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HomeMy WebLinkAboutAQ_F_0200005_20220826_PRMT_Permit ROY COOPER ^sTAr 2 Governor a ELIZABETH S. BISER � Secretary MICHAEL A.ABRACZINSKAS H NC7RTH CAROLINA Director Environmental Quality August 26, 2022 Mr. Rick Ashley Operations Manager Mitchell Gold Company 135 One Comfortable Place Taylorsville,NC 28681 Subject: Air Permit No. 02815RI5 Mitchell Gold Company Hiddenite, Alexander County,North Carolina Permit Class: Small Facility ID#0200005 Dear Mr. Ashley: In accordance with your completed application received July 11, 2022, we are forwarding herewith Permit No. 02815R15 to Mitchell Gold Company, Hiddenite, Alexander County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information purposes as an"ATTACHMENT" to the enclosed air permit. 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- 215.114B. This permit shall be effective from August 26, 2022 until July 31, 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 Division of Air Quality Mooresville Regional Office 1 610 East Center Avenue,Suite 301 Mooresville,NC 28115 nrr<;,rlmei,tm[m rom nml aiO'ty 704.663,1699 T ( 704.663.6040 F Rick Ashley August 26, 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): ® The following conditions were removed since the boiler has been removed from the permit: o 15A NCAC 2D .0503, "Particulates from Fuel Burning Indirect Heat Exchangers" o 15A NCAC 2D .0516, "Sulfur Dioxide Emissions from Combustion Sources" o 15A NCAC 2D .0524, (40 CFR Part 60, Subpart Dc) o Avoidance of 15A NCAC 2D .1111, "Maximum Achievable Control Technology" (40 CFR 63 Subpart JJJJJJ) ® Condition 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions"was added to the permit per DAQ policy. ® A condition 2Q .0102 for"Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements"was added to indicate that an exempt source is subject to NESHAP, Subpart CCCCCC. ® Based on the potential emissions for VOCs and HAPs, this facility will be reclassified from a Prohibitory Small to a Small facility; therefore, stipulation 2Q .0803 will be deleted from the permit. Should you have any questions concerning this matter, please contact Jennifer Manning at 704-235- 2224. Sincerely, Melinda Wolanin, Regional Supervisor Division of Air Quality, NC DEQ JAM Enclosures c: Mooresville Regional Office https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00005/R 15_PERMIT.doex 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(el), 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 littps://Nvww,oali.nc.gov/hearings-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. Page intentionally left blank. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY AIR PERMIT NO. 02815R15 Issue Date: August 26, 2022 Effective Date: August 26, 2022 Expiration Date: July 31, 2030 Replaces Permit: 02815R14 To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other applicable Laws, Rules and Regulations, Mitchell Gold Company 375 Sharpe Lane Hiddenite, Alexander County,North Carolina Permit Class: Small Facility ID#0200005 (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: Emission ' Emission Source Control Control System Source ID Description System ID Description wood furniture finishing operation consisting of ES-SBl (NESHAP), ;nine(9) dry filter-type spray ES-SB2(NESHAP), booths ES-SB3 (NESHAP), ES-SB4(NESHAP), ES-SBS (NESHAP), N/A N/A ES-SB6(NESHAP), ES-SB7(NESHAP), 4 ES-SB8(NESHAP), i ES-SB9(NESHAP) - ES-WTl (NESHAP), 'two (2) washoff tanks ES WT2(NESHAP) N/A N/A ES GO(NESHAP) gluing operation N/A N/A in accordance with the completed application 0200005.22A received July 11, 2022 including any plans, specifications,previous applications, and other supporting data, all of which are filed with the Permit No. 02815R15 Page 2 Department of Environmental Quality, Division of Air Quality(DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D .0202, 2D .0512, 213 .0521, 2D .0535, 2D .0540, 2D .I 111 (40 CFR 63, Subpart JJ), 2D .1806 and 2Q .0102, 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 .0512 "Particulates from Wood Products Finishing Plants," the Permittee shall not discharge particulate matter caused by the working, sanding, or finishing of wood without providing, as a minimum for its collection, adequate duct work and properly designed collectors, or other such devices as approved by the Commission. 4. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from washoff tank (ID No. ES- WT2), spray booth(ID No. ES-SB5), spray booth(ID No. ES-S138), spray booth(ID No. ES-S139) and gluing operation(ID No. ES-GO), manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six- minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with a visible emissions standard in 15A NCAC 2D .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. Permit No. 42815R15 Page 3 5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from washoff tank (ID No. ES- WTI), spray booth (ID No. ES-SB1), spray booth(ID No. ES-S132), spray booth(ID No. ES-SB3), spray booth(ID No. ES-S134), spray booth(ID No. ES-S136) and spray booth(I ) No. ES-SB7), 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 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. 6. 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. 7. 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 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). Permit No. 02815RI5 Page 4 "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). 8. 15A NCAC 2D .I I I I "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - The wood furniture manufacturing operations washoff tank(ID No. ES-WTI), washoff tank (ID No. ES-WT2),spray booth (ID No. ES-SB1), spray booth (ID No. ES-SB2), spray booth(ID No. ES-SB3), spray booth(ID No. ES-SB4), spray booth (ID No. ES-SB5), spray booth(ID No. ES-SB6), spray booth(ID No. ES-SB7), spray booth (ID No. ES-SB8), spray booth(ID No. ES-SB9) and gluing operation (ID No. ES-GO) shall comply with all requirements of 15A NCAC 2D .1 111 "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 __ W�_ W. __ . �._�. . . _____.___.__ __- ._. - �. _.._ -- g--------------- Thinners Thinners 10%b weight HAP _ �... _ w:-... ._: _................_ stains, washcoats, sealers,topcoats, basecoats, and enamels; 1.0 lb VHAP/lb solids, as applied . _ _. 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 Association's (BIFMA's) X5.7, 1.8 lb VHAP per lb solids, as applied UFAC flammability testing, or any similar requirements t 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 coatings and contact adhesives pounds formaldehyde emissions per rolling 12-month period a. Definitions and Nomenclature - For the purpose of this permit condition, the definitions and nomenclature contained in 40 CFR 63.801 shall apply. b. Regulated Pollutants -Volatile Hazardous Air Pollutants (VHAPs) and Volatile Organic Compounds (VOCs) as defined in 40 CFR 63.801. c. General Provisions - The Permittee shall comply with the requirements of 40 CFR Part 63, Subpart A"General Provisions," according to the applicability of Subpart A to such sources, as identified in Table 1 of 40 CFR Part 63, Subpart JJ. d. Work Practice Standards - The Permittee shall adhere to the work practice standards as specified by 40 CFR 63.803, Permit No. 02815RI5 Page 5 e. Recordkeeping Requirements - The Permittee shall prepare, maintain, and follow a written work practice implementation plan in accordance with 40 CFR 63.806(e) that defines environmentally desirable work practices for each wood furniture manufacturing operation and addresses each of the work practice standards specified below: i. Operator Training- in accordance with 40 CFR 63.803(b); ii. Inspection and Maintenance Plan - in accordance with 40 CFR 63.803(c); iii. Cleaning and Washoff Solvent Accounting System - in accordance with 40 CFR 63.803(d); iv. Chemical Composition of Cleaning and Washoff Solvents -in accordance with 40 CFR 63.803(e); V. 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 both the compliant coatings and the facility averaging compliance options for the finishing operations washofftanks (ID Nos. ES-WT2 and ES-WTI), spray booths (ID Nos. ES-SB5,ES-SB6, ES-SB4, ES-SB7, ES-SB2, ES-SBI, ES-SB9, ES-SB8 and ES-SB3) and gluing operation (ID No. ES-GO). Compliance with each of these options is considered a separate ALTERNATIVE OPERATING SCENARIO (AOS) and the Permittee, contemporaneously with making a change from one AOS Permit No. 02815RI5 Page 6 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 washoff tanks (ID Nos. ES-WT2 and ES-WTI), spray booths (ID Nos. ES- SB5, ES-SB6, ES-SB4, ES-SB7, ES-SB2, ES-SB1, ES-SB9, ES-SB8 and ES-SB3) and gluing operation(ID No. ES-GO). All thinners, stains, washcoats, sealers, topcoats,basecoats, and enamels used at the facility shall meet the emission limitations as detailed in the following table: . _. ...... . Regulated Material Emission Limitation Regulated r Thinners 10%by weight HAPmm stains, washcoats, sealers,topcoats,basecoats, and enamelsl.0 lb VHAP/lb solids, as applied coa washcoat,basecoat, or enamel formulated onsite tings 1 0 lb HAP/lb solids V Ethmners 3 0/o by weight VHAP .._ _ .._.. . ii. Compliance Procedures and Monitoring Requirements - Emission sources washoff tanks (ID Nos. ES-WT2 and ES-WTI), spray booths (ID Nos. ES- SB5, ES-SB6, ES-SB4, ES-SB7, ES-SB2, ES-SB1,ES-SB9, ES-SB8 and ES-SB3) and gluing operation (ID No. ES-GO) are using both non- continuous and continuous coaters. The Permittee shall demonstrate that only compliant thinners are used and that all stains,washcoats, sealers, topcoats, basecoats,and enamels; are compliant, as applied, in accordance with 40 CFR 63.804(g)(2) for non-continuous coaters and 40 CFR 63.804(g)(3) for continuous coaters. ill. Performance Test Method-EPA Method 311 [Appendix A of 40 CFR Part 63] shall be used to determine the VHAP content of liquid coatings in accordance with 40 CFR 63.805(a). IV. Recordke ping 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(1), and 40 CFR 63.8060). V. Reporting Requirements -The Permittee shall submit the compliance stats report to the Regional Supervisor by in accordance with 40 CFR 63.804(0(7) and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR 63.807(c). The Permittee shall follow the reporting requirements in 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d). S Permit No. 02815RI5 Page 7 AOS2: Facility Averaging Option vi. Emission Limits - The Permittee shall comply with all provisions of 40 CFR 63.802(a)(1) and 63.804(a)(1) as applicable to the finishing operations washoff tanks (ID Nos. ES-WT2 and ES-WT1), spray booths (ID Nos. ES- SB5, ES-SB6, ES-SB4, ES-SB7, ES-SB2, ES-SB1, ES-SB9, ES-SB8 and ES-S133) and gluing operation (ID No. ES-GO). The weighted average VHAP content across all coatings, as applied, shall not exceed 1.0 kg VHAP per kg solids. vii. Compliance Procedures and Monitoring Requirements - The Permittee shall demonstrate that the monthly average VHAP content for all finishing materials used at the facility is no greater than 1.0 kg VHAP per kg solids, as applied, in accordance with 40 CFR 63.803(g)(1). viii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part 63] shall be used to determine the VHAP content of liquid coatings in accordance with 40 CFR 63.805(a). ix. Recordkeeping Requirements - Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d),40 CFR 63.804(g)(1), 40 CFR 63.806(b)(1) and(b)(2), 40 CFR 63.806(c),40 CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060). X. Reporting Requirements -The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7) and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR 63.807(c).The Permittee shall follow the reporting requirements in 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d). h. Cleaning Operations - i. Emission Limits The Permittee shall comply with the limits of 40 CFR 63.802(a)(3) applicable to the strippable spray booth operations washoff tanks (ID Nos. ES-WT2 and ES-WTI), spray booths (ID Nos. ES-SB5, ES- SB6, ES-SB4, ES-SB7, ES-SB2, ES-SBI, ES-SB9, ES-SB8 and ES-SB3) and gluing operation(ID No. ES-GO) as detailed in the following table: Regulated Materia Emission Limitation strippable spray booth coatings 0.81b 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 Permit No. 02815RI5 Page 8 demonstrate that only compliant adhesives are used in accordance with 40 CFR 63.804(g)(5). iii. Performance Test Method - EPA Method 311 [Appendix A of 40 CFR Part 63] shall be used to determine the VHAP content of liquid coatings in accordance with 40 CFR 63.805(a). iv. Recordkeeping Requirements - The Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(3), 40 CFR 63.806(h), 40 CFR 63.806(i),and 40 CFR 63.8060). V. Reporting Requirements - The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7) and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 63.804(g)(1) and 40 CFR 63.807(c). The Permittee shall follow the reporting requirements in 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d). i. Contact Adhesive Operations - i. Emission Limits -The Permittee shall comply with all provisions of 40 CFR 63.802(a)(2) and 63.804(b) and (c) as applicable to the contact adhesive operations washoff tanks (ID Nos. ES-WT2 and ES-WTI), spray booths(ID Nos. ES-SB5, ES-S136, ES-S134, ES-SB7, ES-S132, ES-S131, ES-S139, ES- S138 and ES-S133) and gluing operation(ID No. ES-GO) as detailed in the following table: Regulated Material Emission Limitation :foam contact adhesives used to products which meet flammability requirements 1.8 lb VHAP per California Technical Bulletin 116, 117, or 133, the Business and Institutional per lb solids, as Furniture Manufacturers Association's (BIFMA's) X5.7,UFAC flammability applied testing, or any similar requirements from local, State, or Federal fire regulatory agencies ;all other contact adhesives 1.0 lb VHAP/lb solids, as 1,applied ii. Compliance Procedures and Monitoring Requirements -When the washoff tanks (ID Nos. ES-WT2 and ES-WTI), spray booths (ID Nos. ES-S135, ES- S136, ES-SB4, ES-S137, ES-SB2, ES-SB1, ES-SB9, ES-SB8 and ES-S133) and gluing operation (ID No. ES-GO) is using foam and other contact adhesives. The Permittee shall demonstrate that only compliant thinners are Permit No. 02815RI5 Page 9 used and that all stains, washcoats, sealers, topcoats, basecoats, and enamels, are compliant, as applied, in accordance with 40 CFR 63.804(g)(5). iii. Performance Test Method -EPA Method 311 [Appendix A of 40 CFR Part 63] shall be used to determine the VHAP content of liquid coatings in accordance with 40 CFR 63.805(a). iv. Recordkeeping Requirements - The Permittee shall keep records in accordance with 40 CFR 63.806(a) following the applicability criteria in 40 CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(2), 40 CFR 63.806(h), 40 CFR 63.806(i),and 40 CFR 63.8060). V. Reporting Requirements -The Permittee shall submit the compliance status report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(5) and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 63.804(g)(5) and 40 CFR 63.807(c),The Permittee shall follow the reporting requirements in 40 CFR 63.807(a)following the applicability criteria in 40 CFR 63.800(d). j. Formaldehyde Requirements - The permittee shall comply with one of the following two options by November 21, 2014 and thereafter: i. Option#1 (400 pounds formaldehyde limit per rolling 12 month period) - A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b), limit total formaldehyde (Ftotal)use in coatings and contact adhesives to no more than 400 pounds per rolling 12 month period. B. Compliance Procedures and Monitoring Requirements - In accordance with 40 CFR 63.804(h), calculate total formaldehyde emissions from all finishing materials and contact adhesives used at the facility using Equation 5 and maintain a value of Ftotal no more than 400 pounds per rolling 12 month period. C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b), the Permittee shall keep records of the formaldehyde content, in pounds per gallon, as applied, of each finishing material and contact adhesive subject to the emission limits of 40 CFR 63.802(a) and(b). D. Reporting Requirements -The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 63.807(c). Permit No. 02815R15 Page 10 ii. Option#2(CPDS < 1.0%by weight formaldehyde) - A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b), use coatings and contact adhesives only if they are low-formaldehyde coatings and adhesives, in any wood furniture manufacturing operations.Low formaldehyde means, in the context of a coating or contact adhesive, a product concentration of less than or equal to 1.0 percent formaldehyde by weight, as described in a certified product data sheet for the material. B. Compliance Procedures and Monitoring_Requirements - In accordance with 40 CFR 63.804(h), demonstrate compliance by use of coatings and contact adhesives only if they are low formaldehyde coatings and contact adhesives maintaining a certified product data sheet for each coating and contact adhesive used and submitting a compliance certification with the semi-annual report. C. Recordkeeping Requirements In accordance with 40 CFR 63.806(b), the Permittee shall keep a certified product data sheet for each coating and contact adhesive used. D. Reporting Requirements -The Permittee shall submit semi-annual reports to the Regional Supervisor in accordance with 40 CFR 40 CFR 63.807(c) and 40 CFR 63.804(h). The compliance certification shall state that low-formaldehyde coatings and contact adhesives, as applicable, have been used each day in the semiannual reporting period or should otherwise identify the periods of noncompliance and the reasons for noncompliance. An affected source is in violation of the standard whenever a coating or contact adhesive that is not low- formaldehyde, as demonstrated by records or by a sample of the coating or contact adhesive, is used. Use of a noncompliant coating or contact adhesive is a separate violation for each day the noncompliant coating or contact adhesive is used. The compliance certification shall be signed by a responsible official of the company that owns or operates the affected source. 9. 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. Permit No. 02815R15 Page 11 10. Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements -Your facility is subject to the following federal and state rules: £40 CFR 63 -NESHAP/GACT -- Subpart CCCCCC -- Gasoline Dispensing Facilities 40 CFR 63 -NESHAP/GACT -- Subpart ZZZZ -- Stationary Reciprocating ;Internal Combustion Engines which are applicable to some of the emission sources at your facility listed on the "Insignificant/Exempt Activities" list attached to this permit. The purpose of this permit condition is to inform you of your compliance obligations to these applicable rules as they are enforceable. 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: Regional Supervisor North Carolina Division of Air Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville,NC 28115 704-663-1699 For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number. 2. RECORDS RETENTION REQUIREMENT - 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. Permit No. 02 815R 15 Page 12 4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 2Q .0301, anew 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 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. Permit No. 02815R15 Page 13 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 21) .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, 143-215.114B, 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 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. Permit No. 02815R15 Page 14 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 26th of August, 2022. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Melinda Wolanin Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 02815R15 ATTACHMENT to Permit No. 02815R15, August 26, 2022 Insignificant/Exempt Activities Source Exemption Source of Source of Title V Regulation = TAPs? Pollutants? .. w.._...:: ..... DIES-1 - diesel-fired pump(220 hp) for the fire ;suppression system(subject to NESHAP 12Q .0102 (h)(5) I Yes Yes :Subpart ZZZZ) ................................. I-GAS - gasoline storage tank(600 gallon E capacity) subject to NESHAP Subpart 12Q .0102 (g)(4) I No No CCCCCC 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: ht s://dec.nc.g_ov/agpermitconditions