HomeMy WebLinkAboutAQ_F_1800242_20140313_PRMT_Permit . . . .. .. ....
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North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
March 13, 2014
Mr. Gene Bullis, Jr.
Chief Financial Officer
Heritage Home Group, LLC - Lane Venture
Post Office Box 849
Conover,NC 28613
Subject: Air Permit No. 04967R16
Heritage Home Group, LLC - Lane Venture
Conover, Catawba County,North_Carolina
Permit Class: Small
Facility ID# 1800242
Dear Mr. Bullis, Jr.:
In accordance with your completed application received February 17, 2014, we are
forwarding herewith Permit No. 04967R16 to Heritage Home Group, LLC - Lane Venture,
Conover,Catawba County,North Carolina for the construction and operation of air emissions
sources or air cleaning devices and appurtenances. Additionally, any emissions activities
determined from your air permit application as meeting the exemption requirements contained in
15A NCAC 2Q .0102 have been listed for information purposes as an "ATTACHMENT"to the
enclosed air permit. Please note the records retention requirements are contained in General
Condition 2 of the General Conditions and Limitations.
If any parts, requirements, or limitations contained in this permit-are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
15OB-23 of the North Carolina General Statutes,and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting.a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
Mooresville Regional Office-Division of Air Quality
610 East Center Avenue,Suite 301,Mooresville,North Carolina 28115
Phone:704-663-16991 FAX:704-663-7579
Internet:www.ncair.org
An Equal Opportunity 1 Affirmative Action Employer-Made in part by Recycled Paper
Gene Bullis, Jr.
March 13, 2014
Page 2
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 150B-23.
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from March 13, 2014 until February 28, 2022, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination,revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
- Based on the potential emissions for VOCs and HAPs, this facility will be reclassified from
a Prohibitory Small to a Small facility; therefore, stipulation 2Q .0803 will be deleted from
the permit.
Should you have any questions concerning this matter, please contact Jennifer Womick at(704)
663-1699.
Sincerely,
Ronald E. Slack
Regional Air Quality Supervisor
JAW
Enclosures
c: Mooresville Regional Office
G:\AQ\Shared\WPDATA\COUNTIES\CATAWBA\00242\RI6_PERMIT.docx
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 04967R16
Issue Date: March 13,2014 Effective'Date: March 13,2014
Expiration Date: February 28, 2022 Replaces Permit: 04967R15
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Heritage Home Group, LLC - Lane Venture
1405 Deborah Herman Road
Conover, Catawba County,North Carolina
Permit Class: Small
Facility ID# 1800242
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
WD-1 woodworking operations CDC-7a,CDC-7b,CDC-7c simple cyclone(ID No.CDC-7a,
11 feet in diameter),simple
cyclone(ID No. CDC-7b, 11 feet
in diameter),simple cyclone(ID
No.CDC-7c,8.5 feet in diameter)
IS(NESHAP), four(4)dry filter type spray
24S(NESHAP), booths N/A N/A
25S(NESHAP),
27S(NESHAP)
1 (NESHAP), four(4)baffle type spray
2(NESHAP); booths N/A N/A
3 (NESHAP),
4(NESHAP)
11 S,(NESHAP), six(6)water cascade type
13S(NESHAP), spray booths
15 S(NESHAP), N/A N/A
16S(NESHAP),
2S(NESHAP);
6S(NESHAP)
Permit No. 04967R16
Page 2
Emission Emission Source Control Control System
Source ID Description System ID Description
DT-I (NESHAP), sixteen(16)dip tanks
DT-10(NESHAP),
DT-11 (NESHAP),
DT-12(NESHAP),
DT-13 (NESHAP),
DT-14(NESHAP),
DT-15(NESHAP),
DT-16(NESHAP), N/A N/A
DT-2(NESHAP),
DT-3 (NESHAP),
DT-4(NESHAP),
DT-5(NESHAP),
DT-6(NESHAP),
DT-7(NESHAP),
DT-8(NESHAP);
DT-9(NESHAP)
WT1 (NESHAP)washofftank - ,N/A-
Q-I (NESHAP) gluing operation ��+��---~ N/A N/A
ES-TouchUp surface coating operation
consisting of hand-held non-
refillable aerosol cans and N/A N/A
touch-up markers/marking
pens
in accordance with the completed application 1800242.14A received February 17, 2014 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environment and Natural Resources, Division of Air Quality(DAQ) and are
incorporated as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct.and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0512, 2D .0521, 2D .0535,2D .0540,.2D .0611, 2D .0958 and 2D .1111 (40
CFR 63, Subpart JJ).
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT -The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q
.0203(i),no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request (with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit,the Permittee shall submit the air pollution emission inventory report
Permit No. 04967RI6
Page 3
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2020 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0512
"Particulates from Wood Products Finishing Plants,"the Permittee shall not discharge
particulate matter caused by the working, sanding, or finishing of wood without providing,
as a minimum for its collection, adequate duct work and properly designed collectors, or
other such devices as approved by the Commission.
4. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six-minute period, except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with 15A NCAC 2D .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
5. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration,and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
6. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints or excessive fugitive
dust emissions from the facility are observed beyond the property boundaries for six minutes
Permit No. 04967R16
Page 4
in any one hour (using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile.working,plant parking lots,
and plant roads (including access roads and haul roads).
7. CYCLONE REQUIREMENTS -As required by 15A NCAC 2D .0611,particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform an annual (for each 12 month period following the initial inspection)
inspection of the cyclone system. In addition,the Permittee shall perform periodic
inspections and maintenance(I&M) as recommended by the manufacturer.
b. Recordkeeping Requirements - The results of all inspections and any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a cyclone logbook. Records of all maintenance activities shall be recorded in the
logbook. The cyclone logbook(in written or electronic format) shall be kept on-site
and made available to DAQ personnel upon request.
8. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. As required by 15A NCAC 2D .0958(c), for all sources at facilities that use volatile
organic compounds (VOC) as solvents, carriers,material processing media, or
industrial chemical reactants, or in similar uses that mix,blend, or manufacture
volatile organic compounds, or emit volatile organic compounds as a product of
chemical reactions; the Permittee shall-adhere to the following required work
practices:
i. The Permittee shall store all VOC-containing material not in use (including
waste material)in containers covered with a tightly fitting lid that is free of
cracks, holes, or other defects.
ii. The Permittee shall clean up spills as soon as possible following proper
safety procedures.
iii. The Permittee shall store wipe rags in closed containers. .
iv. The Permittee shall not clean sponges, fabric, wood,paper products, and
other absorbent materials.
V. The Permittee shall drain solvents used to clean supply lines and other
coating equipment into closable containers and close containers immediately
after each use.
Permit No. 04967RI6
Page 5
vi. The Permittee shall clean mixing,blending, and manufacturing vats and
containers by adding cleaning solvent, closing the vat or container before
agitating the cleaning solvent.
vii. The Permittee shall,pour spent cleaning solvent into closable containers and
close containers immediately after each use.
b. As required by 15A NCAC 2D .0958(d), when cleaning parts with a solvent
containing a volatile organic compound,the Permittee shall:
i. flush parts in the freeboard area,
ii. take precautions to reduce the pooling of solvent on and in the parts,
iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for
drying or until all dripping has stopped, whichever is longer,
iv. not fill cleaning machines above the fill line,
V. not agitate solvent to the point of causing splashing.
9. 15A NCAC 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - The
wood furniture manufacturing operations baffle spray booths (ID Nos. 1, 2, 3 and 4), dip
tanks (ID Nos. DT-1, DT-10, DT-11, DT-12, DT-13, DT-14, DT-15, DT-16, DT-2, DT-3,
DT-4,DT-5, DT-6,DT-7, DT-8 and DT-9), dry filter spray booths(ID Nos. 1S, 24S, 25S
and 27S),water cascade spray booths (ID Nos. 11 S, 13S, 15S, 16S,2S and 6S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1) shall comply with all
requirements of 15A NCAC 2D .1111 "Maximum Achievable Control Technology" and 40
CFR Part 63, Subpart JJ "National Emission Standards for Wood Furniture Manufacturing
Operations." [40 CFR 63.800]
Regulated Material Emission Limitation
Thinners 10%by weight HAP
stains, washcoats, sealers,topcoats, basecoats, 1.0 lb VHAP/lb solids, as applied
and enamels
washcoat basecoat or enamel formulated onsite coatings - 1.0 lb VHAP/lb solids
' thinners - 3.0%by weight VHAP
strippable spray booth coatings 0.8 lb VOC per lb solids, as applied
foam contact adhesives used in products which
meet flammability requirements per California
Technical Bulletin 116, 117, or 133,the Business
and Institutional Furniture Manufacturers 1.8 lb VHAP per lb solids, as applied
Association's(BIFMA's) X5.7, UFAC
flammability testing, or any similar requirements
from local, State, or Federal fire regulatory
agencies
Permit No. 04967R16
Page 6
Re ulated Material Emission Limitation
all other contact adhesives 1.0 lb VHAP/solids, as applied
1.0%by weight formaldehyde or 400 pounds
coatings and contact adhesives formaldehyde emissions per rolling 12-month
period
a. Definitions and Nomenclature - For the purpose of this permit condition,the
definitions and nomenclature contained in 40 CFR 63.801 shall apply.
b. Regulated Pollutants -Volatile Hazardous Air Pollutants (VHAPs)and Volatile
Organic Compounds (VOCs) as defined in 40 CFR 63.801.
c. General Provisions -The Permittee shall comply with the requirements of 40 CFR
Part 63, Subpart A "General Provisions," according to the applicability of Subpart A
to such sources, as identified in Table 1 of 40 CFR Part 63, Subpart JJ.
d. Work Practice Standards - The Permittee shall adhere to the work practice standards
as specified by 40 CFR 63.803.
e. Recordkeeping Requirements -The Permittee shall prepare,maintain, and follow a
written work practice implementation plan in accordance with 40 CFR 63.806(e) that
defines environmentally desirable work practices for each wood furniture
manufacturing operation and addresses each of the work practice standards specified
below:
i. Operator Training- in accordance with 40 CFR 63.803(b);
ii. Inspection and Maintenance Plan - in accordance with 40 CFR 63.803(c);
iii. Cleaning and Washoff Solvent Accounting System- in accordance with 40
CFR 63.803(d);
iv. Chemical Composition of Cleaning and Washoff Solvents - in accordance
with 40 CFR 63.803(e);
V. Sprgy Booth Cleaning - in accordance with 40 CFR 63.803(f);
vi. Storage Requirements - in accordance with 40 CFR 63.803(g);
vii. Application Equipment Requirements -in accordance with 40 CFR
63.803(h); Effective November 21, 2014 conventional air spray guns are
allowed only when emissions are vented to a control device;
viii. Line Cleaning -in accordance with 40 CFR 63.803(i);
ix. Gun Cleaning-in accordance with 40 CFR 63.8030);
x. Washoff Operations - in accordance with 40 CFR 63.803(k); and
Permit No. 04967R16
Page 7
xi. Formulation Assessment Plan- in accordance with 40 CFR 63.803(1).
£ Reporting Requirements-The Permittee shall submit the compliance status report to
the Regional Supervisor by January 30 and June 30 of each year in accordance with
40.CFR 63.804(f)(8) and 40 CFR 63.807(b). The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR 63.804(g)(8) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(e) as required and 40 CFR 63.807(a) following the applicability criteria in 40
CFR 63.800(d).
g. Finishing Operations - Per 40 CFR 63.804(a)(4),the Permittee has chosen to use
both the compliant coatings and the facility averaging compliance options for the
finishing operations dry filter spray booths (ID Nos. 27S, 24S, 25S and 1 S), dip
tanks (ID Nos. DT-6, DT-3, DT-12, DT-11, DT-9, DT-1,DT-4, DT-2, DT-10, DT-5,
DT-7, DT-16, DT-8,DT-13, DT-14 and DT-15), baffle spray booths (ID Nos. 2, 3, 4
and 1), water cascade spray booths (ID Nos. 6S, 15S, 16S, 13S, 2S and 11S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1). Compliance with each
of these options is considered a separate ALTERNATIVE OPERATING
SCENARIO (AOS) and the Permittee, contemporaneously with making a change
from one AOS to another, shall record in a log the scenario under which it is
operating. Records shall be retained for five years. [15A NCAC 2Q .0508(p)]
AOS1: Compliant Coatings Option
i. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations dry
filter spray booths (ID Nos. 27S, 24S, 25S and 1S), dip.tanks (ID Nos. DT-6,
DT-3, DT-12, DT-11, DT-9, DT-1, DT-4, DT=2, DT-10,DT-5, DT-7, DT-16,
DT-8, DT-13, DT-14 and DT-15), baffle spray booths (ID Nos. 2, 3, 4 and 1),
water cascade spray.booths (ID Nos. 6S, 15S, 16S, 13S,2S and 11S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1). All thinners,
stains, washcoats, sealers,topcoats, basecoats, and enamels used at the
facility shall meet the emission limitations as detailed in the following table:
Regulated Material Emission Limitation
Thinners 10% by weight HAP
stains, washcoats, sealers,topcoats, basecoats, 1.0 lb VHAP/lb solids, as
and enamels Iapplied
coatings - 1.0 lb VHAP/lb
washcoat, basecoat, or enamel formulated onsite solids
thinners- 3.0%by weight
VHAP
ii. Compliance Procedures and Monitoring Requirements -Emission sources
dry filter spray booths (ID Nos. 27S, 24S, 25S and 1S), dip tanks (ID Nos.
DT-6, DT-3, DT-12, DT-11, DT-9, DT-1,DT-4, DT-2, DT-10, DT-5, DT-7,
DT-16, DT-8,DT-13,DT-14 and DT-15),baffle spray booths (ID Nos. 2, 3,
4 and 1), water cascade spray booths (ID Nos. 6S, 15S, 16S, 13S, 2S and
Permit No. 04967R16
Page 8
11S), gluing operation(ID No. GO-1) and wash-off tank(ID No. WT-1) are
using both non-continuous and continuous coaters. The Permittee shall
demonstrate that only compliant thinners are used and that all stains,
washcoats, sealers,topcoats, basecoats, and enamels, are compliant, as
applied, in accordance with 40 CFR 63.804(g)(2) for non-continuous coaters
and 40 CFR 63.804(g)(3) for continuous coaters.
iii. Compliance Procedures and Monitoring Requirements - Emission sources
dry filter spray booths (ID Nos. 27S, 24S, 25S and 1S), dip tanks (ID Nos.
DT-6, DT-3, DT-12, DT-11, DT-9, DT-1, DT-4, DT-2, DT-10, DT-5, DT-7,
DT-16, DT-8, DT-13, DT-14 and DT-15), baffle spray booths (ID Nos. 2, 3,
4 and 1), water cascade spray booths (ID Nos. 6S, 15S, 16S, 13S, 2S and
11 S), gluing operation(ID No. GO-1) and wash-off tank(ID No. WT-1) are
using non-continuous coaters. The Permittee shall demonstrate that only
compliant thinners are used and that all stains, washcoats, sealers, topcoats,
basecoats, and enamels, are compliant, as applied, in accordance with 40
CFR 61804(g)(2).
iv. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
V. Recordkeeping Requirements - The-Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.804(g)(2)5 40 CFR 63.806(b)(1) and(b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
vi. Reporting Requirements - The Permittee shall submit the compliance stats
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
vii. Reporting Requirements- The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(2) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
AOS2: Facility Averaging Option
viii. Emission Limits- The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(1) as applicable to the finishing operations dry
filter spray booths (ID Nos. 27S, 24S, 25S and 1 S), dip tanks (ID Nos. DT-6,
DT-3, DT-12, DT-11, DT-9, DT-1, DT-4, DT-2, DT-10, DT-5, DT-7, DT-16,
DT-8, DT-13, DT-14 and DT-15),baffle spray booths (ID Nos. 2, 3, 4 and 1),
water cascade spray booths.(ID Nos. 6S, 15S, 16S, 13S, 2S and 11S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1). The weighted
Permit No. 04967R16
Page 9
average VHAP content across all coatings, as applied, shall not exceed 1.0 kg
VHAP per kg solids.
ix. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate that the monthly average VHAP content for all finishing
materials used at the facility is no greater than 1.0 kg VHAP per kg solids, as
applied, in accordance with 40 CFR 63.803(g)(1).
X. Performance Test Method-EPA Method 311 [Appendix A of 40.CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
xi. Recordkeeping Requirements -Permittee shall keep records in accordance
with 40 CFR 63.806(a) following the applicability criteria in 40 CFR
63.800(d), 40 CFR 63.804(g)(1), 40 CFR 63.806(b)(1) and (b)(2), 40 CFR
63.806(c), 40 CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
xii. Reporting Requirements - The Permittee shall submit the compliance status
report to the Regional Supervisor,by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
xiii. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(1) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
h. Cleaning Operations -
i. Emission Limits - The'Permittee shall comply with the limits of 40 CFR
63.802(a)(3) applicable to the strippable spray booth operations dry filter
spray booths (ID Nos. 275, 245, 25S and 1S), dip tanks (ID Nos. DT-6, DT-
3,DT-12,DT-11, DT-9,DT-1, DT-4,DT-2,DT-10,DT-5, DT-7,DT-16,
DT-8, DT-13, DT-14 and DT-15), baffle spray booths (ID Nos. 2, 3, 4 and 1),
water cascade spray booths (ID Nos. 6S, 155, 165, 135, 2S and 11S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1) as detailed in the
following table:
Regulated Material Emission Limitation
strippable spray booth coatings 0.8 lb VOC per lb solids, as applied
ii. Compliance Procedures and Monitoring Requirements - When the emission
source is using foam and other contact adhesives,the Permittee shall
demonstrate that only compliant adhesives are used in accordance with 40
CFR 63.804(g)(5).
Permit No. 04967RI6
Page 10
iii. Performance Test Method -EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements.-The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(3), 40 CFR 63.806(h), 40 CFR
63.806(i), and 40 CFR 63.8060).
V. Reporting Requirements - The Permittee shall submit the compliance status
report to the Regional.Supervisor by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(1)and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
vi. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
i. Contact Adhesive Operations-
i. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(2) and 63.804(b) and (c) as applicable to the contact adhesive
operations dry filter spray booths (ID Nos. 27S, 24S, 25S and 1S), dip tanks
(ID Nos. DT-6, DT-3, DT-12,DT-11, DT-9, DT-1, DT-4, DT-2, DT-10, DT-
5;DT-7, DT-16, DT-8,DT-13, DT-14 and DT-15), baffle spray booths (ID
Nos. 2, 3, 4 and 1), water cascade spray booths (ID Nos. 6S, 15S, 16S, 13S,
2S and 11 S), gluing operation(ID No. GO-1) and wash-off tank(ID No. WT-
I)as detailed in the following table:
Regulated Material EmissionLimitation
foam contact adhesives used in products which meet 1.8 lb VHAP
flammability requirements per California Technical Bulletin per lb solids,
116, 117, or 133, the Business and Institutional Furniture as applied
Manufacturers Association's (BIFMA's)X5.7,UFAC
flammability testing,or any similar requirements from local,
State, or Federal fire regulatory agencies
all other contact adhesives 1.0 lb
HAP/lb
solids, as
-- - applied:.. -
ii. Compliance Procedures and Monitoring Requirements When the dry filter
spray booths (ID Nos. 27S, 24S, 25S and IS), dip tanks (ID Nos. DT-6, DT-
3, DT-12, DT-11, DT-9, DT-1, DT-4, DT-2, DT-10, DT-5, DT-7, DT-16,
Permit No. 04967R16
Page 11
DT-8, DT-13, DT-14 and DT-15), baffle spray booths (ID Nos. 2, 3,4 and 1),
water cascade spray booths (ID Nos. 6S, 155, 165, 135, 2S and 1I S), gluing
operation(ID No. GO-1) and wash-off tank(ID No. WT-1) is using foam and
other contact adhesives. The Permittee shall demonstrate that only compliant
thinners are used and that all stains, washcoats, sealers,topcoats,basecoats,
and enamels, are compliant, as applied, in accordance with 40 CFR
63.804(g)(5)•
iii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(2), 40 CFR 63.806(h), 40 CFR
63.806(i), and 40 CFR 63.8060).
v. Reporting Requirements - The Permittee shall submit the compliance status
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(5)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(5) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
vi. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(5) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a)following the applicability criteria in 40 CFR 63.800(d).
j. Formaldehydequirements - The permittee shall comply with one of the following
two options by November 21, 2014 and thereafter:
i. Option#1 400 pounds formaldehyde limit per rolling 12 month period) -
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and(b),
limit total formaldehyde (Ftotal)use in coatings and contact adhesives
to no more than 400 pounds per rolling 12 month period.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), calculate total formaldehyde
emissions from all finishing materials and contact adhesives used at
the facility using Equation 5 and maintain a value of Ftotal no more
than 400 pounds per rolling 12 month period.
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep records of the formaldehyde content, in
pounds per gallon, as applied, of each finishing material and contact
adhesive subject to the emission limits of 40 CFR 63.802(a) and (b).
Permit No. 04967RI6
Page 12
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR
63.807(c).
ii. Option#2 (CPDS < 1.0%by weight formaldehyde) -
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b), use
coatings and contact adhesives only if they are low-formaldehyde
coatings and adhesives, in any wood furniture manufacturing
operations.Low formaldehyde means, in the context of a coating or
contact adhesive, a product concentration of less than or equal to 1.0
percent formaldehyde by weight, as described in a certified product
data sheet for the material
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), demonstrate compliance by use
of coatings and contact adhesives only if they are low formaldehyde
coatings and contact adhesives maintaining a certified product data
sheet for each coating and contact adhesive used and submitting a
compliance certification with the semi-annual report.
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep a certified product data sheet for each coating
and contact adhesive used.
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR 40
CFR 63.807(c) and 40 CFR 63.804(h). The compliance certification
shall state that low-formaldehyde coatings and contact adhesives, as
applicable, have been used each day in the semiannual reporting
period or should otherwise identify the periods of noncompliance and
the reasons for noncompliance. An affected source is in violation of
the standard whenever a coating or contact adhesive that is not low-
formaldehyde, as demonstrated by records or by a sample of the
coating or contact adhesive, is used. Use of a noncompliant coating or
contact adhesive is a separate violation for each day the noncompliant
coating or contact adhesive is used. The compliance certification shall
be signed by a responsible official of the company that owns or
operates the affected source.
B. GENERAL CONDITIONS AND LIMITATIONS
1. TWO COPIES OF ALL DOCUMENTS REPORTS TEST DATA MONITORING DATA
NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION
REQUIRED BY.THIS PERMIT shall be submitted to the:
Regional Air Quality Supervisor
North Carolina Division of Air Quality
Permit No. 04967RI 6
Page 13
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville,NC 28115
704-663-1699
For identification purposes, each submittal should include the facility name as listed on the
permit,the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT -Any records required by the conditions of this
permit shall be kept on site and made available to DAQ personnel for inspection upon
request. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. These records must be kept on site for a minimum of 2
years,unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION -A new air permit shall be obtained by the Permittee prior to
establishing; building, erecting,using, or operating the emission sources or air cleaning
equipment at a site or location not specified in this permit.
5. REPORTING REQUIREMENT-Any of the following that would result in previously
unpermitted,new, or increased emissions must be reported to the Regional Supervisor,
DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. This permit is subject to revocation or modification by the DAQ upon a determination that
information contained in the application or presented in the support thereof is incorrect,
conditions under which this permit was granted have changed,or violations of conditions
contained in this permit have occurred. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. This permit is nontransferable by the Permittee. Future owners and operators must obtain a
new air permit from the DAQ.
Permit No. 04967RI6
Page 14
8. This issuance of this permit in no way absolves the Permittee of liability for any potential
civil penalties which may be assessed for violations of State law which have occurred prior
to the effective date of this permit.
9. This permit does not relieve the Permittee of the responsibility of complying with all
applicable requirements of any Federal, State, or Local water quality or land quality control
authority.
10. Reports on the operation and maintenance of the facility shall be submitted by the Permittee
to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be
required by the DAQ. Information required in such reports may include,but is not limited
to,process weight rates,firing rates, hours of operation, and preventive maintenance
schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-2.15314B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2),no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. The Permittee must comply with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act(RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - The Permittee shall retain a current copy of the
air permit at the site. The Permittee must make available to personnel of the DAQ,upon
request,the current copy of the air permit for the site.
15. CLEAN AIR ACT SECTION 112(r)REQUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act,then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants- Prevention of
'Accidental Releases -Purpose and General Duty,"although a risk management plan may not
be required,if the Permittee produces,processes, handles, or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
Permit No. 04967RI 6
Page 15
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification,report submittal, and test
results approval
Permit issued this the 13'h of March, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Ronald E. Slack
Regional Air Quality Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 04967RI6
ATTACHMENT to Permit No. 04967RI6, March 13, 2014
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
FEInatural gas fired boiler(10.35 2Q .0102 .
Btu per hour maximum heat input) (c)(2)(B)(ii) Yes Yes
FIES-3 - dry kiln(30,000 board foot capacity) 2Q .0102 ][�F::E
Yes
(c)(2)(E)(i)
---]
IES-4 - dry kiln(30,000 board foot capacity) 2Q .0102 No Yes
(c)(2)(E)(i)
IES-5 -natural gas-fired packaging heat 2Q .0 102
shrink oven(1.00 million Btu per hour (c)(2)(E)(i) Yes Yes
maximum heat input)
IES-6 -natural gas-fired wood finishing 2Q .0102
dryer(1.00 million Btu per hour maximum Yes Yes
heat input) (c)(2)(E)(i)
IES-7 -natural gas-fired wood finishing 2Q .0102
dryer(0.35 million Btu per hour maximum Yes Yes
heat input) (c)(2)(E)(i)
IES-8 -natural gas-fired wood finishing 2Q .0102
dryer (0.80 million Btu per hour maximum Yes Yes
heat input) (c)(2)(E)(i)
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."