HomeMy WebLinkAboutAQ_F_1900030_20220614_PRMT_Permit ROY COOPER
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ELIZABETH S. BISER
ICHAEL A. ABRACZINSKAS NORTH CAROLINA
Ohr L*& Environmental Quality-
June 14, 2022
Mr. James Gard
Plant Manager
Arclin USA, LLC
790 Corinth Rd
oncure, NC 27559
Subject= Air Permit No. 04162R24
Arclin USA, LLC:
Moncure, Chatham County, North Carolina
Permit Class; Synthetic Minor
Facility ]D# 1900030
Dear Mr. Gard,
In accordance with your completed application received April 4, 2022, we are forwarding
herewith Permit No. 0416 R 4 to Arclin USA, LLC:, Moncure, Chatham County, North Carolina
for the construction and operation of air emissions sources or air cleaning devices and
appurtenances. Additionally, any emissions activities determined from your air permit application
as meeting the exemption requirements contained 1n 15A NC A C 2 Q 0102 have been listed for
information purposes as an "ATTAC HMENT" 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 unuc:eptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt ofthis
permit, identifying the speeIFic issues to be contested. Sucli 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. .
150E-23 of the North Carolina General Statutes, and Filed With the Office 0fAdminl strati ve
Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714, The Form for requesting a formal
adjudicatory hearing may be obtained upon request fro in the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 150B- 3, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
150E- 2, This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless cf a request for informal modification unless a request l'or a hearing is
also inade under G.S. 150B-2 3.
NDrth Carolina Department of Environmental Oualq I Division of Air Quaky
Raleigh R2gionW Office 13800 Bari-0 Drive II Raleigh NC 27609
41 -ipm-
'a� 919.791.4240 T I 919.9.B1.2261 F
Arclin USA, LL
June 14, 2022
Page 2
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 June 14, 2022 until May 31, 2030, 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 applieaxtion, Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
Permit renewed with new expiration date and C Y 202 81rmission Inventory criteria in the
updated condition 2D. 0202-
« Updated General Conditions to include 2Q .031 S,
Should you have any questions concerning this matter, please contact Abdul Kadir at 9 1.9-791-42 97.
Sincerely,
Taylor Hartsfield, E1T, CPM, Regional Supervisor
Division of Air Quality, NC DE
A
Enclosures
c: Raleigh Regional Office
FORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PF..Rl1'1IIT N . 04162R24
Issue Date. June 14, 2022 Effective Date; June 14, 2022
Expiration Date: May 31, 2030 Replaces Permit, 0416 R 3
To construct and operate air emission sources) 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 2 1 B of Chapter 143, General Statutes of North Carolina (NC' S) as amended, and other
applicable Laws, RUIeS and Regulatiorts,
Arclin USA, LLE
790 Corinth Road
oncure. Chatham County, North Carolina
Permit Class: Synthetic Minor
Facility 1D4 1900030
(the Perinittee) 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
pure ID Description ; System 1D Description
Methanol-Formaldehyde Conversion Plant No.1 ( F-1)
ES-A-i formaldehyde absorption system CD-1. regenerative thermal oxidizer
Methanol-Formaldehyde Conversion Plant No.2 (MF-2)
ES-A-2 (iVSP ) absorber column (M-F plant no. 2)
CD-2 thermal oxidiser
ES-A-3 (NSP ) InWorber column (M-F plant no. 2)
Resin Kettles -- — — -----
E -K-I resin kettle with a vapor condense/system
ES-K-2 Iresin kettle with a vapor condenser system
ES- -3 resin kettle with a vapor condenser system p_
-ES- -4 ;resin kettle with a vxpt�r ct�ndenser s m regenerative thermal oxidizer
yste
ES-K-5 resin kettle with a vapor Condenser system
ES-K-6 es in kettle with a vapor condenser systeni
Loading and Unloading Operations
FES-TR-I formaldehyde truck loading and unloading area
ES-PIC-1 phenol and caustic railcar unloading area i
- CD-1 regenerative thermal oxidiser
ES-RC-3 methanol unloading formaldehyde loading railcar i
area
ES-P-5 urea vacuum unloading system NIA 1. NIA
ES-U I vacuum urea unloading system j CD-BH-U I bagfiiter(635.6 square Feet of filter area)
E -U2 vacuum urea unloading system tot -13H-U2, -bagfilter(635-6 square Feet of filter area)
ES-RCC-I (NSPS)Irail car clq�aiiing operation
-= CD-1 regenerative thermal oxidizer
ES-RCC-2 (NSPS),rail ear loading operation
Permit No- 0416 R 4
Page
Emission Emission Source Control Control System
Source [D Description System 1D Description
_ Miscellaneous Sources
ES-FUG Fugitive emissions from MF.-2 Plant N'A tJ/A
Solid [taw Material Storage
- -E - B-I salt bin CD-BH-7 bagfilter(125 square feet of filter area)
ES- T-I.'2 urea weigh tank CD-BH-1 -2 hagfiI1cr(59 -9 square feet of filter area)
ES- T-3 urea weigh tank CD-13H-3 bagfiIter(602 square feet of filter area)
ES-WT-5'6 urea weigh tame CD-BH-5 r6 ba¢fi Iter(598-9 square feet of filter area)
ES-MtS-6 melamine storage silo (100 ton storage capacity) -CD-BH-6 bagfilter(165 square feet of filter area)
F Storage Tanks
urea formaldehyde storage tank(50,000 gallon --- -
storage Capacity)
ES-M-14 formaldehyde storage tank (10,000 gallon storage
capacity)
ES- -15 urea-formaldehyde pre-polymer storage tank
(250,000 gallon capacity) CD-I regenerative thermal oxidizer
E 1++1-]6 urea tbrmaidehyde polymer storage tank(250,000
gallon storage capacity)
ES-M-17 formaldehyde storage tank (125,000 gallon storage
capacity)
ES-M-18 formaldehyde storage tank (125,000 gallon storage
Capacity) _
ES- -20 urea formaldehyde resin storage tank(50,000 N(A —
Ilon storage-capacity) NIA
ES- -21 urea formaldehyde resin Storage tank(50,000 N/A NIA
gallon storage capacity)
urea formaldehyde resin storage tank(50,000 I
gallon storage capacity)
urea formaldehyde resin storage tank(50,000
ES- -23 N/A N)A
gallon storage capacity) i
25 urea formaldehyde resin storage tank(50,000 NIA NIA
ES-
gallon storage capacity) A
urea formaldehyde resin storage tank(50,000
ES- -26 gallon storage capacity) f lY/l NIA
urea formaldehyde resin storage tank(50,0D0
ES-M-27 — -I N/A NIA. ---� gallon storage capacity} I _-
ES-M-28 urea formaldehyde resin storage tank(27,DD0 N/A NIA
gallon storage capacity)
urea formaldehyde resin storage tank(27,{}00 w I
ES- -29 gallon storage capacity} {' "
urea formaldehyde resin storage tank(22,000 —
ES- -30 gallon storage capacity) -T
lYlA Rl'A
ES- -31 phenol storage tank(50,000 gallon storage CD-1 regenerative thermal oxidizer
_ -capacity) --t --
-- ES-M-34 methanol storage tank (500,000 gallon storage NIA N.A
capacity)
ES-M-35 phenol formaldehyde resin storage and/or glycerin NIA N:A
-storage tank (13,000 gallon storage capacity)
Permit No. 041 2R24
Page 3
Emission Emission Source Control Control System
Source ID Deseription System ID Description
urea formal&hyde n sin sturap tank(20.000
E - -36 gallon storage capacity) WA KA
urea formaldehyde resin storage tank (17.500
ES-M-37(NSPS) gallon storage capacity) � lx!!A N.A
area formaldehyde resin storage tank (17,500
ES- -39{NSPS) gallon storage tank) NIA N:A
ES- -45(NSPS) area or phenol - folTnaldehyde resin storage tank NIA N/A
(23.000 gallon storage capacity)
ES- -46 (NSPS) urea or phenol-formaldehyde resin storage tank [CIA N/A
(23,000 gallon storage opacity)
ECM-49 (NSPS) urea or phenol-formaldehydc resin sturageti tank NIA NIA(30,000 gallon gallon storage capacity)
E M-50 (NSPS) lures or phenol-formaldehyde resin storage tank N/A — -� NIA -
1(30,000 gallon storage capacity)
urea or phenol-formaldehyde resin storage tank N/A NIA
ES-M-S] (NSPS)
E(30,000 gallon storage capacity)
ES-M-52 (NSPS) 'urea or phenol-Formaldehyde resin storage tank NIA NIA
(30,000 gallon storage capacity)
urea or phenol-formaldehyde resin storage tank
ES-M-53 (NSPS) NIA NIA
�(23,000 gallon storage capacity)
Brea or phenol-formaldehyde resin storage tank
ES-M-54 (NSPS) : NIA NIA
(30,000 gallon storage capacity)
ES-M-55 (NSPS) urea or phenol-formaldehyde resin storage tank WA NIA
(30,000 gallon storage capacity)
ES- -56(NSPS) urea or phenol-formaldehyde resin storage tank NIA NIA
(33,000 gallon storage capacity)
2S-M-57(NSPS) urea or phenol-
formaIdehyde resin storage tank NIA NIA
1(30,000 gallon stooge capacity)
ES-M-58 (NSPS) urea or phenol-formaldehyde resin storage tank NIA N/A ------
(33,000 gallon!Oorage capacity)
ES-M-59(NSPS) urea or phenol-formaldehyde resin storage tank NIA NIA
.(33,000 gallon storage capacity)
ES-M-6! phenol fonnaldehyde storage tank(15,000 gallon — —
storage capacity) CD-I regenerative thermal oxidizer
ES-M-63 urea formaldehyde storage tank(19,000 gallon
.storage tank)
jE - -64(NSPS) urea or phenol formaldehyde resin storage tank NIA WA(35,000 gallon storage capacity)
E5= -65(NSPS) urea or phenol formaldehyde resin storage tank N/A N!A
:(35,000 gallon storage capacity) _ - -
ES-M-66 (NSPS) urea or phenol-formaldehyde resin storage tank NIA WA
(34.000 gallon storage capacity)
ES-M-67 (NSP ) urea or phenol-formaldehyde resin storage tank NIA N/A
�(34,000 gallon storage capacity)
E -M-68 ([NSPS) Brea or phenol-formaldehyde resin storage tank N.A NIA
1(34,000 gallon storage capacity)
i urea or phenol-formaldehyde resin storage tank
E -M-69 ([ASPS) (34,000 gallon storage capacity) N'A N!A
ES-M-7U (NSPS) urea or phenol-Formaldehyde resin storage tank A NIA
(34,000 gallon storage capacity)
Permit Na 041 2R24
Page 4
- Emission Emission Source Control Control System
Source ID Description System ID Description J
ES-M-71 (NSPS) urea or phenol-formaldehyde resift storage tank N'A N A
(34,000 gallon storage capacity)
ES-M-72 (NSPS) urea or phenol-formaldehyde resin storage tank NSA
(34,000 gallon storage capacity)
ES-M-73 (NSPS) urea or phenol-formaldehyde resin storage tank ' � �
(34,000 gallon storage capacity) J
ES-M-74 (NSPS) urea or phenol-formaldehyde resin storage tank 1 NIA NIA
(34,000 gallon storage capacity)
ES-M-75 (ASPS) urea or phenol-formaldehyde resin storage tank NIA --NIA
(27.500 gallon storage capacity)
F. -M-76 (NSPS) urea or phenol Formaldehyde resin storage tank WA NIA
(27,500 gallon storage capacity)
ES-M-77 (NSPS) urea or phenol-formaldehyde resin storage tank NIA NIA
(41,000 gallon storage capacity)
ES-M-78 (NSP ) Phenol storage tank(41,454 ¢aIIon storage CD-1 regenerative thermal oxidizer
.capacity)
ESM-94 ([ASPS) methanol distillate storage tank(20,000 gallon NIA NIA
storage capacity) _
E -M-95 (NSPS) �nethanoi distillate storage tank (20,000 gallon NSA NIA
Storage capacity)
E -99 (NSPS) formaldehyde resin Jwashwater storage tank N/A NIA
1(20,000 gal]on storage capacity) J
IES- -100(NSPS) lformaldehyde storage tank(75,000 gallon storage
Icapacity)
.fo
ES M ]01 (NSPS) rmaldehyde storage tank(75,000 gallon storage
icapacity) CD-1 regenerative thermal oxidizer
ES-M-102 (NSPS) formaldehyde storage tank(75,000 gallon storage
1capacity)
I ES-M-103 (NSPS) formaldehyde storage tank(75,000 gallon storage J
1capacity)
in accordance with the completed application 1900030,22A received April 4, 2022 including any
plans, specifications, previous applications, and other supporting data, all or which are filed with the
Department of Environmental Quality, Division of Air Quality (DA and are incorporated as part
of this permit-
This permit is subject to the following specified conditions and limitations including any
TESTING- REPORTING- DR MONITOR[NG 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 its 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, 2.D -0515, 2D -0521, 2D .0524 (40 CFR 60, Subparts III, VV and Kb), 2D .0535,
2D ,0 5 40, 2D .0611, 2D 0948, 2 D .0949, 2,D .1100, 2D .1806, 2D . 100, 2 Q .0102,
.0315 and 2 .0317 (Avoidance).
Permit No. 041 2f2 4
Page 5
1 PERMIT RENEWAL AND EMISSION IN FNTORY REOUTRE ENT - The Permittee.
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordarce with 15 A NCAC 2Q .0304(d) and (f). Pursuant to I SA NCAC 2
.0203(i), no permit application fee is required for renewal of an existing air perinit (without
a modification request). The renewal request (with application Form A) should be submitted
to the Regional Supervisor, DA _ Also, at least 90 days prior to the expiration date of this
pp,rrnit. the Perrnittee 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 21 .65. The report shall be submitted to the Regional Supervisor, DAQ and shall
document air pollutants emitted for the 2028 calendar year.
3. PARTICULATE CONTROL RJEOUIRE ENT - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the emission sources shall not exceed allowable emission rates. The allowable emission rates
arse. as defined in 1 5A NCAC 2D .0 1 5, a function of the process weight rate and shall be
determined by the following equation(s), where P is the process throughput rate in torts per
hour(tons/hr) and E is the allowable emission rate in pounds per hour (lbs.qu).
E = 4.10 * (P) 116' for P <= 30 tonslhr, or
E = 55 * (P) ° " - 40 for P >30tonsihr
4. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC: 2D
,05 21 "Control of V isible Emissions," visible emissions 1`rom the emission sources,
manufacIared 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 its any 24-hour
period, However, sources which must comply with a visible emissions standard in 15A
N CAC 2 D .0524 "New Source Performance Standards" or .I 1 10 "National Emission
Standards for Hazardous Air Pollutants" shall meet that siandayd instead nr the 2.D -05 21
visible emissions standard,
5_ 15A N AC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For the
methanol-formaldehyde conversion plant (ID No. IMF-2) consisting of two formaldehyde
absorbers (ID Nos. E S-A-2 and ES-A-3)t the Permittee shall comply with all applicable
provisions, including the notification, testing, reporting, record keeping, and monitoring
requirements contained in Environmental Management Commission Standard 15 A N C A C
2D .0524. "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60,
Subpart III [Standards of Performance for Volatile Organic Compound VO ) Emissions
From the Synthetic Organic Chemical Manufacturing Industry (SOC;MI) Air Oxidation Unit
Processes], and including Subpart A "General Provisions".
a, NSPS Emissions Limitations - As required by 15A NCAC 2D ,0524 and 40 CFR
Part 60.612, the following permit limits shall not be exceeded;
L The thermal oxidiser (ID No_ D-2) installed on the lormaldehyde absorbers
QD Noss, ES- -2 and ES- -3) shall reduce emissions of total organic
compounds or TOO (minus methane and ethane) by 9 8 weight percent or to a
TOO (minus methane and ethane) concentration of 2 0 ppmv on a dry basis
corrected to 3 percent oxygen, whichever is less stringent.
?erinit No, 04162R24
Page
b. NSPS Monitoring of Emissions and Operations - As required by 15A NCAC 2D .0524
and 40 C FR Part 60,61'a, the following requirements shall be met:
i. The Permittee shall install, calibrate, maintain, and operate according to
manufacturer's specifications the following equipment,
, A temperature monitoring device equipped with a continuous recorder
and having an accuracy of plus or minus one percent of the temperature
being monitored expressed in degrees Celsius, or plus or minus 0.5
degrees Celsius, whichever is greater,
B. A flaw indicator that provides a record of vent stream flow to the
incinerator at least once every hour for each affected facility, The flow
indicator shall be installed in the vent stream from each affected facility
at a point closest to the inlet of the incinerator and before being joined
with any other vent stream.
c. N PS Reporting and Recordkeeping f eauireinents - As required by 15A NCAC 2D
,0524 and 40 CFR Part 60.615, the following requirements shall be met:
i. The Pemiittee shall keep up-to-date, readily accessible records of the
following data measured during each performance test, and also include the
following data in the report of the initial performance test required under 40
CFR Part 60.8.
A_ The average temperature of the firebox measured at least every 15
minutes and averaged over the same time period of the performance
testing.
B. The percent reduction of TO determined as specified in 40 C FR Part
60.614(b) achieved by the incinerator, or the concentration of TOC
(ppmv, by compound) determined as specified in 40 CFR Part
60,614(b) at the outlet of the control device on a dry basis corrected to
3 percent oxygen,
ii. The Permittee shall keep up-to-date, readily accessible continuous records of
the equipment operating parameters specified to be monitored under 40 CFR
Part 0. 13(a) as well as up-to-date, readily accessible records ol'periods of
operation during which the parameter boundaries established during the most
recent performance test are exceeded. The Regional Supervisor, DA , may
at any time require a report ol`these data. For the incinerator, the periods of
operation during which the parameter boundaries established during the most
recent performance test are exceeded are defined as follows:
A. All 3-hour periods of operation during which the average combustion
temperature is more than 28 degrees C 50 degrees F) below the
average combustion temperature daring the most recent performance
test at which compliance with 40 CFR Part 60. 12(a) was determined.
Permit Nal 0416 R 4
Page 7
iii_ The Permittee shall keep up-to-date, readily accessible records of all periods
when the vent stream is diverted from the control device or has no flow rate.
iv. The Permittee shall submit to the Regional Supervisor, DA , semiannual
reports of the following information as spec fled in 40 CFR Part 60, 150)_
A. E ceedances of monitoring parameters recorded above in paragraph
c.ii above, and in 44 CFR fart 60.615(c).
B. All periods recorded above in paragraph 6ii above, and in 40 CFR
Part 60. 15(d), when the vent stream is diverted from the control
device or has no flow rate.
6, l SA NCA D .05 24 "N E W SOURCE PERFORMANCE STANDARDS" - For the
equipment in the process unit described as the methanol-formaldehyde conversion plant (ID
No. MF- ), the Permittee shall comply with all provisions, including the notification,
testing, and monitoring requirements contained in Environmental Management Commission
Standard 1 A NC AC 2 D .05 24 "New Source Performance Standards" (NS?S) as
promulgated in 40 C F R 60, Subpart V V, Standards of Performance for Equipment Leaks in
the Synthetic Organic Chemicals Manufacturing Industry_
a, Standards - The Permittee shall comply with the requirements of the leak standards
in 60.4 -1 through 60A8 -10 as applicable for all equipment in the affected facility.
The Permittee may elect to comply with the alternative standards for valves in
60.483-1 and 2 and?or request a determination of equivalence o f a means ofemissi0n
limitation as provided in 60,484,
b. Recordkeeping RNuirements - The Permittee shall comply with the recordkeepilig
requirements in 0.48 (a) through (h).
Affected facilities applying for exemptions from this subpart per 60.480(d) must
comply with the recordkeeping requirements in 60.48 (i).
All records shall be kept in a log in a readily accessible location.
c. Reporting Requirements - The Permittee shall submit semiannual reports to the
Regional Supervisor, Division of Air Quality.
All semiannual reports shall include a summary oI'the recordkeeping requirements
detailed in 60A86-
If electing to comply with the provisions in 6 0 A 3-1 and 60.483- , the Permittee
shall Notify the Regional Supervisor, Division of Air Quality, of the alternative
standard selected 90 days before implementing either of'the provisions,
Permit No. 0416 R 4
Page 8
7_ 15A NCAC 2D .05246NEW SOURCE PERFORMANCE STANDARDS" - For the storage
tanks listed in the table below. the Permittee shall comply with all applicable provisions,
including the notification, testing, reporting, record kecping, and monitoring requirements
contained in Environmental Management Commission Standard 15A NC AC 2D .05 24,
mew Source Performance Standards" (NSP ) as promulgated in 40 C FR 60. Subpart Kb,
including Subpart A "General Provisions."
a_ Recordkeeping Requirements - Per 40 CFR 60.1 l b a and (b), the Permittee shall
keep records showing the dimension of each storage vessel and an analysis showing
the capacity ol'each storage vessel readily accessible for the life of the source.
No. ID No. No. ID No. No. ID No. No. ID No.
l ES- -37 11 ES-M-55 2.1 ES-M-69 31 ES- -94
ES-M-3 12 ES- -56 22 ES- -70 32 ES- -95
3 ES-M-45 13 ES- -57 2.3 ES- -71 33 ES- -99
4 ES, -46 14 ES- -58 2.4 ES- -72 34 ES- -100
5 ES-M-49 15 ES- -59 25 ES- -73 35 ES- -101
6 ES- -50 16 ES- -64 26 ES-M-74 36 E -M-102
7 ES-M-51 17 ES- - 5 27 ES- -75 37 ES-M-103
8 ES- -52 is ES- -66 28 ES-M-7
9 ES- -53 19 ES- -67 29 E -M-77
10 1 ES- -54 20 ES-M- 8 30 ES-M-78
8, NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for snore than four hour 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 iminediately when the corrective measures have
been accomplished.
This reporting requirement does not alto%v the operation of the facility in excess of
Environmental Management Commission Regulations.
Permit No. 04162R 4
Page 9
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 dusk emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. if substantive complaints are received or excessive
fugitive dust emissions from the Facility are observed beyond the property boundaries for six
minutes in any one hour (using Reference Method 22 in 40 C FR, 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 prueess
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_ FA B R TC FILTER R EQU IRE MENTS including cartridge filters, baghouses, and other dry
filter particulate collection devices - As required by 15A N C AC 2D .06 11, 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 Permitter
shall perform, at a minimum, an annual (for each 1 -month period Foliowirig the
initial inspection) internal inspection of each particulate collection device system. In
addition. the Permittee shall perform periodic inspections and maintenance as
recommended by the equipment manufacturer.
b_ Rec:ordkeeping Requirements - The results of All inspections and Wiy variance from
manufacturer's recommendations or from those given in this permit (when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shal I be recorded in the logbook_
The logbook (in written or electronic: format) shall be kept on-site and made
available to DAQ personnel upon request,
11, VOC EMISSIONS FROM TI AN S FER 0PE RATION S - As required by 15A NCAC 2D
.0948 WOC Emissions from Transfer Operations." the Permittee shall not load in any one
day more than 20,000 gallons of volatile organic compounds with a vapor pressure of 1.5
pounds per square inch or greater under actual conditions into any tarok-truck, trailer or
railroad tank car from any loading operation unless the loading operation uses submerged
loading through boom loaWers that extend clown into the compartment being loaded or by
other methods that are at least as efficient based on source testing or engineering
calculations.
12, STORAGE OF MISC ELLANEOUS VOLATILE ORGANIC: COMPOUNQS - As required
by 15A NC:AC: 2D .049 "Storage of Miscellaneous Volatile Organic Compounds," the
Permitter shall not place, store, or hold in any stationary tank, reservoir. or other container
with a capacity greater than 50,000 gallons, any liquid volatile organic compound that has a
vapor pressure of 1,5 pounds per square inch or greater under actual storage conditions
unless such tank, reservoir, or other container:
a. is a pressure tank capable of maintaining working pressures sufficient at all times to
prevent vapor gas loss into the atmosphere; or
Permit No. 04162R 4
Page 10
b_ is designed and equipped with one of the following vapor loss control devices:
i, a floating pontoon, double deck type floating roof or internal pats type
floating roof equipped with closure seals to enclose any space between the
cover's edge and compartment wall; this control equipment shall not be
permitted for volatile organic compounds with a vapor pressure of l I.O
pounds per square inch or greater under actual storage conditions; all tank
gauging or sampling devices shall be gas-tight except when tank gauging or
sampling is taking place;
ii, a vapor recovery sstein or other equipment car means of air pollution control
that reduces the emission of organic materials into the atmosphere by at least
90 percent by weight; all tank gauging or sampling devices shall be gas-tight
except when lank gauging or sampling is taking place.
I I TOXIC AIR POLLUTANT EMI S S I ONS LIMITATION AND P EPORTIIV
REQUIREMENT - Pursuant to I5A NC;AC 2 D .11fl0 "C;ontrol of Toxic Air PolIutants." and
in accordance with the approved application for an air toxic compliance demonstration, the
following perinit limits shall not be exceeded:
Formaldehyde Phenol -
Emission Sources Emission Limits Emission Limits
(pouncig per hour ounds per hour
Regenerative thermal oxidizer(ID No. D-1) 4.33 5.62
The rmaloxidizer(IDNo. D_-2) 3.28 N/A
ES-M-45, 46 and 53 5.74E-05 (each) 2.84E-03 (each)
ES-M-49, 50,51, 52, 54, 55 and 57 6.74E-05 (each) 3.34E-03 (each)
ES-M-56, 58 and 59 7,45E-05 (each) 3.69E-03 (each)
ES-M-64 and 65 7.37E-05 (each) 3.65E-03 (each)
ES-M-66 through 71 8.39E-05 (each) 4.16E-03 each)
ES-M-99 _ 1.81 E-06 3.12E-03
CS-M-72 and 73 6.36E-03 (each) 3.28E-03 (each)
ES-M-74 9.29E-05 4.46E-03
ES-M-75 and 76 6,61E-03 (each) .3,28E-03 (each)
ES-M-77 9.00IE-05 4.46E-03
ES-M-78 NA 0.004
E -M-20, 21,22,23,25,26 and 27 3.43E-06(each) 5.90E-03 (each)
ES-M-28 and 29 2,02E-06(each) 3.47E-03 (each)
i ES-M-30 1.75E-06 3,02E-03
E S-M-36 5.28E-05 2,79E-03
Phenol forinaldehyde resin storage tank 1D No_ ES- -35 4.1 E-05 2,03E-02
Urea forma WA de resin stvra a tanks E -h4-37 and 39 4.69E-05 (each) 2.4$E-03 each
a. C)nerations restrictions - To ensure emissions do not exceed the 1inlitations above,
the following operating restrictions (scenarios) shall apply during control device(s)
maintenance downtime. All sources at facility may operate as requested in the
application during control device(s) maintenance downtime except as described
below;
Ferinit No. 04162R24
Nags l 1
Scenario A Scenario B -1 Scenario Scenario D Scenario E
RTO down RTO down RTO down
(O%DRE) (Oo.aDRE) RTO in operation RTO in operation (O%DRE)
operating at gas operating at gas at gas flow of at gas flow of�}���acfm �*��� acfm operating at gas
flow of 6,000 flaw of 6,000 6,000 acfmium) 6,00(inin racfmuni) flow of 6,000
acfm (minimum) actin(minimwn) acfm (mi11iinkun)
TO down TO down TO down
(exhausting TO in operation (exhausting TO in operation (exhausting
through bypass at gas flow of through bypass at gas flow of through bypass
stack) with gas 26,201 acfm stack) with gas 26,201 acfm stack) with gas
flow of 7,324 (minimum) flaw of 7.324 (minimum) flow of 7.324
acfm minimum acfm minimum acfm minimum
Only one OF Qnly one OF Gnly one t_JF Only one OF Six kettles in
resin kettle in resin kettle in resin kettle in resin kettle in operation, not
operation during operation during operation during operation during during the
the vacuum step the vacuum-q(Bp the vacuums the Vacuum ste vacuum 5tc
Plant MF-I not in Plant F-I not in
operation operation - - -
b. Recordlceeping Requirements - During periods of control device(s) maintenance
downtime, the Pemitttr shall record,
i. The flow rates to the [PTO and TO hourly;
ii. The number of process kettles producing urea-Formaldehyde resin operating
in the vacuum strip step;
Records in i. And ii. shall be recorded in a log book. The logbook (in written or
electronic form) shall be kept on-site and made available to DAQ personnel upon
request
14. CONTROL AND PRDI-IIBITION OF ODOROUS EMISSIONS - As required by ISA
NCAC 2 D .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,
15_ 40 CFR Part 68 "A CiDFNTAL RELEASE PREVENTION RFOUIRF.MENTS, RISK
MANAGEMENT PROGRAMS UNDER THE CLEAR] AIR ACT, SECTION 1 l (r)" - The
Perniittee shall comply with all applicable requirements in accordance with 40 CFR Part 68
including submitting a Disk Management Plan to EPA pursuant to 40 C:HR 68.150 or as
specified in 40 CFR 68.10I
16, Federal Rulc Applicable to Source Exempted li-om Air Permitting Requirements - Your
Facility i subject to the following federal rule which is applicable to an emission source at
your facility listed on the "lnsignificant.`Exr_mpt Activities" list attached to this permit. The
purpose of this permit condition is to inform you of your compliance obligations to this
applicable rule as it is enforceable.
40 C FR 63 - NESHAP' ACT -- Subpart ZZ Z -- Slat ionary+ Rmiprocating Internal
Combustion Engines
Permit No. 04162R24
Page 12.
IT LIMITATION TO AVOID ]SA NCAC 20 .0501 - Pursuant to 15A N AC 2 .0315
"Synthetic Mirror Facilities," to avoid the applicability of 15 A NCAC 2 Q 0541 "Purpose cal'
Section and Requirement for a Permit," as requested by the Permittee. facility-wide air
pollutant emissions shall be less than the amounts tabulated below per consecutive 12-month
period.
Pollutant Emission Limit
tons per consecutive 12-monthperiod)
Volatile Organic Compounds (VO ) 100 tons
Carbon Monoxide ( 0) 100 tons
Formaldehyde and Methanol 10 tons, each
Total Hazardous Air Pollutants (HAP) 25 tons, total
a, Operations restrictions - To ensure emissions do not exceed the limitations above, the
following restrictions shall apply:
i. Facility-wide VO . CO, formaldehyde, methanol, and total HAP emissions shall
be controlled by the regenerative thermal oxidizer (ID No. CD-1) and thermal
oxidizer(ID Flo. CD-2) as described in the equipment list with downtime
allowances as described in section (d)(v) below.
b. l ecordkeeping, Requirements - The Permittee shall record monthly and total annually
the following:
i. Facility-wide VO , CO, formaldehyde, nethanol and total HAP emissions_
The Permittee shall keep each record on file for a minimum of three years,
c. Renorting requirements - Within 30 days after each calendar year, regardless of the
actual emissions, the Permittee shall submit the following to the Regional Supervisor,
DA , in writing:
i, Monthly and total annual facility-wide VO , CO, formaldehyde, methanol and
total HAP emissions l'or the previous 12 months.
d. Regenerative Thermal Oxidizer (RTO) and Thermal Oxidizer (TO)_Requirements -
Facility-wide VOC:. CO, formaldehyde, methanol and total HAP emissions shall be
controlled by the WfO {11) No. C:D-1) and TO (ID No. C D-2) as described in the
equipment list with downtime allowances as described in paragraph (d)(v) below,
i. Inspection and Maintenance Requirernents - To comply with the provisions of
this permit and erasure that emissions do not exceed the regulatory limits, the
Permittee shall perform periodic inspection and maintenance (]&.M) as
rccornmended by the manufacturer. As a minimum, the Permittee shall perform
an annual internal inspection of the primary heat exchanger and associated
inletibutlet valves to ensure structural integrity.
Permit No. 041 2R24
Page 13
ii. Recordkeeping Requirements - The results of all inspections and any variance
from manufacturer's recommendations or from those given in this permit (where
applicable) shall be investigated with corrections made and dates of actions
recorded in a logbook. Records of all maintenance and monitoring activities
shall be recorded in the logbook. The logbook (in written or electronic form)
shall be kept on-site and made available to DAQ personnel upon request.
iii. RTO Monitoring Requirements - The Permittee shall ensure the proper
performance of the RTO ID No. CD-1) by monitoring the following operational
parameters;
A_ The Permittee shall record the maximum temperature measured inside the
unit but in the second half of the RTO (away from the flame zone) monthly.
The allowable range is between 1,400 and 1,700 degrees Fahrenheit,
B. The Permittee shall record the gas flo rate to the RTO daily. The maximum
allowable flo rate is 1 1,800 standard cubic feet per minute, except during
periods ol`RTD maintenance downtime,
iv, TO Monitorinp,, requirements - The Permittee shall ensure the proper
performance of the T (ID No. CD-2) by monitoring the following operational
parameters:
, The Permittee shall record the maximum temperature measured inside the
unit but in the second half of the TO (away from the flame zone) montlily,
The ininimuni temperature is 1,280 degrees Fahrenheit.
B. The Permittee sha11 record the gas f low rate to the TO daily. The maximum
allowable 11OWTale is 11 A 14 standard cubic feet per minute, except during
periods of TO maintenance downtime.
V. RTO and TO Downtime Allowance - As requested by the Permittee, emission
sources listed in the permit equipment list control led by the RTO (1D No. CD-I)
or TO (1D No_ D-2) may operate uncontrolled according to the conditions listed
below. This provision for operation cf emission sources without their associated
control equipment is limited only to satisfying maintenance requirements of the
RX0 acid/or -1-0 However, under no circumstances shall facility-wide emissions
exceed the Synthetic Minor limitations set forth above,
A. Control Device Douistime Recordkeeping Re uirements - The Permittee
shall keep records of the dates and number of hours for each maintenance
downtime of the RTC and;'or the TO- Included with these records shal l be
calculations for emissions resulting frorn each RTO and/or TO downtime and
12-month facility-wide totals for the Synthetic Minor pollutants (VOO, CO,
formaldehyde, niethanol and total HAP emissions).
B_ Control Device Downtime Reporting Requirements - The Pennittee shall
provide a written report to the Regional Supervisor, Division of Air Quality,
within 7 days of conclusion of each control device maintenance downtime,
Permit No. 04162R 4
Page 14
This report shall contain a summary of all RTO andlor TO maintenance
downtime over the previous twelve- month period and calculations showing
Iaeility-wide emissions of all Synthetic Minor pollutants over the previous
1 -month Period.
18. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - In accordance with 15A NC AC 2Q .0317, to comply with this permit
and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant
Deterioration," as reyucsled by the Permittee, emissions shall be limited as follows:
!Affected Sources) ,Pollutant Emission limit (Tons Per Consecutive 12-month Period)
Co 100
Facility Wide C too
Permit No. 041621124
Page 15
U. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S_ 143-215,10#{c)(1}, TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA. NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTI4ER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the, -- -
Regional Super-visor
North Carolina Division of Air Quality
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 2.7609
919-791-42.00
For identification purposes, each submittal should include the facility name as listed on the
hermit, the IaciIIty identification number, and the permit number.
. R-.CORDS RETENTION RE UIREMENT - In accordance with 15A N C AC 2 D .0 05,
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 he 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 speciFled,
3, ANNUAL FEE PAYMENT - Pursuant to 15A NC AC 2 Q 0203(a), the Perm 1ttee shall pay
the annual permit fee within 30 days of being billed by the DA , 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 NC AC 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 iii
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2 .0309, any of the
Fallowing that would result in previously unpermitted, new. or increased emissions must be
reported to the regional Supervisor, DA ,
a, changes in the information submitted in the application regarding facility emissions:
b_ changes that modify equipment car processes of existing permiued Iaciiitim. 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 Iirnitations specified herein,
6. In accordance with 15A NCAC 2 Q 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
Permit No. 04162R 4
Page 16
accordance with G,S. 143-215,108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that wil I 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 t 5A NCAC 02Q
A31 , changes to the facility that are not exempt pursuant to 15A NCAC 42Q .0 102 may be
allowed without first modifying an applicable air permit if the change(s) meet(s) the
requirements of I5A NCAC 02Q M 18(b)(I) 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) meets) the
requirements of I SA NC AC 02Q .0318(b)(1) through b (5)-
8. In accordance with G.S. 143-215.10 (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. 143-215.10 (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)(I), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements cif any Federal, Mate, or Local
water quality or land quality control authority,
I I. In accordance with 15 A 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 DQ. 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 Perm ittee to enforcement
pursuant to G.S- 14 3-2 15.114A, 143-2 15.114B, and 143- 15.114C;, including assessment of
civil and`or criminal. penalties,
13. Pursuant to North Carolina Cieneral Statute 143-215.3(a)( ), no person shall refuse entry or
access to any authorized repr senlalive 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 (1 RA) administered by the
Division of Waste Management.
Permit No. 04162F24
Page 17
15. PERMIT RETENTION RE0UIREMENT - In accordance with 15A NC:AC: 2Q ,0110, the
Permittee shall retain a current copy of the air hermit at the site. The Permittee must make
mailable to personnel of the DA , upon request, the current copy of the air permit for the
site,
16, CLEAN Alit ACT SECTION 1 I2REQUIREMENTS - Pursuant to 15A NC,AO 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 US EPA in accordance with 40 CFR Part
6 .
17. PREVENTION TION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 1 l (r)(1) of the Clean Air Act. "Hazardous Air PolIulants - Prevention of
Accidental Releases - Purpose and General Duty," although a risk management plan may not
be required, if the Perniittei� produces, processes, handles, or stores any ainount of a listed
hazardous substance, the Permittcc 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 EMISSION S TESTIiVQ AND RE PORT rN Q REQUIREMENTS - Ifernissiorns
testing is required by this permit, or the DAB, or if the Permimm sijbmits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance, the Permittee
shall perform such testing in accordance with 15 NC AC 2D ,2600 and follow all DA
procedures including protocol approval, regional notification, report submittal, and test
results approval. Additionally, in accordance with 15A NCAC: 21) .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the 141h ofJune, 022.
NORTH C;AROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
e- qhA�Z_ a
Taylor Harts€field, FIT, OPM
Regional Supen isor
By Authority of the Environmental Management Commission
Air Permit No. 04162R24
ATTACH 1ENT to Permit No, 041621 24, June 14. 2022
Insignificant/ ExempI Activities
Source Exemption Source of Source of Title
Regulation TAM Pollutants`
IES- -40 - potassium hydroxide storage tank 2Q 0102 (g)(4) No Yes
(10,000 gallon storage capacity)
IES- -96 - diesel fuel storage tank (2,000 .010 (g)(4) Yes Yes
gallon capacity)
IES- L - Quality control laboratory .0102 (g)(3)(B) Yes Yes
IS-B-I - natural gas-fired boiler (25 million 2 .0102 (h)(l)(A) yes Yes
Btu per hour maximum heat input rate) _
IS-B-2 - natural gas-fired boiler (20.08 million .010 (h)(1)(A) Yes Yes
Btu per hour maximum heat input rate)
IES-FP-1 - diesel-fired fine pump (255
horsepower) (NESHAP Subpart ) 2 .0102 (h) I 1 0 No
1. Because an activity is exempted from being required to have a permit ur permit modification
does not mean that the ntivily is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
. When applicable, emissions from stationary source activities identified above shall be
included in deterininiug compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "C'ontroI. of Toxic Air Pollutants" or 2Q 0711 "Emission Fates
requiring a Permit."
Sample permit conditions showing the regulatory requirements for exempt sources subject to
NE HAP, NSPS, and NCAC rules may be found here,
https:''deg7 i1c. ko� y'_':agpermiteonditions