HomeMy WebLinkAboutAQ_F_1400008_20221028_PRMT_Permit ROY COOPER � ,s Wl.
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Governor � .
ELIZABETH S. BISER
.secretary
MICHAEL A. ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
October 28, 2022
Mr. John Cahill
CFO and Senior VP
Bernhardt Furniture Company - Plants 2 & 5
1839 Morganton Boulevard
PO Box 740
Lenoir, NC 28645
Subject: Air Permit No. 01755R23
Bernhardt Furniture Company - Plants 2 & 5
Lenoir, Caldwell County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1400008
Dear Mr. Cahill:
In accordance with your completed application received August 8, 2022, we are forwarding
herewith Permit No. 0 175 5R23 to Bernhardt Furniture Company - Plants 2 & 5, Lenoir, Caldwell
County,North Carolina for the construction and operation of air emissions sources or air cleaning
devices and appurtenances. Additionally, any emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an "ATTACHMENT" to the enclosed air permit.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to file a petition for contested case hearing in the North Carolina Office of
Administrative Hearings. Information regarding the right,procedure, and time limit for permittees
and other persons aggrieved to file such a petition is contained in the attached "Notice Regarding
the Right to Contest a Division of Air Quality Permit Decision."
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-
215.11413.
This permit shall be effective from October 28, 2022 until September 30, 2030, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
North Carolina Department of Environmental Quality I Division of Air Quality
DE
Asheville Regional Office 1 2090 U.S.Highway 70 1 Swannanoa,NC 28778
NJFtTH CAFi«t INA "� !!l
oepabMMofEnvimm"awQ"tey 828.296.4500 T 1 828,299.7043 F
Mr. John Cahill
October 28, 2022
Page 2
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
• A condition requiring stack test results from the wood waste/coal-fired boiler (ID No.
ES-515) be submitted by December 31, 2016 has been removed from the permit with
this renewal;
• Emission source ID No. ES-515 will be listed in the permit as a woodwaste-fired boiler
without the option to combust coal; and
• This Permit contains an emissions inventory requirement for the 2029 calendar year as
part of the next renewal in 2030.
Should you have any questions concerning this matter, please contact Amro Ali at 828-296-
4500.
Sincerely,
Brendan G. Davey, P.E., Regional Supervisor
Division of Air Quality, NC DEQ
Enclosures
c: Asheville Regional Office
NOTICE REGARDING THE RIGHT TO CONTEST A DIVISION OF AIR QUALITY
PERMIT DECISION
Right of the Permit Applicant or Permittee to File a Contested Case: Pursuant to NCGS 143-
215.108(e), a permit applicant or permittee who is dissatisfied with the Division of Air Quality's
decision on a permit application may commence a contested case by filing a petition under
NCGS 150B-23 in the Office of Administrative Hearings within 30 days after the Division
notifies the applicant or permittee of its decision. If the applicant or permittee does not file a
petition within the required time, the Division's decision on the application is final and is not
subject to review. The filing of a petition will stay the Division's decision until resolution of the
contested case.
Right of Other Persons Aggrieved to File a Contested Case: Pursuant to NCGS 143-
215.108(e 1), a person other than an applicant or permittee who is a person aggrieved by the
Division's decision on a permit application may commence a contested case by filing a petition
under NCGS 150B-23 within 30 days after the Division provides notice of its decision on a
permit application, as provided in NCGS 150B-23(f), or by posting the decision on a publicly
available Web site. The filing of a petition under this subsection does not stay the Division's
decision except as ordered by the administrative law judge under NCGS 15013-33(b).
General Filing Instructions: A petition for contested case hearing must be in the form of a
written petition, conforming to NCGS 15013-23, and filed with the Office of Administrative
Hearings, 1711 New Hope Church Road, Raleigh NC, 27609, along with a fee in an amount
provided in NCGS 15013-23.2. A petition for contested case hearing form may be obtained upon
request from the Office of Administrative Hearings or on its website at
https://www.oah.nc.gov/hearings-division/filing/hearing-forms. Additional specific instructions
for filing a petition are set forth at 26 NCAC Chapter 03.
Service Instructions: A party filing a contested case is required to serve a copy of the petition,
by any means authorized under 26 NCAC 03 .0102, on the process agent for the Department of
Environmental Quality:
William F. Lane, General Counsel
North Carolina Department of Environmental Quality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
If the party filing the petition is a person aggrieved other than the permittee or permit applicant,
the party must also serve the permittee in accordance with NCGS 15013-23(a).
Additional information is available at https://www.oah.nc.gov/hearin.gs-division/hearing-
process/filing-contested-case. Please contact the OAH at 984-236-1850 or
oah.postmaster@oah.nc.gov with all questions regarding the filing fee and/or the details of the
filing process.
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NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 01755R23
Issue Date: October 28, 2022 Effective Date: October 28, 2022
Expiration Date: September 30, 2030 Replaces Permit: 01755R22
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Bernhardt Furniture Company - Plants 2 & 5
1828 Morganton Boulevard
Lenoir, Caldwell County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1400008
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
Plant 2 woodworking operations consisting of:
ES-WDSP-2 one wood material collection CD-203 one simple cyclone
system installed on woodworking (136 inches in diameter), and
operations CD-219 one bagfilter
(5,767 square feet of filter area)
Plant 2 wood coating and finishing operations consisting of:
ES-SBP-2-226 one baffle type spray booth N/A N/A
(NESHAP)
ES-SBP-2-240 and two dry filter type spray booths
ES-SBP-2-241 N/A N/A
(NESHAP)
ES-SBP-2-271 and two wash off tanks
ES-SBP-2-272 N/A N/A
(NESHAP)
Permit No. 01755R23
Page 2
Emission Emission Source Control Control System
Source ID Description System ID Description
.Plant 5 woodworking operations consisting of:
ES-WDSP-5 one wood material collection _ CD-506, cyclone
system installed on (128 inches in diameter),
woodworking operations CD-507 and
one bagfilter
(4,882 square feet of filter
area)
CD-501 one bagfilter
(4,614 square feet of filter
area)
CD-503 one cyclone
(184 inches in diameter)
Plant 5 wood coating and finishing operations consisting of:
ES-SBP-5-520, eight baffle-type spray booths
ES-SBP-5-521,
ES-SBP-5-522,
ES-SBP-5-523,
ES-SBP-5-524, N/A N/A
ES-SBP-5-525,
ES-SBP-5-526 and
ES-SBP-5-527
(NESHAP)
ES-SBP-5-528 and two dry filter type spray booths
ES-SBP-5-529 located in automated chair leg N/A N/A
(NESHAP) finishing system
ES-SBP-5-530 one drying oven N/A N/A
(NESHAP)
ES-SBP-5-531 one wash off tankJ N/A N/A
(NESHAP)
ES-Glue gluing operations N/A N/A
Boiler operations consisting of:
ES-515 one wood waste-fired boiler(25 T CD-515 multicyclone
million Btu per hour maximum (fourteen 9-inch diameter
heat input) with no fly ash tubes)
reinjection
in accordance with the completed application 1400008.22A received August 8, 2022 including any
plans, specifications, previous applications, and other supporting data, all of which are filed with the
Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part
of this permit.
Permit No. 0 175 5R23
Page 3
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .05049 2D .0512, 2D .0516, 2D .0521, 2D .0535, 2D .0540, 2D .1111 (40 CFR
63, Subpart JJ, Subpart JJJJJJ), 2D .1806, 2Q .0315 and 2Q .0317 (Avoidance).
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit (without
a modification request). The renewal request (with application Form A) should be submitted
to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this
permit, the Permittee shall submit the air pollution emission inventory report (with
Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General
Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ and shall
document air pollutants emitted for the 2029 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0504
"Particulates from Wood Burning Indirect Heat Exchangers," particulate matter emissions
from the wood burning indirect heat exchangers shall not exceed the allowable emission
rates listed below:
Emission Limit
Source (lbs/million Btu)
wood waste-fired boiler
(ID No. ES-515) 0.57
4. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0512
"Particulates from Wood Products Finishing Plants," the Permittee shall not discharge
particulate matter caused by the working, sanding, or finishing of wood without providing,
as a minimum for its collection, adequate duct work and properly designed collectors, or
other such devices as approved by the Commission.
5. SULFUR DIOXIDE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from one
wood waste-fired boiler (25 million Btu per hour maximum heat input) with no fly ash
reinjection (ID No. ES-515) shall not exceed 2.3 pounds per million Btu heat input.
6. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the two dry filter type spray
booths (ID Nos. ES-SBP-2-240 and ES-SBP-2-241), the two dry filter type spray booths
Permit No. 01755R23
Page 4
located in automated chair leg finishing system (ID Nos. ES-SBP-5-528 and ES-SBP-5-529)
and the two wood material collection systems installed on woodworking operations (ID Nos.
ES-WDSP-2 and ES-WDSP-5), manufactured after July 1, 1971, shall not be more than 20
percent opacity when averaged over a six-minute period, except that six-minute periods
averaging not more than 87 percent opacity may occur not more than once in any hour nor
more than four times in any 24-hour period. However, sources which must comply with a
visible emissions standard in 15A NCAC 2D .0524 "New Source Performance Standards" or
.I 110 "National Emission Standards for Hazardous Air Pollutants" shall meet that standard
instead of the 2D .0521 visible emissions standard.
7. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 21)
.0521 "Control of Visible Emissions," visible emissions from the wood waste/coal-fired
boiler (ID No. ES-515) and the nine baffle type spray booths (ID Nos. ES-SBP-2-226 and
ES-SBP-5-520 through ES-SBP-5-527), manufactured as of July 1, 1971, shall not be more
than 40 percent opacity when averaged over a six-minute period, except that six-minute
periods averaging not more than 90 percent opacity may occur not more than once in any
hour nor more than four times in any 24-hour period. However, sources which must comply
with a visible emissions standard in 15A NCAC 21) .0524 "New Source Performance
Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" shall meet
that standard instead of the 2D .0521 visible emissions standard.
8. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
9. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints are received or excessive
Permit No. 01755R23
Page 5
fugitive dust emissions from the facility are observed beyond the property boundaries for six
minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots,
and plant roads (including access roads and haul roads).
10. 15A NCAC 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - The
wood furniture manufacturing operations nine baffle type spray booths (ID Nos. ES-SBP-2-
226 and ES-SBP-5-520 through ES-SBP-5-527), two dry filter type spray booths (ID Nos.
ES-SBP-2-240 and ES-SBP-2-241), three wash off tanks (ID Nos. ES-SBP-2-271, ES-SBP-
2-272 and ES-SBP-5-531), two dry filter type spray booths located in automated chair leg
finishing system (ID Nos. ES-SBP-5-528 and ES-SBP-5-529) and one drying oven (ID No.
ES-SBP-5-530) shall comply with all requirements of 15A NCAC 2D .l I I I "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
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.
Permit No. 01755R23
Page 6
d. Work Practice Standards - The Permittee shall adhere to the work practice standards
as specified by 40 CFR 63.803.
e. Recordkeepi ng Requirements - The Permittee shall prepare, maintain, and follow a
written work practice implementation plan in accordance with 40 CFR 63.806(e) that
defines environmentally desirable work practices for each wood furniture
manufacturing operation and addresses each of the work practice standards specified
below:
i. Operator Training - in accordance with 40 CFR 63.803(b);
ii. Inspection and Maintenance Plan - in accordance with 40 CFR 63.803(c);
iii. Cleaning and Washoff Solvent Accounting System - in accordance with 40
CFR 63.803(d);
iv. Chemical Composition of Cleaning and Washoff Solvents - in accordance
with 40 CFR 63.803(e);
V. Spray Booth Cleaning - in accordance with 40 CFR 63.803(f);
vi. Storage Requirements - in accordance with 40 CFR 63.803(g);
vii. Application Equipment Requirements - in accordance with 40 CFR
63.803(h); Effective November 21, 2014 conventional air spray guns are
allowed only when emissions are vented to a control device;
viii. Line Cleaning - in accordance with 40 CFR 63.803(i);
ix. Gun Cleaning - in accordance with 40 CFR 63.8030);
X. Washoff Operations - in accordance with 40 CFR 63.803(k); and
xi. Formulation Assessment Plan - in accordance with 40 CFR 63.803(1).
f. Reporting Requirements - The Permittee shall submit the compliance status report to
the Regional Supervisor by in accordance with 40 CFR 63.804(f)(8) and 40 CFR
63.807(b). The Permittee shall submit semi-annual reports to the Regional
Supervisor in accordance with 40 CFR 63.804(g)(8) and 40 CFR 63.807(c). The
Permittee shall follow the reporting requirements in 40 CFR 63.807(e) as required
and 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
g. Finishing_Operations - Per 40 CFR 63.804(a)(4), the Permittee has chosen to use the
compliant coatings compliance option for the finishing operations.
i. Emission Limits - The Permittee shall comply with all provision of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations. All
thinners, stains, washcoats, sealers, topcoats, basecoats, and enamels used at
the facility shall meet the emission limitations as detailed in the following
table:
Permit No. 01755R23
Page 7
Regulated Material Emission Limitation
thinners 10%by weight HAP
stains, washcoats, sealers, topcoats, 1.0 lb VHAP/lb solids, as applied
basecoats, and enamels
washcoat, basecoat, or enamel coatings - 1.0 lb VHAP/lb solids
i
formulated onsite thinners - 3.0% by weight VHAP
ii. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate for emissions sources of the finishing operation that only
compliant thinners are used and that all stains, washcoats, sealers, topcoats,
basecoats, and enamels, are compliant, as applied, in accordance with 40
CFR 63.804(g)(2) for non-continuous coaters and 40 CFR 63.804(g)(3) for
continuous coaters, as applicable.
iii. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.804(g)(2), 40 CFR 63.806(b)(1) and (b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
iv. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(1) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
h. Finishing Operations - Per 40 CFR 63.804(a)(4), the Permittee may choose to use
both the compliant coatings and the facility averaging compliance options for the
finishing operations. Compliance with each of these options is considered a separate
ALTERNATIVE OPERATING SCENARIO (AOS) and the Permittee,
contemporaneously with making a change from one AOS to another, shall record in
a log the scenario under which it is operating. Records shall be retained for five
years. [15A NCAC 2Q .0508(p)]
AOSI: Compliant Coatings Option
i. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations. 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, 1.0 lb VHAP/lb solids, as applied
basecoats, and enamels
washcoat, basecoat, or enamel coatings - 1.0 lb VHAP/lb solids
formulated onsite thinners - 3.0% by weight VHAP
Permit No. 01755R23
Page 8
ii. Compliance Procedures and Monitoring Requirements - Emission sources of
the finishing operations are using non-continuous coaters. The Permittee shall
demonstrate that only compliant thinners are used and that all stains,
washcoats, sealers, topcoats, basecoats, and enamels, are compliant, as
applied, in accordance with 40 CFR 63.804(g)(2).
iii. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.804(g)(2), 40 CFR 63.806(b)(1) and (b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
iv. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(2) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
AOS2: Facility Averaging Option
V. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(1) as applicable to the finishing operations. The
weighted average VHAP content across all coatings, as applied, shall not
exceed 1.0 kg VHAP per kg solids.
vi. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate that the monthly average VHAP content for all finishing
materials used at the facility is no greater than 1.0 kg VHAP per kg solids, as
applied, in accordance with 40 CFR 63.803(g)(1).
vii. Performance Test Method - EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
viii. Recordkeeping Requirements - Permittee shall keep records in accordance
with 40 CFR 63.806(a) following the applicability criteria in 40 CFR
63.800(d), 40 CFR 63.804(g)(1), 40 CFR 63.806(b)(1) and (b)(2), 40 CFR
63.806(c), 40 CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
ix. Reporting Requirements - The Permittee shall submit semi-annual reports to
the Regional Supervisor in accordance with 40 CFR 63.804(g)(1) and 40
CFR 63.807(c). The Permittee shall follow the reporting requirements in 40
CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).
i. Cleaning Operations -
i. Emission Limits - The Permittee shall comply with the limits of 40 CFR
63.802(a)(3) applicable to the strippable spray booth operations (NO
EQUIPMENT SELECTED) as detailed in the following table:
Permit No. 01755R23
Page 9
Regulated Material Emission Limitation
strippable spray booth coatings 0.8 lb VOC per lb solids, as
applied
ii. Compliance Procedures and Monitoring Requirements - When the emission
source is using foam and other contact adhesives, the Permittee shall
demonstrate that only compliant adhesives are used in accordance with 40
CFR 63.804(g)(5).
iii. Performance Test Method - EPA Method 311 [Appendix A of 40 CFR Part
631 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 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).
j. Formaldehyde Requirements - The permittee shall comply with one of the following
two options by November 21, 2014 and thereafter:
i. Option#1 400 pounds formaldehyde limit per rolling 12 month period) -
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b),
limit total formaldehyde (Ftotal) use in coatings and contact adhesives
to no more than 400 pounds per rolling 12 month period.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), calculate total formaldehyde
emissions from all finishing materials and contact adhesives used at
the facility using Equation 5 and maintain a,value of Ftotal no more
than 400 pounds per rolling 12 month period.
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep records of the formaldehyde content, in
pounds per gallon, as applied, of each finishing material and contact
adhesive subject to the emission limits of 40 CFR 63.802(a) and (b).
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR
63.807(c).
ii. Option#2 (CPDS < 1.0% by weight formaldehyde) -
Permit No. 01755R23
Page 10
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.
11. GENERALLY AVAILABLE CONTROL TECHNOLOGY - For the one wood waste-fired
boiler (25 million Btu per hour maximum heat input) with no fly ash reinjection (ID No. ES-
515), the Permittee shall comply with all applicable provisions, including the notification,
testing, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .I I 11, as promulgated in 40 CFR 63, Subpart JJJJJJ, " National
Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial,
and Institutional Boilers", including Subpart A "General Provisions."
a. Compliance Requirements - As required by 15A NCAC 2D .l 111, the Permittee
shall comply with the following requirements:
i. General Duty Clause (40 CFR 63.11205(a)) - At all times the Permittee shall
operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with
safety and good air pollution control practices for minimizing emissions.
Permit No. 01755R23
Page 11
ii. Boiler Tune-up (40 CFR 63.11223) - An initial boiler tune-up is required by
March 21, 2014. If the unit is not operating on the required date for a tune-up,
the tune-up must be conducted within thirty days of startup. The Permittee
shall comply with the following with respect to the tune-up:
A. Periodic tune-ups: A biennial tune-up is required and shall be
conducted no more than 25 months after the previous tune-up. The
following units are only required to conduct a tune-up every five
years: seasonal boilers (shutdown for 7 consecutive months or 210
consecutive days each 12-month period due to seasonal conditions;
only biomass or oil), limited-use boilers, and units with oxygen trim
systems, as defined in 40 CFR 63.11237. Each five-year tune-up must
be conducted within 61 months of the previous tune-up.
B. Fuel required for the tune-up: The permittee shall conduct the tune-up
while burning the type of fuel (or fuels in the case of boilers that
routinely burn two types of fuels at the same time) that provided the
majority of the heat input to the boiler over the 12 months prior to the
tune-up.
C. As applicable, inspect the burner, and clean or replace any
components of the burner as necessary. The Permittee may delay the
burner inspection until the next scheduled unit shutdown, but must
inspect each burner at least once every 36 months (72 months for 5-
year tune-ups).
D. Inspect the flame pattern, as applicable, and adjust the burner as
necessary to optimize the flame pattern. The adjustment should be
consistent with the manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio, as applicable, and
ensure that it is correctly calibrated and functioning properly. The
Permittee may delay the air to fuel ratio inspection until the next
scheduled unit shutdown, but must conduct the inspection at least
once every 36 months (72 months for 5-year tune-ups).
F. Optimize total emissions of carbon monoxide. This optimization
should be consistent with the manufacturer's specifications, if
available, and with any nitrogen oxide requirement to which the unit
is subject.
G. Measure the concentrations in the effluent stream of carbon monoxide
in parts per million, by volume, and oxygen in volume percent, before
and after the adjustments are made (measurements may be either on a
dry or wet basis, as long as it is the same basis before and after the
adjustments are made). Measurements may be taken with a portable
CO analyzer.
b. Notification and Reporting Requirements - In addition to the notification and
reporting requirements of the Environmental Protection Agency (EPA), the
Permit No. 0 175 5R23
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Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of
the following:
Compliance Report must be prepared by March 1 of every other year (or
every five years depending on the frequency of the tune-up requirements)
starting March 1 the year following the first periodic tune-up, and submitted
upon request. The report must meet the requirements of 40 CFR
63.11225(b)(1-2).
c. Recordkeeping Requirements - In addition to any other recordkeeping requirements
of the EPA, the Permittee shall maintain the following records as defined under 40
CFR 63.11225(c):
i. Copies of all required notifications.
ii. Maintain the following records to document conformance with the work
practices, emission reduction measures, and management practices:
A. Tune-up records - records must identify each boiler, the date of tune-
up, the procedures followed for tune-up, the manufacturer's
specifications to which the boiler was tuned, and the following:
I. The concentrations of CO in the effluent stream in parts per
million, by volume, and oxygen in volume percent, measured
at high fire or typical operating load, before and after the tune-
up of the boiler.
II. A description of any corrective actions taken as a part of the
tune-up of the boiler.
III. The type and amount of fuel used over the 12 months prior to
the tune-up of the boiler but only if the unit was physically
and legally capable of using more than one type of fuel during
that period. Units sharing a fuel meter may estimate the fuel
use by each unit.
B. A copy the Energy Assessment required by 40 CFR 63.11214(c).
C. Seasonal boilers - For each boiler that meets the definition of seasonal
boiler, you must keep records of days of operation per year.
D. Records of non-waste determinations per 40 CFR 63.11225(c)(2)(ii).
iii. Malfunction Records - Records of the occurrence and duration of each
malfunction of the boiler, or of the associated air pollution control and
monitoring equipment. Records of actions taken during periods of
malfunction to minimize emissions in accordance with the general duty to
minimize emissions in 40 CFR 63.11205(a), including corrective actions to
restore the malfunctioning boiler, air pollution control, or monitoring
equipment to its normal or usual manner of operation.
Permit No. 0 175 5R23
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iv. Record Retention - You must keep each record for 5 years following the date
of each recorded action.
12. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
13. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee, facility-wide
emissions shall be less than the following:
Pollutant
Emission Limit
(Tons per consecutive 12-month period).
PM10 100
VOC 100
individual HAPs 10
j Total HAPs 25
a. Inspection and Maintenance Requirements -
i. Bagfilter Requirements - Particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions of
this permit and ensure that emissions do not exceed the regulated limits, the
Permittee shall perform periodic inspections and maintenance (I&M) as
recommended by the manufacturer. In addition, the Permittee shall perform,
at a minimum, an annual internal inspection of each bagfilter system.
ii. Cyclone Requirements - Particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions of
this permit and ensure that emissions do not exceed the regulatory limits, the
Permittee shall perform, at a minimum, an annual inspection of each cyclone
system. In addition, the Permittee shall perform periodic inspections and
maintenance (I&M) as recommended by the manufacturer.
iii. Multi-Cyclone Requirements - Particulate matter emissions shall be
controlled as described in the permitted equipment list. To comply with the
provisions of this permit and ensure that emissions do not exceed the
regulatory limits, the Permittee shall perform, at a minimum, an annual
internal inspection of the multi-cyclone system. In addition, the Permittee
shall perform periodic inspections and maintenance (I&M) as recommended
by the manufacturer.
b. Recordkeeping Requirements
i. The Permittee shall maintain purchase orders and invoices of materials
containing VOC. These purchase orders and invoices shall be maintained for
Permit No. 01755R23
Page 14
a period of at least three years and be made available to DAQ personnel upon
request.
ii. The Permittee shall record monthly and total annually the facility-wide VOC,
Individual, and Total HAPs emissions.
iii. A log book shall be kept on site for the three bagfilters (ID Nos. CD-219,
CD-501 and CD-507), the three cyclones (ID Nos. CD-203, CD-503 and CD-
506) and one multicyclone (ID No. CD-515), and made available to Division
of Air Quality personnel upon request. The Permittee shall record all
inspection, maintenance and monitoring requirements listed above in the log
book. Any variance from the manufacturer's recommendations shall be
investigated with corrections made and date of actions recorded in the log
book.
c. Reporting Requirements - Within 30 days after each calendar year, regardless of the
actual emissions, the Permittee shall submit the following emissions and/or
operational data listed below. The data should include monthly and 12 month totals
for the previous 12 month period.
i. a report summarizing emissions of VOC and HAPs containing the following:
A. the pounds of VOC used during the previous calendar year;
B. the greatest quantity in pounds of an individual HAP used during the
previous calendar year; and
C. the total pounds of all HAPs used during the previous calendar year.
14. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - In accordance with 15A NCAC 2Q .0317, to comply with this permit
and avoid applicability of 15A NCAC 2D .0530 "Prevention of Significant Deterioration,"
as requested by the Permittee, volatile organic compound (VOC) emissions shall be limited
as follows:
Affected Source(s) Pollutant Emission Limit (Tons Per
Consecutive 12-month Period)
two dry„filter type spray booths VOC,total 40
(ES-SBP-2-240 and ES-SBP-2-241)
Compliance with this regulation is established through the Synthetic Minor recordkeeping
requirements listed in Specific Condition 13 above.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Permit No. 01755R23
Page 15
Regional Supervisor
North Carolina Division of Air Quality
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,NC 28778
828-296-4500
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effectuate 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. CHANGES NOT REQUIRING PERMIT REVISIONS - Pursuant to 15A NCAC 02Q
.0318, changes to the facility that are not exempt pursuant to 15A NCAC 02Q .0102 may be
Permit No. 0 175 5R23
Page 16
allowed without first modifying an applicable air permit if the change(s) meet(s) the
requirements of 15A NCAC 02Q .0318(b)(1) through (b)(5) and the owner or operator
notifies the Director in writing, using forms provided by the Division, seven calendar days
before the change is made. Within 10 business days of receipt of the notice, the Division
shall notify the owner or operator of its determination of whether the change(s) meet(s) the
requirements of 15A NCAC 02Q .0318(b)(1) through (b)(5).
8. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
9. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
10. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
11. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to, process weight rates, firing rates, hours of
operation, and preventive maintenance schedules.
12. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.11413, and 143-215.114C, including assessment of
civil and/or criminal penalties.
13. 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.
14. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act (RCRA) administered by the
Division of Waste Management.
15. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request, the current copy of the air permit for the
site.
16. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permit No. 01755R23
Page 17
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
17. 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.
18. 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. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the 281h of October, 2022.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Brendan G. Davey, P.E.
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 0 175 5R23
ATTACHMENT to Permit No. 01755R23, October 28, 2022
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
____. ,.a_ -... __,_1
.e -_
Regulation TAPS? Pollutants?
IES-BOILER-Natural gas-fired boiler 2Q .0102 Yes Yes
(8.375 million Btu/hr heat input capacity) (h)(1)(B)
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."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here:
https://dcq.nc. o�gpermitconditions