES-1001-
1-3-W W)
Ethyl Vanillin Glucoside (EVG) Operations, including:
• One water spray fuine scrubber (0.5 gallon per minute minimum water injection rate; ID No.
CD-Z-9215) venting to one water spray fume scrubber (0.5 gallon per minute minimum water
injection rate; ID No. CD-Z-9216) controlling emissions from:
o Three reactors (ID Nos.D-2202,D-1215, and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks (ID No.ES-1003-2-2-F); and
• EVG Operations wastewater stream (ID No.ES-1003-2-2-WW)
Sclareol Reciystallization (SFG) Operations, including:
• Four process tanks (2,500 gallons capacity each; ID Nos.T-3002 through 3005);
• One hexane storage tank(6,700 gallon capacity; ID No.T-3001);
• One centrifuge(ID No. C-3001);
• One chilled water condenser(ID No. CD-3001)controlling emissions from:
- One reactor(ID No.R-3001)equipped with a process chilled water condenser(EX-3001)
- One reactor(ID No.R-3002)equipped with a process chilled water condenser(EX-3003)
- One steam heated dryer(ID No.D-3001)
• Process equipment leaks (ID No.ES-1003-10-F);
• SFG Operations wastewater stream (ID No.ES-1003-10-WW)
Plant Nutrient Extraction (PNE) Operations, including one water spray fume scrubber (0.5
gallon per minute minimum water injection rate; ID No. CD-Z-9215) venting to one water
spray fume scrubber (0.5 gallon per minute minimum water solution injection rate; ID No.
CD-Z-9216) controlling emissions from:
• One product extract reactor(ID No. D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities (ID No. ES-1003-2-1-P);
• One centrifuge(ID No. C-31203);
• Process equipment leaks(ID No.ES-1003-2-1-F);
• One waste solids separator vessel (1,333 gallon capacity; ID No. D31211) and one associated
chilled water condenser(ID No.EX2205); and
• PNE Process wastewater stream (ID No.ES-1003-2-1-WW)
Permit 01819T40
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Concrete Operations,including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and HB-4);
• Process equipment leaks (H)No.ES-1001-1-2-F);
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser(ID No. CD-1001-1-2); and
• Concrete Operations wastewater stream (ID No.ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No. WWTP-ATI)
The following table provides a sununary of limits and standards for the emission sources describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Maximum Achievable Control 15A NCAC 2D .1111
Hazardous Air Pollutants (HAP) Technology [40 CFR Part 63, Subpart
FFFF]
1. 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63,Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF, including Subpart A "General Provisions". For convenience, some of the
relevant definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435,
63.2440, 63.2445(b),and 63.25501
Group I batch process veal means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions from all of the batch process vents are greater than or equal to
10,000 Ib/yr at an existing source or grater than or equal to 3,000 lb/yr at a new source.
Group 2 batch process vent means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group I continuous process vent means a continuous process vent for which the flow rate is greater
than or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b), is less than or equal to 1.9 at an existing source and less than or
equal to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not ineet the definition of
a Group 1 continuous process vent.
Group I storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group I wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria for Group 1 status in §63.2485(c)for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in§63.132(d)for compounds in Table 8 to subpart G of this part 63.
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group i wastewater stream.
Pei7nit 01819T40
Page 45
In organic HAP service means that a piece of equipment either contains or contacts a fluid (liquid or
gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions
of§63.180(d). The provisions of§63.180(d) also specify how to determine that a piece of equipment is
not in organic HAP service.
Miscellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in §63.2435(b). For
the purposes of this subpart, process includes any, all or a combination of reaction, recovery,
separation, purification, or other activity, operation, manufacture, or treatment which are used to
produce a product or isolated intermediate.
Nonslandaral batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch. A nonstandard batch may be necessary as a result of a malfunction, but j
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of
an MCPU as described by records specified in §63.2525(b).
Point of determination means each point where process wastewater exits the MCPU or control device.
Slandard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions fi-om a standard batch ate based on the operating
conditions that result in highest emissions. The standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Requirements/Limitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.I.b.i through v, below:
i. The Permittee must submit a Notice of Compliance Status Report for the SDE Operations, the
Concrete Operations, and/or the PNE Operations prior to the operation of those operations in
organic HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63,
Subpart FFFF apply to those operations,pursuant to 40 CFR§63.2520(d).
ii. Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to
avoid unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. If a Group 2 emission point becomes a Group I emission point, the Permittee must be in
compliance with the Group I requirements beginning on the date the switch occurs. An initial
compliance demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within
150 days after the switch in group status occurs. The Permittee shall be deemed in non-compliance
with 15A NCAC 2D .I I II if the Permittee does not meet these requirements. [40 CFR
§63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR §63.6(e) for the affected sources. The Permittee is not, however, required to
address equipment Ieaks (except for control devices) or Group 2 emission points in the SSM Plan.
The SSM Plan must describe, in detail, procedures for operating and maintaining the affected
sources during periods of startup, shutdown, and malfunction; and corrective actions for
malfunctioning process, control,and monitoring equipment used to comply with Subpart FFFF. The
SSM Plan does not need to address any scenario that would not cause an affected source to exceed
an applicable emission Iimit in Subpart FFFF. The SSM Plan must be maintained on site and made
available for inspection by authorized personnel. [40 CFR§§63.6(e)(3)and 63.25250)]
The Permittee shall be deemed in non-compliance with I5A NCAC 2D A I I I if it does not meet the
requirements of Sections 2.2 C.l.b.i through v,above.
Permit 01819T40
Page 46
Monitoring Requirements [I SA NCAC 2Q .0508(f)]
c. The Permittee shall comply with the specific requirements of Sections 2.2 C.l.c.i through vii, below:
L Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.i(A)and (B), below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.h through k,
above.
(B) For continuous process vent associated with the Botanical Extraction Operations, the Permittee
shall perform the monitoring found in Sections 2.2 B.1.h and i, above.
ii. Batch process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.ii(A)through (C), below,for the affected batch process vents:
(A)For the batch process vents associated with the SFG Operations, the EVG Operations, and the
Biological conversion equipment for purification of sclareolide, the Permittee shall comply
with the requirements of 40 CFR §63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF. To
maintain Group 2 classification for these emission sources the organic HAP emissions must be
less than 10,000 pounds per consecutive 365-day period, each source. The Permittee shall
monitor the organic HAP emissions from each of these emission sources,monthly, as follows:
(1) Organic HAP emissions from the SFG Operations shall calculated using the following
equation:
ornrdsl 11outrds) ,, rotttrdsOrganic HAP= 37.89 pxBtf + [11.45(polfflds xBregJ+[15.03(P xB �+L9.75(P )xB,,
J J
tan tll batch batch batch
Where: B,,g — The number of regular batches processed in the SFG Operations; and
Bf,C The number of recrop batches processed in the SFG Operations
Btc = The number of third crop batches processed in the SFG Operations; and
Btf = The number of hexane tank(T-3001) fills.
(2) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 1.0 pounds x B
( batch
Where: B — The number of batches processed in the EVG Operations
(3) Organic HAP emissions from the Biological conversion equipment for purification of
sclareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x B
batch
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B) The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.l.c.ii(A)(1)through(3), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations, the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of
40 CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,
combined. The Permittee shall monitor the organic HAP emissions from these batch process vents,
monthly, as follows:
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:
Permit 01 S 19T40
Page 47
(pounds poundsOrganicHAP= 11.3 hatch )x B,�g +[31.8(( batch )X B,,,
Where: Bfeg = The number of regular batches processed in the EVG Operations; and
B,,, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.I.c.iii(A), above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(i i).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Pertnittee shall comply
with the requirements of 40 CFR§63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair
(LDAR) program found in Section 2.2 B.2, above, for the equipment associated with the affected
sources.
vi. Wastewater streams: For the wastewater streams associated with the affected miscellaneous
organic chemical manufacturing processes (MCPU), the Permittee shall comply with the
requirements of 40 CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca,
Inc. facility;and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2, unless the conditions of Section 2.2 C.Lb.iv, above, have been
met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR§63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will
be used to detect leaks of process fluids into cooling water. This plan shall require monitoring
of one or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more
process parameters or other conditions that indicate a leak. The plan shall include the
following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s) or conditions(s) that shall constitute a leak. This shall be
documented by data or calculations showing that the selected levels or conditions will
reliably identify leaks. The monitoring must be sufficiently sensitive to determine the range
of parameter levels or conditions when the system is not leaking. When the selected
parameter level or condition is outside that range, a Ieak is indicated;
(3) The monitoring frequency which shall be no Iess frequent than monthly for the first 6
months and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after
discovery of the leak.
(C)The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded, retain the most recent superseded plan at least until 5 years from
the date of its creation.
Pennit 01819T40
Page 48
(D)If a leak is detected in any heat exchanger system, it shall be repaired as soon as practical but
not later than 45 calendar days after the Permittee receives results of monitoring tests indicating
a leak, unless the Permittee demonstrates that the results are due to a condition other than a
leak. Once the leak has been repaired, the owner or operator shall confirm that the heat
exchange system has been repaired within 7 calendar days of the repair or startup, whichever is
later, except where the Permittee appropriately applies the delay of repair provisions found in
Section 2.2 C.i.c.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the j
process. Delay of repair is also allowed if repair is technically infeasible without a shutdown
and any one of the conditions listed in 40 CFR§63.104(e)(1)through(2) is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.eA through vii,above.
Record1weying Requirements[15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.l.d.i through v,below:
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B)An identification of related process vents (including associated emissions episodes),
wastewater points of determination(PODS),and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents, the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of
operating and/or testing conditions for any associated control device;
(E) The process vents, wastewater POD, transfer racks, and storage tanks (including those from
other processes)that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G)Calculations and engineering analyses required to demonstrate compliance.
iii. For each affected MPCU with a Group 2 process vent, the Permittee shall retain the following
records:
(A)A record of the day each batch was completed;
(B)A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a
non-standard batch; and
(D)Records of the daily 365-day rolling summations of emissions, or alternative records that
correlate to the emissions(e.g.,number of batches), calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream,the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds listed in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw), including documentation of the methodology used to determine concentration; and,
(D)Stream flow rate(in litershnin).
v. For each affected heat exchanger system, the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak, the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan, including the date the leak was discovered;
(C)The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .l 111 if the Permittee does not
Permit 01819T40
Page 49
meet the requirements of Sections 2.2 C.l.d.i through v, above.
Renortin [15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR§63.2460(b)(6) and 40 CFR§63.2520(e)(10).
f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and December, and July 30 of
each calendar year for the preceding six-month period between January and June. The report shall
contain the following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard
specified in this subpart, include a statement that there were no deviations from the emission limits,
operating limits,or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period;and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable),as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered
by the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary format by equipment type, the number of
components for which leaks were detected and for valves,pumps and connectors show the percent .
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required, and for valves and connectors, identify the number
of components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized, report that delay of repair has occurred and report
the number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report, if applicable,the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair,
include the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s)for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired, the expected date of repair.
Permit 0j 819T40
Page 50
2. 15A NCAC 2Q.0317: AVOIDANCE CONDITIONS
15A NCAC 2D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the SFG operations shall discharge into the atmosphere
less than 95.29 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]
MonitoringMecordlccening,[15A NCAC 2Q .0508 (f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a log(written or
electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
L The monthly VOC emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.
3. LIMITATION TO AVOID BEING CLASSII+IED AS A MON GROUP 1 BATCH PROCESS VENT
a. In order to remain classified as a Group 2 batch process vent for hazardous air pollutants(HAP)under
40 CFR 63, Subpart PFFF, uncontrolled HAP emissions from the SFG operations shall be less than
10,000 pounds per year. The Permittee shall be deemed a Group I batch process vent if the HAP
emissions exceed this limit.
Monitorinu/Recordkeepintl Requirements [15A NCAC 2Q ,0508(l)]
b. Maintain monthly calculations of HAP emissions. The Permittee shall be deemed a Group 1 batch
process vent if the records are not maintained.
Reporting Reauh-ements [15A NCAC 2Q .0508(f)]
c. Submit to the Regional Supervisor, Division of Air Quality, semiannually, a report summarizing HAP
emissions from SFG operations containing the following:
L greatest quantity in pounds of an individual hazardous air pollutant used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average;
ii. pounds of all hazardous air pollutants used:
A. for each month during the semiannual period, and
B. for each 12-month period ending on each month during the semiannual period using a
12-month rolling average.
Permit 01819T40
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SECTION 3 GENERAL CONDITIONS (version 3.6)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions[NCGS 143-215 and 15A NCAC 2Q,0508(i)(16)]
1.Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2.The terms,conditions,requirements, limitations,and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B,including assessment of civil and/or criminal penalties.Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3.This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the
facility which are not addressed in this permit.
4.This permit does not relieve the Permittee fiom liability for harm or injury to human health or welfare,animal or plant
life,or property caused by the construction or operation of this permitted facility,or fiom penalties therefore,nor does
it atlow the Pennittee to cause pollution in contravention of state laws or rules,unless specifically authorized by an
order from the North Carolina Environmental Management Commission.
5.Except as identified as state-only requirements in this permit,all terms and conditions contained herein shall be
enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal Clean Air Act.
6.Any stationary source of air pollution shall not be operated,maintained,or modified without the appropriate and valid
permits issued by the DAQ,unless the source is exempted by rule. The DAQ may issue a permit only after it receives
reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements.
A permitted installation may only be operated,maintained,constructed,expanded,or modified in a manner that is
consistent with the terms of this permit.
B. Permit Availability[15A NCAC 2Q.0507(k)and.0508(i)(9)(B)]
The Pennittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit teen
one complete copy of the application and any information submitted in support of the application package. The permit and
application shall be made available to an authorized representative of Department of Environment and Natural Resources
upon request.
C. Severability Clause[15A NCAC 2Q.0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid,the
provisions in this permit are severable so that all requirements contained in the permit,except those held to be invalid,shall
remain valid and must be complied with.
I
D. Submissions[15A NCAC 2Q .0507(e)and 2Q.0508(i)(16)]
Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,notifications,request j
for renewal,and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer
to the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems(CEMS)
reports,continuous opacity monitoring systems(COMS)reports,quality assurance(QA)/quality control(QC)reports,acid
rain CEM certification reports,and NOx budget CEM certification reports,one copy shall be sent to the appropriate
Regional Office and one copy shalt be sent to:
Supervisor,Stationary Source Compliance
North Carolina Division ofAir Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
E. Duty to Comply[15A NCAC 2Q.0508(i)(3)]
Tire Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in this permit.
Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a violation of
Permit 01819T40
Page 52
the Federal Clean Air Act. Noncompliance with any pen-nit condition is grounds for enforcement action,for pen-nit
termination,revocation and reissuance,or modification,or for denial of a permit renewal application.
F. Circumvention-STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner 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 pollution control device(s)and appurtenances.
G. Permit Modifications
1.Administrative Permit Amendments[I5A NCAC 2Q.0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with I5A NCAC 2Q
.0514.
2.Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q.0524 and 2Q.0505]
The Perrnittee shall submit an application for an ownership change in accordance with 15A NCAC 2Q.0524 and 2Q
.0505.
3.Minor Permit Modifications [I5A NCAC 2Q.0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q .0515.
4.Significant Permit Modifications[15A NCAC 2Q.0516]
The Permittee shall submit an application for a significant pen-nit modification in accordance with 15A NCAC 2Q
.0516.
5.Reopening for Cause[I5A NCAC 2Q.0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q.0517.
H. Changes Not Rea uirina Permit Modifications
1.Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in Section 1
must be reported to the Regional Supervisor,DAQ:
a. changes in the infonnation submitted in the application;
b. changes that modify equipment or processes;or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit
conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations
specified herein.
2.Section 502(b)(10)Changes[I 5A NCAC 2Q.0523(a)]
a. "Section 502(b)(10)changes"means changes that contravene an express permit tern or condition.Such changes
do not include changes that would violate applicable requirements or contravene federally enforceable permit
terms and conditions that are monitoring(including test methods),recordkeeping,reporting,or compliance
certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Pennittee notifies the Director and EPA with written notification at least seven days before the change
is made;and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions;and
iv. any pennit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10)changes shall be made in the permit the next time that the pennit is revised or renewed,
whichever comes first.
3.Off Permit Changes[15A NCAC 2Q.0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
i
Permit 01819T40
Page 53
a. the change affects only insignificant activities and the activities remain insignificant after the change;or
b. the change is not covered under any applicable requirement.
4.Emissions Trading[15A NCAC 2Q.0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D,including subsequently adopted maximum
achievable control technology standards,emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 2Q.0523(c).
I.A.Reporting Requirements for Excess Emissions and Permit Deviations
[15A NCAC 2D.0535(f)and 2Q.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard allowed by any
rule in Sections.0500,.0900,.1200,or.1400 of Subchapter 21);or by a permit condition;or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q.0700. (Note:Definitions of excess emissions cinder 2D.I I 10 and 2D
.1111 shall apply where defined by cwle.)
"Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and conditions of
this penuit including those attributable to upset conditions as well as excess emissions as defined above lasting less than
four hours.
Excess Emissions
1.If a source is required to report excess emissions under NSPS(15ANCAC 2D.0524),NESHAPS(15A NCAC 2D
.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of excess emissions,reporting
shall be performed as prescribed therein.
2.If the source is not subject to NSPS(15A NCAC 2D.0524),NESHAPS(15A NCAC 2D.I I 10 or.1111),or these ru les
do NOT define"excess emissions,"the Permittee shall report excess emissions hi accordance with 15A NCAC 2D
.0535 as follows:
a. Pursuant to 15A NCAC 2D.0535,if excess emissions last for more than four hours resulting from a malfunction,
a breakdown of process or control equipment,or any other abnormal condition,the owner or operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m.Eastern Time of the
Division's next business day of becoming aware of the occun•ence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration;and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished;and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC
2D.0535(f)(3).
Permit Deviations
3.Pursuant to 15A NCAC 2Q .0508(f)(2),the Permittee shall report deviations fiorn permit requirements(terms and
conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from pen-nit requirements not covered under
15A NCAC 2D.0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of
such deviation and any connective actions or preventative actions taken. The responsible official shall certify all
deviations from permit requirements.
I.B. Other Requirements under 15A NCAC 2D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D.0535,including 15A
NCAC 2D.0535(c)as follows:
1.Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the appropriate
rule unless the owner or operator of the sources demonstrates to the Director,that the excess emissions are a result of a
malfunction. Tyre Director shall consider,along with any other pertinent information,the criteria contained in 15A
NCAC 2D.0535(c)(1)through(7).
2. 15A NCAC 2D.0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
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J. Enteraency Provisions[40 CFR70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1.An emergency means any situation arising fi•om sudden and reasonably unforeseeable events beyond the control of the
facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitation under the permit,due to unavoidable
increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment,lack of preventive maintenance,careless or improper operation,or operator
error.
2.An emergency constitutes an aflinnative defense to an action brought for noncompliance with such technology-based
emission limitations if the conditions specified in 3.below are met.
3.The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating togs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the pennit;and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency,steps
taken to mitigate emissions,and corrective actions taken.
4.In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the burden of
proof.
5.This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal[15A NCAC 2Q.0508(e)and 2Q.0513(b)]
This I5A NCAC 2Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its term.
Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 2Q .0500 renewal application is
submitted at least nine months before the date of permit expiration. If the Permittee or applicant has complied with 15A
NCAC 2Q .0512(b)(1), this 15A NCAC 2Q .0500 permit shall not expire until the renewal permit has been issued or
denied. Permit expiration under 15A NCAC 2Q .0400 terminates the facility's right to operate unless a complete 15A
NCAC 2Q .0400 renewal application is submitted at least six months before the date of permit expiration for facilities
subject to 15A NCAC 2Q .0400 requirements. In either of these events, all terns and conditions of these permits shall
remain in effect until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense[15A NCAC 2Q.0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information)[15A NCAC 2Q.0508(i)(9)]
1.The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director may request in
writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to
determine compliance with the permit.
2.Tile Permittee shalt furnish the DAQ copies of records required to be kept by the permit when such copies are requested
by the Director.For information claimed to be confidential,the Permittee may furnish such records directly to the EPA
upon request along with a claim of confidentiality.
N. Duty to Supplement[15A NCAC 2Q.0507(f)]
The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the
permit application,shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee
shall also provide additional information as necessary to address any requirement that becomes applicable to the facility
after the date a complete permit application was submitted but prior to the release of tine draft permit.
O. Retention of Records[15A NCAC 2Q.0508(f)and 2Q.0508(I)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five
Permit 01819T40
Page 55
years from the date of the monitoring sample,measurement,report,or application. Supporting information includes al
calibration and maintenance records and all original strip-chart recordings for continuous monitoring information,and
copies of all reports required by the permit. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. Any records required by the conditions of this permit shall be kept on site and made
available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 21).0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,bl Forsyth
Street,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for the preceding calendar year)
by a responsible official with a1I federally-enforceable terms and conditions in the permit, including emissions limitations,
standards,or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the
entire year regardless of who owned the facility during the year. The compliance certification shall comply with additional
requirements as may be specified under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance
certification shall specify:
1.the identification of each term or condition of the permit that is the basis of the certification;
2.the compliance status(with the terms and conditions of the permit for the period covered by the certification);
3.whether compliance was continuous or intermittent;and
4.the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Resnonsible Official[15A NCAC 2Q.0520]
A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after
reasonable inquiry,the statements and information in the document are true,accurate,and complete.
R. Permit Shield for Applicable ReQuirements[15A NCAC 2Q.0512]
1.Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the permit as of the date of permit
issuance.
2.A permit shield shall not alter or affect:
a. the power of the Commission,Secretary of the Department,or Governor under NCGS 143-215.3(a)(12),or EPA
under Section 303 of the Federal Clean Air Act; j
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective j
date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV;or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3.A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made j
under 15A NCAC 2Q.0523.
4.A permit shield does not extend to minor permit modifications made under 15A NCAC 21).0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 2Q.0519]
The Director may terminate,modify,or revoke and reissue this permit if:
1.the information contained hi the application or presented in support thereof is determined to be incorrect;
2.the conditions under which the pennit or permit renewal was granted have changed;
3.violations of conditions contained in the permit have occurred;
4.the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or
5.the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to carry out the
purpose ofNCGS Chapter 143,Article 21B.
T. Insignificant Activities f 15A NCAC 2Q.0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or that the owner or operator of the source is exempted fi•om demonstrating compliance with
any applicable requirement. The Permittee shall have available at the facility at all times and made available to an
authorized representative upon request,documentation,including calculations,if necessary,to demonstrate that an
emission source or activity is insignificant.
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Page 56
U. Property Rights[15A NCAC 2Q.0508(i)(8)]
This permit does not convey any proper rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry[15A NCAC 2Q.0508(1)and NCGS 143-215.3(a)(2)]
1.Upon presentation of credentials and other documents as may be required by law,the Permittec shall allow the DAQ,or
an authorized representative,to perform the following:
a. enter the Pennittee's premises where the permitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions of the permit;
b. have access to and copy,at reasonable tunes,any records that are required to be kept under the conditions of the
permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring
and air pollution control equipment),practices,or operations regulated or required under the permit;and
d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under
Section 114 or other provisions of the Federal Clean Air Act.
2.No person shall refirse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment[15A NCAC 2Q.0508(i)(10)]
1.The Pennittee shall pay all fees in accordance with 15A NCAC 2Q.0200.
2.Payment of fees may be by check or money order made payable to the N.C.Department of Environment and Natural
Resources. Annual permit fee payments shall refer to the permit number.
3.If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate action to terminate
the permit under 15A NCAC 2Q.0519.
X. Annual Emission Inventory Requirements[15A NCAC 2Q.0207]
The Permittee shall report by.Tune 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q
.0207(a)from each emission source within the facility during the previous calendaryear. The report shall be in or on such
form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the
facility.
Y. Confidential Information[15A NCAC 2Q.0107 and 2Q.0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107,the
Pennittee may also submit a copy of all such urfannation and claim directly to the EPA upon request. All requests for
confidentiality must be in accordance with 15A NCAC 2Q.0107.
Z. Construction and Operation Permits[15A NCAC 2Q.0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or
emission source which is not exempted from having a permit prior to the beginning of construction or modification,in
accordance with all applicable provisions of 15A NCAC 2Q.0100 and.0300.
AA.Standard Application Form and Required Information[15A NCAC 2Q.0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 2Q
.0505 and .0507.
BB.Financial Responsibility and Complianee History[15A NCAC 2Q.0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
CC.Refrigerant Requirements(Stratospheric Ozone and Climate Protection)[15A NCAC 2Q.0501(c)]
1.if the Pennittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or 11
Permit 0 1 819T40
Page 57
ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40
CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment
according to the work practices,personnel certification requirements,and certified recycling and recovery equipment
specified in 40 CFR Pail 82 Subpart F.
2.The Permittee shall not knowingly vent or otherwise release any Class I or 11 substance into the environment during the
repair,servicing,maintenance,or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3.The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR❑ 82.166. Reports shall be
submitted to the EPA or its designee as required.
DD.Prevention of Accidental Releases-Section 112(r)[15A NCAC 2Q.0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r)of the
Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
FF. Prevention of Accidental Releases General Duty Clause-Section 112(r)(1)-
FEDERALLY-ENFORCEABLE ONLY
Although a risk management plan may not be required,if the Permittee produces,processes,handles,or stores any amount
of a listed hazardous substance,the Pennittee has a general duty to take such steps as are necessary to prevent the
accidental release of such substance and to minimize the consequences of any release.
FF. Title I Allowances [t5A NCAC 2Q.0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not use
allowances as a defense to noncompliance with any other applicable requirement. The Permittec's emissions may not
exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG.Ali-Pollution Emergency Episode[15A NCAC 2D.0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to operate in
accordance with the Permittee's previously approved Emission Reduction Plan or,in the absence of an approved plan,with
the appropriate requirements specified in 15A NCAC 2D.0300.
HH.Re istration of Air Pollution Sources[15A NCAC 2D.0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to
register a source of air pollution,this registration and required information will be in accordance with 15A NCAC 2D
.0202(b).
II. Ambient Air Quality Standards[15A NCAC 2D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,any source
of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 2D.0400 to be exceeded at any point beyond the premises on which the source is located. When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of
the ambient air quality standards or are required to create an offset,the permit shall contain a condition requiring these
controls.
JJ. General Emissions Testing and Reporting Requirements[15A NCAC 2Q.0508(i)(16)]
Emission compliance testing shall be by the procedures of Section.2600,except as may be otherwise required in Rules
.0524,.0912, .1110, .11 l 1,or.1415 of Subchapter 2D.If emissions testing is required by this permit or the DAQ or if the
Permittee submits emissions testing to the DAQ to demonstrate compliance,the Permittee shall perform such testing in
accordance with 15A NCAC 213.2600 and follow the procedures outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing.Testing protocols are not required to be pre-approved by the Director prior to
air pollution testing.The Director shall review air emission testing protocols for pre-approval prior to testing if
requested by the owner or operator at least 45 days before conducting the test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard shall
notify the Director at least 15 days before beginning the test so that the Director may at his option observe the test.
3.The owner or operator of the source shall arrange for controlling and measuring the production rates during the
period of air testing.The owner or operator of the source shall ensure that the equipment or process being tested is
Permit 01819T40
Page 58
operated at the production rate that best fulfills the purpose of the test.The individual conducting the emission test
shall describe the procedures used to obtain accurate process data and include in the test report the average
production rates determined during each testing period.
4.Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after sample
collection unless otherwise specified in the specific conditions. The owner or operator may request an extension to
submit the final test report.The Director shall approve an extension request if he fmds that the extension request is
a result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the validity of
the compliance test. The Director may:
(1) Allow deviations fi•om a method specified under a rule in this Section if the owner or operator of the
source being tested demonstrates to the satisfaction of the Director that the specified metliod is
inappropriate for the source being tested.
(2)Prescribe alternate test procedures on an individual basis when he finds that the alternative method is
necessary to secure more reliable test data.
(3)Prescribe or approve methods on an individual basis for sources or pollutants for which no test method is
specified in this Section if the methods can be demonstrated to determine compliance of permitted
emission sources or pollutants.
b.The Director may authorize the Division of Air Quality to conduct independent tests of any source subject to a
rule in this Subchapter to determine the compliance status of that source or to verify any test data submitted
relating to that source.Any test conducted by the Division of Air Quality using the appropriate testing
procedures described in Section 2D.2600 has precedence over all other tests.
KK.Reopening for Cause[15A NCAC 2Q.0517]
L A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three or more
years;
b. additional requirements(including excess emission requirements)become applicable to a source covered by Title
1V;
c. the Director or EPA finds that the pennit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards or other terms or conditions of the pennit;or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2.Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is
promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit term
unless the term of the permit was extended pursuant to 15A NCAC 2Q.0513(c).
3.Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 2Q.0507,.0521,or
.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the permit is reopened,the
procedures in 15A NCAC 2Q.0300 shall be followed. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4.The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,except in
cases of imminent threat to public health or safety the notification period may be less than 60 days.
5.Within 90 days,or 180 days if the EPA extends the response period,after receiving notification firm the EPA that a
permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the EPA a proposed
determination oftennination,modification,or revocation and reissuance,as appropriate.
LL. Reporting Requirements for Non-Operating Equipment[15A NCAC 2Q.0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken 11-om
and placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the
permit shall be unplemented within the monitoring period.
MM.Fugitive Dust Control Reguirennent[15A NCAC 2D.0540]-STATE ENFORCEABLE ONLY
As required by l 5A 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
boundary.If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the
property y P g� • n' Y
property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
Permit 01819T40
Page 59
operator may be required to submit a fugitive dust plan as described in 2D.0540(f).
"Fugitive dust emissions"means particulate matter from process operations that does not pass through a process stack or
vent and that is generated within plant property boundaries from activities such as:unloading and loading areas,process
areas stockpiles,stock pile working,plant parking lots,and plant roads(including access roads and haul roads).
NN.Specific Permit Modifications[I5A NCAC 2Q.0501 and.0523]
1.For modifications made pursuant to 15A NCAC 2Q.0501(c)(2),the Permittee shall file a Title V Air Quality Permit
Application for the air emission source(s)and associated air pollution control device(s)on or before 12 months
after commencing operation.
2.For modifications made pursuant to 15A NCAC 2Q .0501(d)(2),the Permittee shal I not begin operation of the air
emission sources)and associated air pollution control device(s)until a Title V Air Quality Permit Application is
filed and a construction and operation permit following the procedures of Section .0500(except for Rule .0504 of
this Section)is obtained.
3.For modifications made pursuant to 502(b)(10), in accordance with I5A NCAC 2Q .0523(a)(1)(C),the Permittee
shall notify the Director and EPA(EPA-Air Planning Branch,61 Forsyth St., Atlanta,GA 30303)in writing at
least seven days before the change is made. The written notification shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions;and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement,with the next significant modification or Air Quality Permit renewal,
the Permittee shall submit a page"ES"of the application forms signed by the responsible official verifying that the
application For the 502(b)(10)change./modification, is true,accurate,and complete. Further note that
modifications made pursuant to 502(b)(10)do not relieve the Permittee fi-om satisfying preconstruction
requirements.
00.Third Party Participation and EPA Review[15A NCAC 2Q.0521,.0522 and .0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency(EPA), EPA's
decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party
petition,the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit.
The time period available to submit a public petition pursuant to 15A NCAC 2Q .0518 begins at the end of the 45-day
EPA review period.
i
I
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CAA Clean Air Act
CAIR Clean Air Interstate Rule
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
MCPU Miscellaneous Organic Chemical Manufacturing Process Units
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PMrp Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
SIC Standard Industrial Classification
SIP State Implementation Plan
S02 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound