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HomeMy WebLinkAboutAQ_F_1800365_20210714_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Corning Optical Communications,LLC-HMTC NC Facility ID 1800365 Inspection Report County/FIPS:Catawba/035 Date: 07/14/2021 Facility Data Permit Data Corning Optical Communications,LLC-HMTC Permit 06409/R20 1164 A 23rd Street SE Issued 2/2/2018 Hickory,NC 28602 Expires 1/31/2026 Lat: 35d 42.7074m Long: 8ld 17.5590m Class/Status Small SIC: 3357/Nonferrous Wire Drawing/Insulating Permit Status Active NAILS: 335921 /Fiber Optic Cable Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Steve Street Ahmed Koilakh Steve Street Senior EHS Coordinator Plant Manager Senior EHS Coordinator (828)901-6695 (828)901-5699 (828)901-6695 Compliance Data Comments: Inspection Date 07/14/2021 Inspector's Name Donna Cook Inspector's Signature: `904um eaak VM Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: C711512C21 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 1.23 --- --- 33.17 --- 1.23 804.50 2012 --- --- --- 30.60 --- --- 1693.05 *Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Corning Optical Communications,LLC—HMTC July 14,2021 Page 2 Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: X Date submitted for initial review 07/15/2021 _IBEAM WARNING/OB,NOD,NOV,NRE X IBEAM Document X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint X IBEAM Planning,Next Inspection Date 07/01/2023 Directions: From Mooresville Regional Office to Hickory,travel via Statesville Avenue;North Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte Highway (Highway 21 North and Highway 115 North); Interstate 77 North; Exit 5 1-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 126-US 70/Hickory/Newton;turn right off exit ramp onto McDonald Parkway SE; and then immediately take the next street to the right onto 23rd Street SE. The driveway for Corning Optical Communications,LLC—HMTC is located on the left. The street address of this company is 1164 23'Street SE. It is recommended that the facility contact be phoned prior to leaving the office due to the security entry procedures. Safety Equipment: The inspector will have to show a driver license at the security entrance in order to gain access to this facility. The inspector will not be allowed to wear lanyards.No photography,recording devices, or cell phones are allowed in the facility. This company requires that the inspector wear steel- toed shoes, safety glasses, safety vest, and hearing protection at this facility. A face covering is required to be worn by all employees and visitors at this facility due to the ongoing coronavirus pandemic. I wore a face covering during the on-site inspection of this facility. Safety Issues: The inspector should be cautious of forklifts at this facility. The facility requires all employees and visitors to wear face coverings due to the ongoing coronavirus pandemic. I also completed a health questionnaire as required by this company prior to entering this facility. Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site indicates the facility's location is accurate and matches the facility's latitude and longitude coordinates listed in IBEAM. No changes to the latitude and longitude coordinates of this facility are needed in IBEAM. The latitude and longitude coordinates of this facility are locked in IBEAM. Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by Mr. Steve Street, senior environmental health and safety(ehs) coordinator. I changed the email address of Mr. Street in IBEAM. 1. General Information: The purpose of this site visit was to conduct a routine air quality inspection. This facility manufactures indoor and outdoor fiber optic cable for the telecommunication industry. This company operates this facility 24 hours per day, 7 days per week, 52 weeks per year. Mr. Steve Street, senior environmental health and safety (ehs) coordinator, and Mr. Dalton Kaylor, environmental and safety(ehs)technician, accompanied me during this inspection. Corning Optical Communications,LLC-HMTC July 14,2021 Page 3 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Street. No changes are needed in IBEAM. 3. Compliance history file review: No problems have been noted in the last five years by DAQ prior to this inspection. The current compliance status is discussed in the following sections. 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control Control System Source ID Description FSystem ID Description P101,P102,P103,P104, painting process 1 consisting P 105,P 106,P 107,P 108, of seventy-two(72)painting P 109,P 110,P 111,P 112, lines (ID Nos. P 101 through P113,P114,P115,P116, P172) P 117,P 118,P 119,P 120, P121,P122,P123,P124, P125,P126,P127,P128, P129,P130,P131,P132, P133,P134,P135,P136, N/A N/A P137,P138,P139,PI40, P141,P142,P143,P144, P 145,P 146,P 147,P I48, P149,P150,P151,PI52, P153,P154,P155,P156, P157,P158,P159,P160, P 161,P 162,P 163,P 164, P 165,P 166,P 167,P 168, P169,P170,P171,P172 The compliant coatings are applied in the painting process 1. The routine cleaning applications are also conducted on the painting process 1. Any emissions from isopropyl alcohol(IPA)and acetone are fugitive. However,the emission sources on the painting process I have fume hoods that are located above the emission sources and exhaust outside of this facility. Observed.The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 1 were less than the 72 permitted painting lines.No visible emissions were observed by me from the painting process 1. No odors were detected by me from the painting process 1. P301,P302,P303,P304, painting process 3 consisting P305,P306,P307,P308, of eighteen(18)painting P309,P310,P311,P312, lines (ID Nos. P301 through N/A N/A P313,P314,P315,P316, P318) P317,P318 The compliant coatings are applied in the painting process 3. The maintenance cleaning and repair applications are also conducted on the painting process 3.Any emissions from isopropyl alcohol Corning Optical Communications,LLC-HMTC July 14,2021 Page 4 (IPA),acetone, and methyl ethyl ketone(MEK) are fugitive. However,the emission sources on painting process 3 have fume hoods that are located above the emission sources and then exhaust outside of this facility. Observed.The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 3 were less than the 18 permitted painting lines.No visible emissions were observed by me from the painting process 3. No odors were detected by me from painting process 3. P0322,P0323,P0324, painting process 4 consisting P0325,P0326,P0327, of twenty(20)painting lines P0328,P0329,P0330, (ID Nos. 0322 through P0331,P0332,P0333, P0341) N/A N/A P0334,P0335,P0336, P0337,P0338,P0339, P0340,P0341 The compliant coatings are applied in the painting process 4. The maintenance cleaning applications are also conducted on the painting process 4. Any emissions from isopropyl alcohol (IPA),acetone,methyl ethyl ketone(MEK) and methyl isobutyl ketone(MIBK) are fugitive. However,the emission sources on painting process 4 exhaust to a filter system(manufacturer, Neuderman)located inside of this facility and then it exhausts outside of this facility. Observed.The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 4 were less than the 20 permitted painting lines.No visible emissions were observed by me from the painting process 4. No odors were detected by me from painting process 4. P701,P702,P703,P704, painting process 7 P705,P706,P707,P708, consisting of forty(40) P709,P710,P711,P712, painting lines(ID Nos. P701 P713,P714,P715,P716, through P740) P717,P718,P719,P720, N/A N/A P721,P722,P723,P724, P725,P726,P727,P728, P729,P730,P731,P732 P733,P734,P735,P736 P737,P738,P739,P740 The compliant coatings are applied in the painting process 7. The maintenance cleaning applications are also conducted on the painting process 7. Any emissions from methyl ethyl ketone (MEK)are fugitive. However,the emission sources on painting process 7 have fume hoods that are located above the emissions and exhaust outside of this facility. Observed. The compliant coatings and cleaning applications were operational at the time of the inspection. I observed that the emission sources on the painting process 7 were less than the 40 permitted painting lines. No visible emissions were observed by me from the painting process 7. No odors were detected by me from painting process 7. PMO1,PM02,PM03,PM04, Ten(10) spare printers PM05,PM06,PM07,PM08, N/A N/A PM09,PM 10 Corning Optical Communications,LLC—HMTC July 14,2021 Page 5 Mr. Street stated that the ten spare printers will minimize downtime on the paint processing lines. The ten inkjet printers will replace the operating printers on the painting process lines 3 and 7 if maintenance is needed on them. The inkjet printers are located in the northwest corner of the manufacturing plant. Any emissions from the cycling of methyl ethyl ketone(MEK)through the ten inkjet printers are fugitive. Observed.No spare inkjet printers were observed in the northwest corner of the manufacturing plant at the time of the inspection. C 101, C 102, C 103, C 104, cleaning process 1 consisting C 105 of five(5)cleaning lines (ID N/A N/A Nos. C101 through C105) The maintenance cleaning applications for the curing dyes are conducted in the cleaning process 1.Any emissions from isopropyl alcohol(IPA)in bottles and mainly acetone in bath are fugitive. However,one cleaning line and a manual station in the cleaning process 1 have fume hoods that exhaust outside of this facility. Observed.The cleaning applications were operational at the time of the inspection. I observed that the emission sources on the cleaning process 1 were less than the five permitted cleaning lines.No visible emissions were observed by me from the cleaning process 1.No odors were detected by me from cleaning process 1. C601, C602, C603 cleaning process 2 consisting of three(3) cleaning lines N/A N/A (ID Nos. C601 through C603) The repair cleaning applications in extrusion area are conducted in the cleaning process 2. Any emissions from isopropyl alcohol(IPA) and methyl ethyl ketone(MEK) are fugitive. However, two cleaning lines in the cleaning process 2 have fume hoods that exhaust outside of this facility. Observed.The cleaning applications were operational at the time of the inspection. I observed that the emission sources on the cleaning process 2 were less than the three permitted cleaning lines.No visible emissions were observed by me from the cleaning process 2.No odors were detected by me from cleaning process 2. C301, C302, C303, C304 cleaning process 3 consisting of four(4)cleaning lines(ID N/A N/A Nos. C301 through C304 The cleaning applications for extrusion tooling are conducted in the cleaning process 3.Any emissions from these operations are hydrocarbons,nitrogen oxide(NOx) and particulate matter. The particulate emissions are captured by two cyclones that are installed on two electric ovens and two baths. Each stack of the two cyclones is manifolded and exhaust outside of this facility. This office received a letter dated November 7,2018 from this company stating that a small amount of hydrochloric acid(HCL)would be used on all lines of the cleaning process 3. The cleaning of HCL was not considered a permit modification and did not trigger air toxics. During the inspection,Mr. Street indicated that HCL was no longer being used on all lines of the cleaning process 3. Observed.The cleaning applications were operational at the time of the inspection. I observed Corning Optical Communications,LLC-HMTC July 14,2021 Page 6 that the emission sources on the cleaning process 3 were less than the four permitted cleaning lines.No visible emissions were observed by me from emission sources or two cyclones on the cleaning process 3.No odors were detected by me from cleaning process 3. rC44O1, C402, C403,C404, cleaning process 4 consisting 05, C406 of six(6) cleaning lines(ID N/A N/A Nos. C401 through C406) The cleaning and maintenance applications involve the use of parts washer(manufacturer,ZEP). Any volatile organic compounds(VOC)emissions from the parts washer is fugitive. Observed.The cleaning and maintenance applications using the parts washer were not in use at the time of the inspection. I observed that the cleaning lines on cleaning process 4 were less than the six permitted cleaning lines.No visible emissions were observed by me from the parts washer. No odors were detected by me from the parts washer. E101,E102,E103,E104, extrusion process 1 E105,E106,E107,E108, consisting often(10) N/A N/A E109,E110 extrusion lines (ID Nos. E 101 through El 10) The extrusion of plastics materials is conducted in extrusion process 1. The volatile organic compound(VOC)emissions are emitted from the extrusion process 1. The cleaning with isopropyl alcohol(IPA)is conducted in the extrusion area. The extruders on extrusion process 1 vent to the outdoor atmosphere.No cleaning is conducted in the extrusion area. Observed.The extrusion process 1 and cleaning applications were operational at the time of the inspection. I observed that the emission sources on extrusion process I were less than the ten permitted extrusion lines.No visible emissions were observed by me from extrusion process 1 or the cleaning applications.No odors were detected by me from extrusion process 1 or the cleaning applications. E201,E202,E203,E204, extrusion process 2 E205,E206,E207,E208, consisting of forty(40) E209,E210,E211,E212, extrusion lines (ID Nos. E213,E214,E215,E216, E201 through E240) E217,E218,E219,E220, N/A N/A E221,E222,E223,E224, E225,E226,E227,E228, E229,E230,E231,E232, E233,E234,E235,E236, E237,E238,E239,E240 The extrusion of plastics materials is conducted in extrusion process 2. The volatile organic compound(VOC)emissions are emitted from the extrusion process 2. The extruders on extrusion process 2 vent outside of this facility.No cleaning is conducted in the extrusion area. Observed.The extrusion process 2 was operational at the time of the inspection. I observed that the emission sources on extrusion process 2 were less than the 40 permitted extrusion lines.No visible emissions were observed by me from extrusion process 2.No odors were detected by me from extrusion process 2. F E302,E303,E304 extrusion process 3 N/A N/A E306,E307,E308, consisting of twelve(12) Corning Optical Communications,LLC—HMTC July 14,2021 Page 7 E309,E310,E311,E312 extrusion lines (ID Nos. E301 through E312) Mr. Street stated that extrusion process 3 has been moved from this facility and installed at another Corning facility. Observed.The extrusion process 3 is no longer at this facility. Mr. Street stated that the extrusion process 3 consisting of twelve(12)extrusion lines (ID Nos. E301 and E312) should remain on the current air permit for future growth. E401,E402,E403,E404, extrusion process 4 E405,E406,E407,E408, consisting of ten(10) E409,E410 extrusion lines (ID Nos. N/A N/A E401 through E410) The extrusion of plastics materials is conducted in extrusion process 4. The volatile organic compound(VOC)emissions are emitted from the extrusion process 4.The extruders on extrusion process 4 vent outside of this facility.No cleaning is conducted in the extrusion area. There is laser etching of text statements into the polyethylene fiber optic cable on the lines in extrusion process 4. Any emissions from the laser etching is captured by a HEPA filter and a carbon filter. This office received a letter dated August 9,2019 from this company regarding the laser etching process.MRO DAQ permitting sent an email dated August 21, 2019 exempting the laser etching process per 2Q .0102 (h)(5). Observed.The extrusion process 4 was operational at the time of the inspection. I observed that the emission sources on extrusion process 4 were less than the ten permitted extrusion lines.No visible emissions were observed by me from extrusion process 4.No odors were detected by me from extrusion process 4. MESD Imetal machining I N/A I N/A The machines lathe metal tools using oil and water-based coolants inside the machine shop of MESD. All of the metal machining sources use volatile organic compounds(VOC)containing materials for the purposes such as cutting,cleaning and lubrication. The metal machining operations do not exhaust outside of this facility. Observed.The metal machining of tools was being conducted at the time of the inspection. I observed no visible emissions or detected any odors from the metal machining operations. AU ammonia usage I N/A F N/A Mr. Street stated that ammonia is not being used for production at this facility. However, ammonia is used in the technology research and development labs at this facility. It was estimated by Mr. Street that the ammonia usage was less than five gallons per year. Observed.No ammonia use was observed by me at the time of the inspection. PSB1 dry filter-type spray booth N/A N/A The spray booth equipped with dry filters was installed in August 2015. The spray booth is located in the former battery room of this facility.No manufacturing process is occurring in the spray booth. This company uses aerosol spray cans in the booth to apply touch-up paint to the maintenance work carts and stands used in the production area of this facility. The spray booth exhausts through the roof to the outside of this facility. The stack of the spray booth is vertical. When the spray booth fan is turned off,then the damper closes inside the spray booth stack. Corning Optical Communications,LLC—HMTC July 14,2021 Page 8 Observed.No painting using aerosol cans was being conducted at the time of the inspection. The dry filters were in place in the booth at the time of the inspection. PW parts washer I N/A I N/A The Cuda model electrically heated parts washer is located in the machine shop of this facility. The parts washer contained detergent(6.3%VOC/glycol ether)that is used to clean oil out of the metal filters from the two smog hogs(electrostatic precipitators)installed on the four oil evaporation lines(ID No. ISH). The parts washer is currently not vented outside of this facility. Observed.The Cuda model electrically heated parts washer was not operational at the time of the inspection.No visible emissions were observed or any odors detected by me from the parts washer at the time of the inspection. 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source Exemption Source of Source of Title V Regulation TAPs? Pollutants? IC501 —QA and technology lab r(gQ) 0102 Yes Yes (3)(B) The material evaluation processes are conducted in QA lab for new incoming raw materials and technology labs for potential raw materials.Acetone,toluene, chloroform, IPA and MEK are used in the material evaluation processes.Various fume hoods and muffle furnaces are used to vent any emissions generated from the lab processes outside of this facility. Observed.The material evaluation processes were operational in the QA and technology labs at the time of the inspection. I observed no visible emissions or detected any odors from the QA and technology labs. F 504 -cleaning process r(9Q .0102 Yes Yes )(3)(B) F This process uses one EDM to place holes in metal. This process exhausts through a hood to the outside atmosphere. Observed.The EDM machine was in operation at the time of the inspection. I observed no visible emissions or detected any odors from the EDM machine. IMPDE -five(5)MPDE storage silos 12Q .0102 (h)(5) F No Yes The five MDPE silos are located outside of this facility. The five MDPE silos are used to store plastic materials. A vacuum system is used to unload the plastic materials from the tanker trucks into the five MPDE silos. The description should be changed to IMDPE—five(5)MDPE storage silos as indicated by Mr. Street during the next permit revision. Observed.No tanker truck unloading of plastic materials into the five MDPE silos was occurring at the time of the inspection. The five MDPE storage silos were in use with no visible emissions observed or odors detected by me at the time of the inspection. Corning Optical Communications,LLC—HMTC July 14,2021 Page 9 IFR-flexible resin vacuum system [2Q .0102 (h)(5) No Yes venting to a fabric filter The flexible resin vacuum systems are used to transport the plastic compounding materials to the electric drying operations (ID No. I-DRY) and then to the extruders. The various filter systems are used to capture particulate matter emissions from the flexible resin vacuum systems. The filter systems do not exhaust outside of this facility. Since there are more than one particulate filter system associated with flexible resin vacuum systems,then the description should be changed to flexible resin vacuum systems venting to filter systems during the next permit revision.This process is also discussed in the electric drying operations(ID No. I-DRY). Observed.The flexible resin vacuum systems with associated filter systems were operational. I observed no visible emissions or detected any odors from these sources at the time of the inspection. IAC -industrial air cleaners 12Q .0102 (h)(5) F Yes Yes The six industrial air cleaners had been used to attract and capture any fugitive oily mist from the cutting oils used in the metal machining operations(ID No. MESD). Mr. Street stated that the six industrial air cleaners have been removed from this facility. Observed.The six industrial air cleaners are no longer at this facility. IVH-vent hood 2Q .0102 (h)(5) Yes Yes Observed. Mr. Street stated that the vent hood in the clean room has never been installed at this facility. ISH-four(4)oil evaporation lines F2Q .0102 (h)(5) No Yes each venting to smog hogs The four process lines are used to evaporate oil off of products on the bx lines. The four oil evaporation lines vent to two smog hogs (electrostatic precipitators). Each smog hogs has a separate exhaust outside of this facility. Mr. Street indicated that only one smog hog is in service at a time. Observed. Only one smog hog installed on the oil evaporation lines was in operation. I observed no visible emissions from the four oil evaporation lines or the two smog hogs (electrostatic precipitators) at the time of the inspection. IE619-research/saleable product 2Q .0102 (h)(5) No Yes extrusion line The extrusion line 619 is used for technology research and development of outdoor cable products. The extrusion line 619 exhausts outside of this facility. The inkjet printing is also occurring on the extrusion line 619. The extrusion line 619 and extrusion lines 975-1 and 975-2 share the same inkjet printer. There was not inkjet printer installed on the extrusion line 619 or extrusion lines 975-1 and 975-2 during the inspection. Observed.The extrusion line 619 was not in operation at the time of the inspection. IE975 -research/saleable product [2Q .0102 (h)(5) No Yes extrusion line The extrusion lines 975-1 and 975-2 are used for technology research and development of outdoor cable products. The extrusion lines 975-1 and 975-2 exhaust outside of this facility. The inkjet Corning Optical Communications,LLC—HMTC July 14,2021 Page 10 printing is also occurring on the extrusion lines 975-1 and 975-2. The extrusion lines 975-1 and 975-2 and extrusion line 619 share the same inkjet printer. There was not inkjet printer installed on the extrusion lines 975-1 and 975-2 or extrusion line 619 during the inspection. Observed.The extrusion lines 975-1 and 975-2 were not in operation at the time of the inspection. F O-soldering operation r(9Q) .0102 No No (14)(B) The MESD operations use solder for extrusion tooling equipment. Any emissions from this process is fugitive inside of the machine shop. Observed.No soldering operations were observed by me at the time of the inspection. I-DRY-electric in o erations r(gQ) .0102 No No Yg p (14)(B) The plastic compounding materials are transported by the flexible resin vacuum systems to the electric drying operations (ID No. I-DRY) and then to the extruders. The electric drying operations(ID No. I-DRY) are comprised of ten electric dryers in the manufacturing area and nine electric dryers in an enclosed room of this facility. The dryers vent outside of this facility to remove heat from the drying process and to provide employee comfort. This process is also described in the IFR-flexible resin vacuum system venting to filter systems. Observed.The electric drying operations(ID No. I-DRY; 19 electric dryers)were operational. I observed no visible emissions or detected any odors at the time of the inspection. I-QTCP -quartz tube cleaning process 2Q .0102 (h)(5) I No F No The quartz tubes are cleaned in this process by using heat from two electric ovens to remove any residue from them. The two electric ovens exhaust outside of this facility through one stack. Observed.The quartz tube cleaning process was in operation at the time of the inspection. I observed no visible emissions or detected any odors form the quartz tube cleaning process. 6. Observations of air emission sources and control devices not listed on the current permit: a. This company has various cartridge filter systems installed on extrusion processes that do not exhaust outside of this facility. The filter systems are exempt per 15A NCAC 2D .0102 (g)(14)(J)-equipment not vented to the outdoor atmosphere and not listed as exempt sources per DAQ policy. b. This company has natural gas-fired furnaces that are used to provide comfort heat to the employees in the warehouse and manufacturing areas of this facility. The natural gas-fired furnaces are exempt per 15A NCAC 2Q .0102 (g)(5)(A) and not listed as exempt sources per DAQ policy. C. This company has a laser etching process that exhausts to a HEPA filter in the MESD area of this facility. The HEPA filter is located under the laser etching process on the floor and exhausts inside of the machine shop room. The laser etching process and HEPA filter were not in operation at the time of the inspection. The laser etching process is exempt per 15A Corning Optical Communications,LLC—HMTC July 14,2021 Page 11 NCAC 2D .0102 (g)(14)(J)-equipment not vented to outdoor atmosphere and not listed per DAQ policy. d. This company has one carbon dioxide and one nitrogen storage tanks. The storage tanks are exempt from permitting per 15A NCAC 2Q .0102 (g)(14)(A) and not listed as exempt sources per DAQ policy. e. Duke Energy has installed a natural gas-fired Caterpillar(CAT)model emergency generator rated at 100 kilowatts for the purpose of providing power during electrical outages to the information technology(i.t..) system at this facility in April 2019. The owner and operator of the natural gas-fired emergency generator is Duke Energy. Corning Optical Communications,LLC has no access or control over the operations of the natural gas-fired emergency generator at its facility as indicated by Mr. Street. The natural gas-fired emergency generator is exempt per 15A NCAC 2Q .0102 (h)(5). f. The spot welding operations are conducted only for maintenance purposes at this facility. The welding operations are not subject to 40 CFR Part 63 Subpart XXXXXX (6X), NESHAP for Nine Fabrication and Finishing Area Source Categories, since the primary SIC code 3357 (nonferrous wire drawing/insulating) and NAICS code 335921 (fiber optic cable manufacturing) of this facility does not match the SIC or NAICS listed in the NESHAP 6X rule. 7. Compliance with specific permit conditions and limitations: a. Condition A. 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 with an application form and submit the air pollution emission inventory report with certification sheet for 2024 calendar year to MRO DAQ. Observed.I informed Mr. Street that the air permit expires on January 31, 2026,and the air pollution emission inventory report with certification sheet for 2024 calendar year and application form must be submitted with the permit renewal request. I advised Mr. Street to contact Jennifer Womick or Denise Hayes if there are any questions regarding air quality permitting. Compliance with this stipulation is indicated. b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes,"particulate matter emissions from dry filter-type spray booth(ID No. PSB1) shall not exceed allowable emission rates. Observed.The dry filters are considered adequate control for capturing particulate matter from the spray booth(ID No. PSB 1). The allowable emission rate from the dry filter type spray booth(ID No. PSB1) is not being exceeded. Compliance with this stipulation was indicated during the permit application process. C. Condition A.4. Visible Emissions Control Requirement-As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period. Corning Optical Communications,LLC—HMTC July 14,2021 Page 12 Observed.No visible emissions were observed by me from this facility. Compliance with this stipulation is indicated. d. Condition A. 5. Notification Requirement - As required by 15A NCAC 2D .0535, the permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall 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. Observed.Based on a conversation with Mr. Street,no excess emissions have occurred at the facility. Compliance with this stipulation is indicated. e. Condition A. 6. Fugitive Dust Control Requirement-As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emissions Sources," the permittee shall not cause or allow fugitive dust emissions to cause or contribute to the substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes 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). Observed. MRO DAQ has not received any fugitive dust emissions complaints regarding this facility. This company has paved roads at this facility. During the inspection, I observed no fugitive dust or visible emissions from this facility. Compliance with this stipulation is indicated. f. Condition A. 7. Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed toxic air pollutants (TAPS),the permittee has made a demonstration that facility-wide actual emissions,where one or more emission release points are obstructed or non-vertically oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .0711(a). Chronic Acute Acute Pollutant Carcinogens Toxicants Systemic Irritants (lb/yr) (lb/day) Toxicants (lb/hr) (lb/hr) Acetic acid(64-19-7) _-F 0.96 Ammonia(as NH3) (7664-41-7) F 0.68 Benzene(71-43-2) 8.1 F__F_ Formaldehyde(50-00-0) -F-F-I 0.04 MEK(methyl ethyl ketone,2- 78 22.4 butanone) (78-93-3) MIBK(methyl isobutyl ketone) 52 F-1 7.6 Corning Optical Communications,LLC—HMTC July 14,2021 Page 13 Methyl chloroform(71-55-6) 250 64 Methylene chloride(75-09-2) 1600 0.39 Proethylene 13000 F (tetrachetrachloroethylene)(127-18-4) Phenol(108-95-2) F 0.24 Toluene(108-88-3) 98 14.4 Vinyl chloride(75-01-4) 26 Xylene(mixed isomers)(1330- 57 16.4 20-7) Observed.The TPER limits of 2Q .0711(a)are applicable since the exhaust stacks are mixed vertical/horizontal and capped/uncapped at this facility. According to the 2016 emissions inventory and air permit review for R20,this facility operated 8760 hours and 365 days and emitted 9049.22 lbs/yr, 24.79 lbs/day and 1.03 lbs/hr of MEK; 221.74 lbs/yr, 0.61 lbs/day and 0.025 lb/hr of MIBK; 4.80 lbs/yr, 0.013 lbs/day and 0.00055 lbs/hr of methyl chloroform; 47.90 lbs/yr; 0.13 lbs/day and 0.0055 lbs/hr of toluene; and 6.60 lbs/yr, 0.018 lbs/day and 0.00075 lbs/hr of xylene. All the pollutants listed in the above TPER table were below the emission limits. Mr. Street has a spreadsheet along with MSDS information and material usage to calculate the actual emissions of the above referenced pollutants.A review of the spreadsheet data from January 1, 2019 through May 31, 2021 indicated that methyl ethyl ketone(MEK),methyl isobutyl ketone(MIRK),phenol(not emitted in January 2019), toluene and xylene are the only pollutants emitted from this facility. The actual emissions from these pollutants are less than the TPER limits listed in the above referenced table. A copy of the monthly TAP report has been placed in the file of this facility. Compliance with this stipulation is indicated. 8. NSPS/NESHAP Review: The sources at this facility are not subject to NSPS. This company is not subject to EPA rules, CFR Part 63, Subpart HHHHHH(6H),NESHAP: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources and 40 CFR Part 63, Subpart MMMM(4M),NESHAP for Surface Coating of Miscellaneous Metal Parts and Products. EPA 6H rule only applies to spray application of coatings containing compounds of chromium (Cr),lead(Pb),manganese(Mn),nickel(Ni), and cadmium(Cd), collectively referred to as the target HAPs and chemical strippers that contain methylene chloride to removed dried paint from wood,metal,plastic, and other substrates. The spray coating operation does not emit any of the targeted HAPs and no paint stripping with any chemicals is used by this facility. EPA 4M rule only applies to a facility that is a major source of RAPS. This facility does not emit or have the potential to emit equal to or greater than 10 tons per year of any one HAP or 25 tons per year of any combination of HAP. Corning Optical Communications,LLC—HMTC July 14,2021 Page 14 This company has no boilers, fire pump engines,peak shaving generators, or gasoline storage tanks at this facility. A natural gas-fired emergency generator rated at 100 kilowatts has been installed by Duke Energy for the purpose of providing power during electrical outages to the information technology system at this facility. The owner and operator of the natural gas-fired emergency generator is Duke Energy. Corning Optical Communications,LLC has no access or control over the operations of the natural gas-fired emergency generator at its facility as indicated by Mr. Street. The spot welding operations are only for maintenance purposes at this facility. The welding operations are not subject to 40 CFR Part 63 Subpart XXXXXX(6X) GACT,NESHAP for Nine Fabrication and Finishing Area Source Categories, since the primary SIC code 3357 (nonferrous wire drawing/insulating)and NAICS code 335921 (fiber optic cable manufacturing)of this facility does not match the SIC or NAICS listed in the NESHAP 6X rule. 9. Summary of changes needed to the current permit: a. The description of the insignificant/exempt activity, flexible resin vacuum system venting to a fabric filter(ID No. IFR), should be changed to flexible resin vacuum systems venting to filter systems(ID No.IFR). b. The description of the insignificant/exempt activity, IMPDE—five(5)MPDE storage silos should be changed to IMDPE—five(5)MDPE storage silos. C. MRO DAQ received a letter and 02Q .0318 notification form on August 12,2019 from this company regarding the addition of six improved jacket marking lines (IJM; ID Nos. IJMO 1-IJM06),which will vent through a fume extraction system and then to a HEPA filter and carbon filtration prior to exhausting inside the building of this facility. These sources appear to qualify for an exemption since they have no exhaust to the outside atmosphere and the potential VOC emissions for all six units are below the exemption threshold limit of 5 tons per year as indicated in 15A NCAC 2Q .0102(h)(5). d. MRO DAQ received a letter and 02Q .0318 Notification Form on February 14, 2020 from this company regarding the addition of a new extrusion process 5 (ID Nos. E0501- E0504)containing four extrusion lines with two of the extrusion lines being new lines and two are existing lines that will be moved from extrusion process 1 (ID Nos. E107 and E108); a new extrusion process 6 containing one new extrusion line(ID No. E0601) and a new extrusion process 7(ID Nos. E0701-E0706)containing six extrusion lines that will be moved from the existing extrusion process 4 with 5 lines being modified(ID Nos. E402 through E406)and the sixth line(ID No. E401)will be moved without being modified. e. The electronic yellowsheet for permit changes needed has been completed and placed in the facility's electronic file. 10. Compliance assistance offered duringthe he inspection: None. Corning Optical Communications,LLC—HMTC July 14,2021 Page 15 11. Section 112(r)applicability: This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r)of the Clean Air Act. 12. Compliance determination: Based on my observations, this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. DLC:dlc c: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAVaA/00365/INSPECT 20210714.docx