HomeMy WebLinkAboutAQ_F_2000115_20220429_PRMT_Permit ROY COOPER t ssArF`
Governor ��f a
ELIZABETH S. BISER �3: `!;-' A,
g
Secretary
MICHAEL A.ABRACZINSKAS
NORTH CAROLINA
Director Environmental Quality
April 29, 2022
Mr. R. Scott Keaton
General Manager
Moog, Inc.
1995 Hwy. 141
Murphy,NC 28906
Subject: Air Permit No. 07680R07
Moog, Inc.
Murphy, Cherokee County, North Carolina
Permit Class: Small
Facility ID#2000115
Dear Mr. Keaton:
In accordance with your completed application received April 13, 2022, we are forwarding
herewith Permit No. 07680R07 to Moog, Inc., Murphy, Cherokee County,North Carolina for the
construction and operation of air emissions sources or air cleaning devices and appurtenances.
Additionally, any emissions activities determined from your air permit application as meeting the
exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information
purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention
requirements are contained in General Condition 2 of the General Conditions and Limitations.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
_✓ North Carolina Department of Environmental Quality I Division of Air Quality
Asheville Regional Office 1 2090 U.S.Highway 70 1 Swannanoa,NC 28778
�epirtatent a4Env;rmmcntat Uoa?i �/I"�'�'` 828.296.4500 T 1 828.299.7043 F
Mr. Keaton
April 29, 2022
Page 2
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 April 29, 2022 until March 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 application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
• 15A NCAC 2D .0958—"Work Practices for Sources of Volatile Organic Compounds"
is no longer applicable and is removed;
• In accordance with the September 19, 2012 revisions to NESHAP Subpart N, the
surface tension limit for the chromium anodizing tank has been lowered to 40
dynes/cm and the housekeeping practices [63.342 Table 21 have been added to the
permit; and
• An emissions inventory for calendar year 2028 is due 90 days prior to the expiration of
the permit.
Should you have any questions concerning this matter, please contact Michael Koerschner at 828-
296-4550.
Sincerely,
Brendan G. Davey, P.E., Regional Supervisor
Division of Air Quality,NC DEQ
BGD:mfk
Enclosures
c: Asheville Regional Office
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 0768OR07
Issue Date: April 29, 2022 Effective Date: April 29, 2022
Expiration Date: March 31, 2030 Replaces Permit: 0768OR06
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 2 1 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Moog, Inc.
1995 Hwy 141
Murphy, Cherokee County,North Carolina
Permit Class: Small
Facility ID#2000115
(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
.... .... ... ............. .... ....... .
001 and 016 two water curtain-type paint spray booths used N/A N/A
in a metal parts coating operation
007(NESHAP-GACT) one nickel plating line N/A " N/A
........... . . ..... ......... ....._._. _.. . ........ ..... . ........ . ...
011 (NESHAP-MACT)'one chromium anodizing operation(tank N/A N/A
surface area of 13.5 square feet)
_.._..._. _._-_,.._,_ �.._._ _......._.._.__.._.._.__,.... � ...__. � ...._.__._..... _...._..W
012(NESHAP-GACT) one sodium dichromate passivating operation N/A N/A
in accordance with the completed application 2000115.22A received April 13, 2022 including any
plans, specifications, previous applications, and other supporting data, all of which are filed with the
Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part
of this permit.
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
Permit No. 07680R07
Page 2
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0515, 2D .0521, 2D .0535, 2D .0540, 2D .1111 (40 CFR 63 Subpart N,
Subpart WWWWWW), 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 2028 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the air emission sources shall not exceed allowable emission rates. The allowable emission
rates are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall
be determined by the following equation(s), where P is the process throughput rate in tons
per hour (tons/hr) and E is the allowable emission rate in pounds per hour(lbs/hr).
E=4.10 * (P) 0 67 for P <= 30 tons/hr, or
E = 55 * (P) '-" - 40 for P >30 tons/hr
4. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions the air emission sources
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six-minute period, except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with 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.
5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the air emission sources
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
Permit No. 07680R07
Page 3
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(0.
"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 111, "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - For
the chromium anodizing operation (ID No. 011), the Permittee shall comply with all
applicable provisions, including the notification, reporting, recordkeeping, and monitoring
requirements contained in Environmental Management Commission Standard 15A NCAC
2D .1111 "Maximum Achievable Control Technology" (MACT) as promulgated in 40 CFR
63, Subpart N "National Emission Standards for Chromium Emissions From Hard and
Decorative Chromium Electroplating and Chromium Anodizing Tanks," including Subpart
A "General Provisions."
a. MACT Emissions Limitations - As required by 40 CFR 63.342(d)(3), during tank
operation the surface tension of the electroplating bath for each affected source shall
not exceed:
Permit No. 07680R07
Page 4
Affected Source Size Surface Tension Limit
(dynes/cm)
chromium anodizing 13.5 square feet of 40
operation(011) surface area
b. MACT Monitoring and Work Practice Standards - In addition to any other
monitoring and work practice standards of the Environmental Protection Agency
(EPA),the Permittee shall comply with the following requirements:
i. In accordance with 40 CFR 63.342 (f)(1)the Permittee shall operate and
maintain any affected source and monitoring equipment including periods of
startup, shutdown and malfunction, in a manner consistent with good air
pollution practices, consistent with the operation and maintenance plan
required by 40 CFR 63.342(f)(3).
ii. The Permittee shall prepare an operation and maintenance plan to be
implemented and kept on-site no later than the compliance date for existing
affected sources or upon start-up for new affected sources. The plan shall
include the elements prescribed by 40 CFR 63.342(f)(3), which include, but
are not limited to the following:
A. The plan shall specify the operation and maintenance criteria for the affected
source and the process and control system monitoring equipment and shall
include a standardized checklist to document the operation and maintenance
of this equipment.
B. The plan shall specify procedures to be followed to ensure that equipment or
process malfunctions due to poor maintenance or other preventable
conditions do not occur.
C. The plan shall include a systematic procedure for identifying malfunctions of
process equipment, and process and control system monitoring equipment
and for implementing corrective actions to address such malfunctions.
D. Work Practice Standards for the stalagmometer or tensiometer shall follow
the manufacturer's recommendations.
E. If the plan fails to address or inadequately addresses an event that meets the
characteristic of a malfunction, the plan shall be revised within 45 days after
such an event occurs.
F. The plan shall include housekeeping procedures, as specified in Table 2 of 40
CFR 63.342 as follows.
Permit No. 07680R07
Page 5
................................................................................................................... ...
For You must: At this minimum frequency
_ . ___ _..._. ...... .... . . .. ..
Any substance used in an (a) Store the substance in a At all times, except when
affected chromium closed container in an enclosed transferring the substance to and
electroplating or chromium :storage area or building; AND ;from the container. Whenever
anodizing tank that contains (b) Use a closed container when transporting substance, except
hexavalent chromium transporting the substance from when transferring the substance
_....... _....._ _....
the enclosed storage area to and from the container.
Each affected tank, to minimize (a) Install drip trays that collect
spills of bath solution that result and return to the tank any bath
from dragout. solution that drips or drains
from parts as the parts are
Note: this measure does not removed from the tank; OR
require the return of (b) Contain and return to the :Prior to operating the tank.
contaminated bath solution to tank any bath solution that Whenever removing parts from
the tank. This requirement drains or drips from parts as the an affected tank.
applies only as the parts are parts are removed from the tank;.Whenever removing parts from
removed from the tank. Once OR an affected tank.
away from the tank area, any (c) Collect and treat in an onsite
:spilled solution must be handled wastewater treatment plant any
in accordance with Item 4 of bath solution that drains or drips
these housekeeping measures from parts as the parts are
:removed from the tank
._................. . _.. .. .._ . .. ...... ..................
;Install a splash guard to
minimize overspray during
:Each spraying operation for :spraying operations and to
removing excess chromic acid ensure that any hexavalent :Prior to any such spraying
from parts removed from, and chromium laden liquid captured operation.
occurring over, an affected tank.by the splash guard is returned
to the affected chromium
electroplating or anodizing tank.
Each operation that involves the Begin clean up, or otherwise
handling or use of any substance contain, all spills of the
:used in an affected chromium substance. Note: substances that ;Within 1 hour of the spill.
electroplating or chromium fall or flow into drip trays,pans,
anodizing tank that contains ,sumps, or other containment
hexavalent chromium areas are not considered spills.
..... . ............. ..... ......
(a) Clean the surfaces using one
or more of the following At least once every 7 days if one
Surfaces within the enclosed methods: HEPA vacuuming; or more chromium electroplating
torage area, open floor area, Hand-wiping with a damp cloth; or chromium anodizing tanks
walkways around affected tanks 'Wet mopping; Hose down or were used, or at least after every
contaminated with hexavalent rinse with potable water that is 40 hours of operating time of one
chromium from an affected collected in a wastewater or more affection chromium
chromium electroplating or collection system; Other electroplating or chromium
chromium anodizing tank :cleaning method approved by anodizing tank, whichever is
the permitting authority; OR 'later. According to
(b) Apply a non-toxic chemical manufacturer's recommendations.'
dust suppressant to the surfaces.
Permit No. 0768OR07
Page 6
....... ...._... _..._..... ......... ......... ....................... ..................................................... . .
For You must: At this minimum frequency
... .. _. __....w_. _..w._._..._.__ _.._..___
All buffing, grinding, or Separate the operation from any
polishing operations that are affected electroplating or
located in the same room as 'anodizing operation by Prior to beginning the buffing,
chromium electroplating or installing a physical barrier; the ;grinding, or polishing operation.
:chromium anodizing operations barrier may take the form of
plastic strip curtains.
........ .. ......... _. ... . .. . ..
Store, dispose, recover, or
All chromium or chromium- recycle the wastes using
containing wastes generated Practices that do not lead to At all times.
from housekeeping activities 'fugitive dust and in accordance
with hazardous waste
requirements.
..__........ .__. .. ........
iii. Monitoring Requirements to demonstrate continuous compliance in
accordance with 40 CFR 63.343(c):
A. The Permittee of an affected source shall monitor the surface tension of the
electroplating bath. Operation of the affected source at a surface tension
greater than 40 dynes/cm, as measured by a stalagmometer, or 33 dynes/cm,
as measured by a tensiometer shall constitute noncompliance with the
standards. The surface tension shall be monitored according to the following
schedule:
B. The surface tension shall be measured once every four hours during operation
of the tank with a stalagmometer or a tensiometer as specified in Method
306B, appendix A of 40 CFR Part 63.
C. The time between monitoring can be increased if there have been no
exceedances. The surface tension shall be measured once every four hours of
tank operation for the first 40 hours of tank operation after the compliance
date. Once there are no exceedances during 40 hours of tank operation,
surface tension measurement may be conducted once every eight hours of
tank operation. Once there are no exceedances during 40 hours of tank
operation, surface tension measurement may be conducted once every 40
hours of tank operation on an ongoing basis, until an exceedance occurs. The
minimum frequency of monitoring allowed by Subpart N is once every 40
hours of tank operation.
D. Once an exceedance occurs as indicated through surface tension monitoring,
the original monitoring schedule of once every four hours must be resumed.
A subsequent decrease in frequency shall follow the schedule laid out in
paragraph(b)(iv)(A)(2) above. For example, if the Permittee had been
monitoring an affected source once every 40 hours and an exceedance occurs,
subsequent monitoring would take place once every four hours of tank
operation. Once an exceedance does not occur for 40 hours of tank operation,
monitoring can occur once every eight hours of tank operation. Once an
exceedance does not occur for an additional 40 hours of tank operation on
this schedule, monitoring can occur once every 40 hours of tank operation.
Permit No. 07680R07
Page 7
iv. Once a bath solution is drained from the affected tank and a new solution
added, the original monitoring schedule of once every four hours must be
resumed, with a decrease in monitoring frequency allowed following the
procedures of paragraph (b)(iv)(A)(2) above.
c. MACT Recordkeeping Requirements - In addition to any other recordkeeping
requirements of the EPA, the Permittee is required to maintain the following records
for an affected source:
i. Inspection records for the monitoring equipment, to document that the
inspection and maintenance required by the work practice standards of 40
CFR 63.342(f) and Table 1 of 40 CFR 63.342 have taken place. The record
can take the form of a checklist and should identify the device inspected, the
date of inspection, a brief description of the working condition of the device
during the inspection, and any actions taken to correct deficiencies found
during the inspection;
ii. Records of all maintenance performed on the affected source and monitoring
equipment;
iii. Records of the occurrence, duration, and cause (if known) of each
malfunction of process and monitoring equipment;
iv. Records of actions taken during periods of malfunction when such actions are
inconsistent with the operation and maintenance plan;
V. Other records, which may take the form of checklists, necessary to
demonstrate consistency with the provisions of the operation and
maintenance plan required by 40 CFR 63.342(f)(3);
vi. Records of monitoring data required by 40 CFR 63.343(c)that are used to
demonstrate compliance with the standard including the date and time the
data are collected;
vii. The specific identification(i.e., the date and time of commencement and
completion) of each period of excess emissions, as indicated by monitoring
data, that occurs during malfunction of the process or monitoring equipment;
viii. The specific identification (i.e., the date and time of commencement and
completion) of each period of excess emissions, as indicated by monitoring
data, that occurs during periods other than malfunction of the process or
monitoring equipment;
ix. The total process operating time of the affected source during the reporting
period;
X. For sources using fume suppressants to comply with the standards, records of
the date and time that fume suppressants are added to the electroplating bath,
and records of the fume suppressant manufacturer and product name;
Permit No. 07680R07
Page 8
xi. Any information demonstrating whether a source is meeting the requirements
for a waiver of recordkeeping or reporting requirements, if the source has
been granted a waiver under 40 CFR 63.10(f);
xii. All documentation supporting the notifications and reports required by 40
CFR 63.9, 63.10, and 63.347; and
xiii. All records shall be maintained for a period of five years in accordance with
40 CFR 63.10(b)(1).
d. MACT Reporting Requirements - In addition to any other notification requirements
of the EPA, the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in
WRITING, of the following:
i. As required by 40 CFR 63.342(f)(3)(iv), if actions taken by the Permittee
during periods of malfunction are inconsistent with the procedures specified
in the operation and maintenance plan required by 40 CFR 63.342(f)(3)(i),
the Permittee shall record the actions taken for that event and shall report by
phone such actions within two working days after commencing actions
inconsistent with the plan. This report shall be followed by a letter within
seven working days after the end of the event.
ii. New and reconstructed sources are subject to the requirements of 40 CFR
63.345, including reporting requirements.
iii. Ongoing Compliance Status Reports for Area Sources - In accordance with
40 CFR 63.347(h), the Permittee shall prepare and retain on-site an annual
ongoing compliance status summary report to document ongoing compliance
status of the affected source. If the total duration of excess emissions is 1
percent or greater of the total operating time for the reporting period, or the
total duration of malfunctions of the monitoring equipment is 5 percent or
greater of the total operating time, then the report shall be prepared and
submitted to the administrator semiannually (by July 30 of each year for the
first half of the year, and by January 30 for the second half of the year) until a
request to reduce reporting frequency is approved. The ongoing compliance
status report shall contain, at a minimum:
A. The company name and address of the affected source;
B. An identification of the operating parameter that is monitored for compliance
determination, as required by 40 CFR 63.343(c);
C. The relevant emission limitation for the affected source, and the operating
parameter value, or range of values, that correspond to compliance with this
emission limitation as specified in the notification of compliance status;
D. The beginning and ending dates of the reporting period;
E. A description of the type of process performed in the affected source;
Permit No. 07680R07
Page 9
F. The total operating time of the affected source during the reporting period;
G. A summary of operating parameter values, including the total duration of
excess emissions during the reporting period as indicated by those values, the
total duration of excess emissions expressed as a percent of the total source
operating time during that reporting period, and a breakdown of the total
duration of excess emissions during the reporting period into those that are
due to process upsets, control equipment malfunctions, other known causes,
and unknown causes;
H. A certification by a responsible official, as defined in 40 CFR 63.2, that the
work practice standards in 40 CFR 63.342(f) were followed in accordance
with the operation and maintenance plan for the source;
I. If the operation and maintenance plan required by 40 CFR 63.342(f)(3) was
not followed, an explanation of the reasons for not following the provisions,
an assessment of whether any excess emission and/or parameter monitoring
exceedances are believed to have occurred, and a copy of the report(s)
required by 40 CFR 63.342(f)(3)(iv) documenting that the operation and
maintenance plan was not followed;
J. Description of any changes in monitoring,processes, or controls since the last
reporting period;
K. The name, title, and signature of the responsible official who is certifying the
accuracy of the report; and
L. The date of the report.
9. 15A NCAC 2D .1111 "GENERALLY AVAILABLE CONTROL TECHNOLOGY" - For
the nickel plating line (ID No. 007) and the sodium dichromate passivating operation (ID
No. 012), the Permittee shall comply with all applicable provisions, including the
notification, testing, recordkeeping, reporting and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111, "Generally
Available Control Technology" as promulgated in 40 CFR 63, Subpart WWWWWW,
"National Emissions Standards for Hazardous Air Pollutants: Area Source Standards for
Plating and Polishing Operations", including Subpart A "General Provisions."
a. Compliance Date - Pursuant to 40 CFR 63.11506, sources which commenced
construction or reconstruction on or before March 14, 2008, must be in compliance
with 40 CFR 63, Subpart WWWWWW by July 1, 2010. Sources that commenced
construction or reconstruction after March 14, 2008, must be in compliance with 40
CFR 63, Subpart WWWWWW by July 8, 2008 or upon initial startup of the affected
source, whichever is later.
b. Standard and Management Practices -The Permittee shall comply with the following
management practices for affected sources that use or emit plating and polishing
metal HAP. Plating and polishing metal HAP means materials containing any
compounds of cadmium, chromium, lead, manganese or nickel, or any of these
metals in elemental form with the exception of lead. Materials that do not contain
Permit No. 07680R07
Page 10
cadmium, chromium, lead or nickel in amounts greater than 0.1%by weight and do
not contain manganese in amounts greater than or equal to 1.0% by weight are not
considered to be plating or polishing metal HAPs. Pursuant to 40 CFR 63.11507(g),
the Permittee shall comply with the following management practices for each
affected source
i. The Permittee shall minimize bath agitation when removing any parts
processed in the tank, as practical except when necessary to meet part quality
requirements.
ii. The Permittee shall maximize the draining of the bath solution back into the
tank by extending drip time when removing parts from the tank, using drain
boards, or withdrawing parts slowly from the tank.
iii. The Permittee shall optimize the design of barrels, racks, and parts to
minimize dragout of batch solution (such as by using slotted barrels and tilted
racks or by designing parts with flow-through holes).
iv. The Permittee shall use tanks covers, if already owned and available at the
facility.
V. The Permittee shall minimize or reduce heating of process tanks, as
practicable.
vi. The Permittee shall perform regular repair, maintenance, and preventative
maintenance of racks, barrels, and other equipment associated with affected
sources.
vii. The Permittee shall minimize bath contamination, such as through the
prevention or quick recovery of dropped parts, use of distilled/de-ionized
water, water filtration, pre-cleaning of parts to be plated, and thorough
rinsing of pre-treated parts to be plated.
viii. The Permittee shall maintain quality control of chemicals, and chemical and
other bath ingredient concentrations in the tanks.
ix. The Permittee shall perform general good housekeeping, such as regular
sweeping or vacuuming, if needed, and periodic washdowns.
X. The Permittee shall minimize spills and overflow of tanks.
xi. The Permittee shall use squeegee rolls in continuous or reel-to-reel plating
tanks.
xii. The Permittee shall perform regular inspections to identify leaks and other
opportunities for pollution prevention.
Permit No. 07680R07
Page 11
c. Recordkeeping Requirements - Pursuant to 40 CFR 63.11509(e), the Permittee shall
maintain the following records on-site:
iv. A copy of the Initial Notification and Notification of Compliance Status and
all supporting documentation.
V. The occurrence and duration of each startup or shutdown when the startup or
shutdown causes the source to exceed any applicable emission limitation in
the relevant emission standards.
vi. The occurrence and duration of each malfunction of operation(i.e., process
equipment) or the required air pollution control and monitoring equipment.
vii. All required maintenance performed on the air pollution control and
monitoring equipment.
viii. The records required to show continuous compliance with each management
practice and equipment standard pursuant to 40 CFR Part 63.11508(d).
ix. Pursuant to 40 CFR 63.11509(c), the Permittee is required to prepare and
maintain an annual certification of compliance report. The report must be
prepared no later than January 31 of the year immediately following the
reporting period.
X. All records shall be maintained for a minimum of five (5)years following the
date of each occurrence, measurement, maintenance, corrective action, report,
or record. The records shall be kept on-site for two (2)years and made
available to DAQ personnel upon request. The records can be maintained
off-site for the remaining three (3)years.
d. Reporting - In accordance with 40 CFR 63.11509, the Permittee is required to
NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following:
An annual certification of compliance, as described in 40 CFR 63.11509(c) and a
deviation report, as described in 40 CFR 63.11509(d) shall be submitted by January
31 of each year in which a deviation has occurred during the previous year.
10. 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.
11. "GENERALLY AVAILABLE CONTROL TECHNOLOGY"- Pursuant to 15A NCAC 2D
.1111, the paint spray booths (Source ID Nos. 001 and 006) do not utilize coatings that
contain compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium
(Cd) above threshold levels listed in 40 CFR 63 Subpart HHHHHH-National Emission
Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating
Operations at Area Sources. In addition,paint stripping materials do not contain methylene
chloride (MeCI). If the Permittee uses coatings containing compounds of chromium (Cr),
Permit No. 0768OR07
Page 12
lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) above the threshold levels; or uses
paint stripping materials containing methylene chloride (MeCI), the Permittee shall comply
with all applicable provisions, including the notification, testing, and monitoring
requirements as promulgated in 40 CFR 63, Subpart below, including Subpart A "General
Provisions."
......... _._.............. _ .
...Miscellaneous Surface Coating Operations
that utilize coatings that contain Subpart HHHHHH-National
compounds of chromium (Cr), lead (Pb), ;Emission Standards for
manganese (Mn), nickel (Ni), or cadmium Hazardous Air Pollutants: Paint
(Cd) to coat a plastic and/or metal Stripping and Miscellaneous
substrate on a part or product; and Paint Surface Coating Operations at
Stripping Operations that utilize materials 'Area Sources
containing Methylene Chloride.
. _
12. Federal Rule Applicable to Sources Exempted from Air Permitting Requirements - Your
facility is subject to the following federal rule:
40 CFR 63 -NESHAP/MACT -- Subpart XXXXXX --Nine Metal
Fabrication and Finishing Source Categories Area Sources
........ ........ ........ ... ......... ........ ........ ............ .. . ..... ........... ..
which are applicable to the bead blast operations (ID Nos. 1-014 and 1-015) 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
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
828-296-4500
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
Permit No. 0768OR07
Page 13
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effectuate an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. CHANGES NOT REQUIRING PERMIT REVISIONS - Pursuant to 15A NCAC 02Q
.0318, changes to the facility that are not exempt pursuant to 15A NCAC 02Q .0102 may be
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.
Permit No. 07680R07
Page 14
9. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
10. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
11. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to, process weight rates, firing rates, hours of
operation, and preventive maintenance schedules.
12. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, 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. 07680R07
Page 15
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 29 h of April, 2022.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Brendan G. Davey, P.E.
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 07680R07
ATTACHMENT to Permit No. 07680R07, April 29, 2022
Insignificant/Exempt Activities
. ......................................... ............................ ........ ...... .. ....I.... .........................................
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
......... . ........ ........ ........_. ....................._.. . _........_... ...... .......... . . ......... . _ ................... .:............ _..........................................................................................................................
`I-008 - one zinc phosphate coating line 2Q .0102 No No
(g)(14)
--- .... ._ _ _....._._....._...._.
1-014 - one bead blast operation (M3333 2Q .0102
BlastnPeen) (vented inside, controlled by (g)(14) Yes Yes
bagfilter) (GACT 6X)
....... .......... .. ..... ......._........... ....... ......... _.._. ... .. ....... ................................................ .
I-015 - one bead blast operation(M3264 2Q .0102
Silverado) (vented inside, controlled by (g)(14) Yes Yes
bagfilter) (GACT 6X)
1-017 - one air compressor heat evaporator 2Q .0102 No No
(g)(14)
l. 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 .l 100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here:
https://deq.nc.,;ov/agpermitconditiotis