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HomeMy WebLinkAboutAQ_F_0800018_20210511_PRMT_PmtRvw NORTH CAROLINA DIVISION OF Region: Washington Regional Office AIR QUALITY County: Bertie Application Review NC Facility ID: 0800018 Inspector's Name: Kurt Tidd Issue Date: 5/11/2021 Date of Last Inspection: 07/08/2020 Com liance Code: 3/Compliance-inspection Facility Data Permit Applicability(this application only) Applicant(Facility's Name): FSC II,LLC-Windsor Asphalt Plant SIP: x NSPS: Facility Address: NESHAP: FSC II,LLC-Windsor Asphalt Plant PSD: 129 County Farm Road(SR 1527) PSD Avoidance: Lewiston Woodville,NC 27849 NC Toxics: 112(r): SIC:2951 /Paving Mixtures And Blocks Other: NAILS: 324121 /Asphalt Paving Mixture and Block Manufacturing Facility Classification:Before: Synthetic Minor After: Synthetic Minor Fee Classification:Before: Synthetic Minor After: Synthetic Minor Contact Data Application Data Facility Contact Authorized Contact Technical Contact Application Number: 0800018.21A Tim Perry Brent Wood Tim Perry Date Received: 02/17/2021 Plant Superintendent Vice President of Legal Plant Superintendent Application Type: Admin.Amendment (252)287-7829 Affairs (252)287-7829 Application Schedule: State P O Box 806 (919)740-7325 P O Box 806 Existing Permit Data Ahoskie,NC 27910 701 Corporate Center Ahoskie,NC 27910 Existing Permit Number: 03707/R19 Drive Existing Permit Issue Date: 02/03/2021 Raleigh,NC 27607 Existing Permit Expiration Date: 02/28/2025 Review Engineer: Yongcheng Chen Comments/Recommendations: Issue 03707/R20 Review Engineer's Signature: Date: 5/5/2021 Permit Issue Date: 5/11/2021 / " tl 4", Permit Expiration Date: 02/28/2025 Purpose of Application: An application was received on 2/17/2021 from FSC II, LLC - Windsor Asphalt Plant. to request adding Natural Gas as a combustion source. This is based on the Permit Applicability Determinations made by Betsy Huddleston, Regional Supervisor, WaRO on February 9, 2021: Facility 0800018, Permit 03 707R19-Windsor, Bertie County FSC II, LLC wants to burn natural gas. It is not currently listed on the permit as a fuel, so a permit modification is needed. Since Permit R19 was just issued for ownership change to FSC II, LLC, I think it's best to add natural gas to the permit through a written request for administrative change. Please provide this request within 30 days of the permit issuance date. A hard copy with authorized signature is needed, but an email copy will allow DAQ to begin processing sooner. No fee is required for the administrative change. The facility is a typical batch asphalt plant. The facility also has a RAP crusher. The aggregate is conveyed to a drum where it is dried. The aggregate is then separated by a screening process. The aggregate is then mixed in the desired proportions, injected with asphalt,weighed,and transferred to a storage silo. The asphalt is then unloaded into trucks. This facility is permitted for two operating sites that are: 123 NC I I South Bypass, Lewiston, Bertie County and SR 1527 County Farm Road, Windsor, Bertie County It is currently located on SR 1527 in Windsor. 2. Application Chronology: Application Received 02/17/2021 Fee Received and Acknowledgement Letter Sent 02/17/2021 Permit Issued 05/11/2021 3. New Equipment/Changes in Regulatory Requirements: No new equipment was added with this application. A switch to a fuel or raw materials is not considered as a modification but as an administrative change. The 2Q .0315 "Limitation to Avoid" — Synthetic Minor Condition is still in place and is not affected by this change as long as the facility does not emission more than the limits in the permit. 4. NSPS, NESHAPS, PSD,Attainment Status, 112r: a. NSPS-No NSPS Subpart is applicable to this facility. Subpart I is not applicable to the asphalt plant because it has not made any modifications (defined as changes which increase emissions) since the Subpart was promulgated in June 1973 (this facility was apparently constructed in 1972). Subpart 000 is not applicable to the crusher because it is portable and has a capacity less than 150 tons per hour. b. NESHAPS -No NESHAP Subpart is applicable to this facility c. PSD—Without the synthetic minor restriction,this facility would be major for PSD for carbon monoxide. However, it was constructed before the PSD applicable date of June 1, 1975, so the initial construction did not trigger PSD. There is no condition currently in the Permit limiting emissions to synthetic minor levels for PSD purposes. However, since there have been no major modifications which would trigger PSD, one is not needed at this time to avoid PSD applicability. (Note that a switch to a fuel or raw materials is not considered as a modification). Bertie County has been triggered for increment tracking for S02,PM-10,and NOx(NO2 actually),but no changes in emissions occur because of this modification since the same limits are holding for this synthetic minor permit. d. Attainment Status - This facility is in an attainment area. e. 112r - The facility does not handle, store, or use any 112r pollutants in sufficient quantity to be subject to this regulation (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 2 5. Facility Wide Air Toxics: Since this facility has not made any modifications which increased TAP emissions since September 1993, the toxics rules are not applicable. A toxics review is not trigged by this ownership change application. 6. Facility Compliance Status: This facility was inspected by Kurt Tidd of the WaRO on 7/8/2020 and appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. 7. Facility Emissions Review: Not done for an administrative change application. The potential emissions in the table below were taken from previous permit reviews as no equipment changes have been made. These were generated by NCDEQ asphalt spreadsheets. 2Q .0315 "Limitation to Avoid" — Synthetic Minor Condition is still is not affected by this change as long as the facility does not emission more than the limits in the permit. TOTAL FACILITY EMISSIONS Actual Potential Emissions - Potential Emissions Pollutant Emissions Synthetic Minor -No controls or (tons/yr) restrictions (tons/yr) restrictions (tons/yr) TSP 0.48 6.87 72.03 PM-10 0.30 4.61 27.58 S02 1.12 99 668.72 NOx 1.28 20.36 133.67 VOC 0.40 7.89 57.08 CO 4.07 61.25 441.34 Total HAPS <1 <10 <10 8. Stipulation Review and Regulatory Review: 2D .0202 "Registration of Air Pollution Sources" This Rule gives the Director the authority to require the registration of air pollution sources, and require them to submit information about the source. It is under this Rule that the Division is requiring facilities to submit an emissions inventory 90 days before their air quality permit expires. 21). 0506—"Control of Particulates from Hot Mix Asphalt Plants" This is applicable to particulate matter emissions from the operation of the asphalt plant. Maximum allowable particulate matter emissions from the asphalt plant operation are determined from the equation: E =4.9445 * (P) 0.4376 (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 3 Visible emissions from stacks or vents at a hot mix asphalt plant shall be less than 20 percent opacity. Previous inspections have noted compliance with the dust and fugitive emission requirements. 2D .0515—"Particulates From Miscellaneous Industrial Processes" This Rule applies to the asphalt crusher. This crusher has a maximum capacity of 50 tons/hr. Therefore the maximum allowable particulate matter emissions from the crusher are determined by the equation: E = 55.0 * (P) 0" -40 The maximum allowable particulate matter emissions are 44.6 lb/hr. Using the AP-42 emission factor for a primary crusher,the PM emissions at maximum crushing capacity are 0.0351b/hr. Thus compliance is easily expected. 2D.0516 - "Sulfur Dioxide Emissions from Combustion Sources" This is applicable to the asphalt plant. Sulfur dioxide emissions from the plant shall not exceed 2.3 pounds per million Btu heat input. Using unadulterated or equivalent recycled No.4 fuel with a sulfur content of 2.0%,the sulfur dioxide emissions from the asphalt plant would be about 1.86 lb per million Btu. Compliance is expected. 2D .0521 - "Control of Visible Emissions" This Rule applies to the asphalt plant and crusher which were manufactured after July 1, 1971; therefore, visible emissions from these processes 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(4)times in any 24-hour period. Compliance with this rule has been indicated. 2D.0535 - "Excess Emissions Reporting and Malfunctions" The facility is required to report excess emissions which last for more than four hours that result from a malfunction, a breakdown of process or control equipment or any other abnormal conditions. A notification condition is included in the permit. 2D .0540 - "Particulates from Fugitive Dust Emission Sources" The facility must not allow fugitive dust emissions to become a nuisance outside of the facility boundaries. If a second substantive complaint is received concerning such dust emissions, the facility is required to produce a dust control plan. No dust problems have been noted. 2D .0605 - "Testing Requirement" NCDEQ's testing policy for asphalt batch plants was clarified in a memorandum dated August 13, 2013. Some plants can be granted an alternate compliance method, but this plant does not fall under the necessary condition "T Asphalt plants that are classified as "small"or that have actual average production rates of less than 40,000 tons per year(in the prior 36 calendar months before a required test)may petition for an alternate compliance method provided it is not otherwise required to test by some other regulation or has a demonstrated compliance issue (e.g., opacity issues,poor operation and maintenance in those prior 36 calendar months)." (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 4 Asphalt plants that meet certain criteria must test every 10 years. The last stack test was done on 5/3/2018, therefore testing is required and the date is still set up to be 5/3/2028. 2D .0611 "Fabric Filter Requirements" It is under this Rule that the control device I and M requirements are implemented. This Rule requires that the facility maintain records of all inspections and variances from manufacturer's recommendations for bagfilters. Also all maintenance activities must be recorded in a logbook. They will need to check their bagfilter systems annually. 2D .0611 "Cyclone Requirements" It is under this Rule that the control device I and M requirements are implemented. This Rule requires that the facility maintain records of all inspections and variances from manufacturer's recommendations for cyclones. Also all maintenance activities must be recorded in a logbook. They will need to check their cyclone systems annually. 2D .1806 "Control and Prohibition of Odorous Emissions" The facility may not operate without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions that would go past the property boundary and create a nuisance. 20 .0311 - "Permitting of Facilities at Multiple Temporary Sites" This is the Rule authorizing emissions from a facility or source at multiple temporary sites. At least ten days before each relocation of the plant,the facility must provide written notice to the Regional Supervisor, DAQ responsible for the new location. This written notice needs to include the following: • The installation or relocation dates; • A list of the equipment affected by the installation or relocation; • The county in which the equipment was installed or to which the equipment was relocated; and • The county from which the equipment was relocated(if applicable). 20 .0315 "Limitation to Avoid" — Synthetic Minor Condition To avoid Title V, the facility needs to limit potential CO, S02 and NOx emissions below 100 tons per year. The facility likes to have the flexibility to burn No. 2 and No. 4 fuel oils (virgin or recycled) as desired by keeping the annual emissions below the TV thresholds. Compliance has been indicated during through inspections and annual reports. The Synthetic Minor Condition is not affected by this change as long as the facility does not emission more than the limits in the permit. 20 .0317 "Recycled Asphalt Shingle Requirements" This facility is also permitted to use post-consumer reclaimed asphalt roofing shingles(also known as PRAS and herein called recycled shingles). This Rule also allows for the avoidance of certain Rules and requirements if they demonstrate the recycled shingles are equivalent to their virgin or unadulterated counterparts. The requirements are included in the Permit. Through testing and recordkeeping, the facility must also demonstrate that the recycled shingles and roofing materials are certified to be free of asbestos containing material (ACM). So far the facility has not started using recycled shingles. (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 5 20 .0317 "Recycled No. 2 & No. 4 Fuel Oil Requirements" This Rule allows for the avoidance of certain Rules and requirements. This facility uses recycled fuel. It is under this Rule that a facility can avoid the applicability of 2Q .0700 requirements if they demonstrate the recycled fuel is equivalent to unadulterated fuel. The fuel requirements are included in the Permit. The facility will need to keep records of the recycled fuel delivered to the site and submit annual reports of any analytical testing performed and the amount of fuel delivered. The plant has been using Recycled No. 4 fuel and compliance with this requirement has been indicated. Other Stipulation Issues—All stipulations are updated by using Permit Writer and covered in the regulatory review. 9. Conclusions, Comments and Recommendations: Issue Permit No. 03707R20. (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 6 NORTH CAROLINA DIVISION OF Region: Washington Regional Office AIR QUALITY County: Bertie Application Review NC Facility ID: 0800018 Inspector's Name: Kurt Tidd Issue Date: 5/11/2021 Date of Last Inspection: 07/08/2020 Com liance Code: 3/Compliance-inspection Facility Data Permit Applicability(this application only) Applicant(Facility's Name): FSC II,LLC-Windsor Asphalt Plant SIP: x NSPS: Facility Address: NESHAP: FSC II,LLC-Windsor Asphalt Plant PSD: 129 County Farm Road(SR 1527) PSD Avoidance: Lewiston Woodville,NC 27849 NC Toxics: 112(r): SIC:2951 /Paving Mixtures And Blocks Other: NAILS: 324121 /Asphalt Paving Mixture and Block Manufacturing Facility Classification:Before: Synthetic Minor After: Synthetic Minor Fee Classification:Before: Synthetic Minor After: Synthetic Minor Contact Data Application Data Facility Contact Authorized Contact Technical Contact Application Number: 0800018.21A Tim Perry Brent Wood Tim Perry Date Received: 02/17/2021 Plant Superintendent Vice President of Legal Plant Superintendent Application Type: Admin.Amendment (252)287-7829 Affairs (252)287-7829 Application Schedule: State P O Box 806 (919)740-7325 P O Box 806 Existing Permit Data Ahoskie,NC 27910 701 Corporate Center Ahoskie,NC 27910 Existing Permit Number: 03707/R19 Drive Existing Permit Issue Date: 02/03/2021 Raleigh,NC 27607 Existing Permit Expiration Date: 02/28/2025 Review Engineer: Yongcheng Chen Comments/Recommendations: Issue 03707/R20 Review Engineer's Signature: Date: 5/5/2021 Permit Issue Date: 5/11/2021 / " tl 4", Permit Expiration Date: 02/28/2025 Purpose of Application: An application was received on 2/17/2021 from FSC II, LLC - Windsor Asphalt Plant. to request adding Natural Gas as a combustion source. This is based on the Permit Applicability Determinations made by Betsy Huddleston, Regional Supervisor, WaRO on February 9, 2021: Facility 0800018, Permit 03 707R19-Windsor, Bertie County FSC II, LLC wants to burn natural gas. It is not currently listed on the permit as a fuel, so a permit modification is needed. Since Permit R19 was just issued for ownership change to FSC II, LLC, I think it's best to add natural gas to the permit through a written request for administrative change. Please provide this request within 30 days of the permit issuance date. A hard copy with authorized signature is needed, but an email copy will allow DAQ to begin processing sooner. No fee is required for the administrative change. The facility is a typical batch asphalt plant. The facility also has a RAP crusher. The aggregate is conveyed to a drum where it is dried. The aggregate is then separated by a screening process. The aggregate is then mixed in the desired proportions, injected with asphalt,weighed,and transferred to a storage silo. The asphalt is then unloaded into trucks. This facility is permitted for two operating sites that are: 123 NC I I South Bypass, Lewiston, Bertie County and SR 1527 County Farm Road, Windsor, Bertie County It is currently located on SR 1527 in Windsor. 2. Application Chronology: Application Received 02/17/2021 Fee Received and Acknowledgement Letter Sent 02/17/2021 Permit Issued 05/11/2021 3. New Equipment/Changes in Regulatory Requirements: No new equipment was added with this application. A switch to a fuel or raw materials is not considered as a modification but as an administrative change. The 2Q .0315 "Limitation to Avoid" — Synthetic Minor Condition is still in place and is not affected by this change as long as the facility does not emission more than the limits in the permit. 4. NSPS, NESHAPS, PSD,Attainment Status, 112r: a. NSPS-No NSPS Subpart is applicable to this facility. Subpart I is not applicable to the asphalt plant because it has not made any modifications (defined as changes which increase emissions) since the Subpart was promulgated in June 1973 (this facility was apparently constructed in 1972). Subpart 000 is not applicable to the crusher because it is portable and has a capacity less than 150 tons per hour. b. NESHAPS -No NESHAP Subpart is applicable to this facility c. PSD—Without the synthetic minor restriction,this facility would be major for PSD for carbon monoxide. However, it was constructed before the PSD applicable date of June 1, 1975, so the initial construction did not trigger PSD. There is no condition currently in the Permit limiting emissions to synthetic minor levels for PSD purposes. However, since there have been no major modifications which would trigger PSD, one is not needed at this time to avoid PSD applicability. (Note that a switch to a fuel or raw materials is not considered as a modification). Bertie County has been triggered for increment tracking for S02,PM-10,and NOx(NO2 actually),but no changes in emissions occur because of this modification since the same limits are holding for this synthetic minor permit. d. Attainment Status - This facility is in an attainment area. e. 112r - The facility does not handle, store, or use any 112r pollutants in sufficient quantity to be subject to this regulation (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 2 5. Facility Wide Air Toxics: Since this facility has not made any modifications which increased TAP emissions since September 1993, the toxics rules are not applicable. A toxics review is not trigged by this ownership change application. 6. Facility Compliance Status: This facility was inspected by Kurt Tidd of the WaRO on 7/8/2020 and appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. 7. Facility Emissions Review: Not done for an administrative change application. The potential emissions in the table below were taken from previous permit reviews as no equipment changes have been made. These were generated by NCDEQ asphalt spreadsheets. 2Q .0315 "Limitation to Avoid" — Synthetic Minor Condition is still is not affected by this change as long as the facility does not emission more than the limits in the permit. TOTAL FACILITY EMISSIONS Actual Potential Emissions - Potential Emissions Pollutant Emissions Synthetic Minor -No controls or (tons/yr) restrictions (tons/yr) restrictions (tons/yr) TSP 0.48 6.87 72.03 PM-10 0.30 4.61 27.58 S02 1.12 99 668.72 NOx 1.28 20.36 133.67 VOC 0.40 7.89 57.08 CO 4.07 61.25 441.34 Total HAPS <1 <10 <10 8. Stipulation Review and Regulatory Review: 2D .0202 "Registration of Air Pollution Sources" This Rule gives the Director the authority to require the registration of air pollution sources, and require them to submit information about the source. It is under this Rule that the Division is requiring facilities to submit an emissions inventory 90 days before their air quality permit expires. 21). 0506—"Control of Particulates from Hot Mix Asphalt Plants" This is applicable to particulate matter emissions from the operation of the asphalt plant. Maximum allowable particulate matter emissions from the asphalt plant operation are determined from the equation: E =4.9445 * (P) 0.4376 (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 3 Visible emissions from stacks or vents at a hot mix asphalt plant shall be less than 20 percent opacity. Previous inspections have noted compliance with the dust and fugitive emission requirements. 2D .0515—"Particulates From Miscellaneous Industrial Processes" This Rule applies to the asphalt crusher. This crusher has a maximum capacity of 50 tons/hr. Therefore the maximum allowable particulate matter emissions from the crusher are determined by the equation: E = 55.0 * (P) 0" -40 The maximum allowable particulate matter emissions are 44.6 lb/hr. Using the AP-42 emission factor for a primary crusher,the PM emissions at maximum crushing capacity are 0.0351b/hr. Thus compliance is easily expected. 2D.0516 - "Sulfur Dioxide Emissions from Combustion Sources" This is applicable to the asphalt plant. Sulfur dioxide emissions from the plant shall not exceed 2.3 pounds per million Btu heat input. Using unadulterated or equivalent recycled No.4 fuel with a sulfur content of 2.0%,the sulfur dioxide emissions from the asphalt plant would be about 1.86 lb per million Btu. Compliance is expected. 2D .0521 - "Control of Visible Emissions" This Rule applies to the asphalt plant and crusher which were manufactured after July 1, 1971; therefore, visible emissions from these processes 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(4)times in any 24-hour period. Compliance with this rule has been indicated. 2D.0535 - "Excess Emissions Reporting and Malfunctions" The facility is required to report excess emissions which last for more than four hours that result from a malfunction, a breakdown of process or control equipment or any other abnormal conditions. A notification condition is included in the permit. 2D .0540 - "Particulates from Fugitive Dust Emission Sources" The facility must not allow fugitive dust emissions to become a nuisance outside of the facility boundaries. If a second substantive complaint is received concerning such dust emissions, the facility is required to produce a dust control plan. No dust problems have been noted. 2D .0605 - "Testing Requirement" NCDEQ's testing policy for asphalt batch plants was clarified in a memorandum dated August 13, 2013. Some plants can be granted an alternate compliance method, but this plant does not fall under the necessary condition "T Asphalt plants that are classified as "small"or that have actual average production rates of less than 40,000 tons per year(in the prior 36 calendar months before a required test)may petition for an alternate compliance method provided it is not otherwise required to test by some other regulation or has a demonstrated compliance issue (e.g., opacity issues,poor operation and maintenance in those prior 36 calendar months)." (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 4 Asphalt plants that meet certain criteria must test every 10 years. The last stack test was done on 5/3/2018, therefore testing is required and the date is still set up to be 5/3/2028. 2D .0611 "Fabric Filter Requirements" It is under this Rule that the control device I and M requirements are implemented. This Rule requires that the facility maintain records of all inspections and variances from manufacturer's recommendations for bagfilters. Also all maintenance activities must be recorded in a logbook. They will need to check their bagfilter systems annually. 2D .0611 "Cyclone Requirements" It is under this Rule that the control device I and M requirements are implemented. This Rule requires that the facility maintain records of all inspections and variances from manufacturer's recommendations for cyclones. Also all maintenance activities must be recorded in a logbook. They will need to check their cyclone systems annually. 2D .1806 "Control and Prohibition of Odorous Emissions" The facility may not operate without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions that would go past the property boundary and create a nuisance. 20 .0311 - "Permitting of Facilities at Multiple Temporary Sites" This is the Rule authorizing emissions from a facility or source at multiple temporary sites. At least ten days before each relocation of the plant,the facility must provide written notice to the Regional Supervisor, DAQ responsible for the new location. This written notice needs to include the following: • The installation or relocation dates; • A list of the equipment affected by the installation or relocation; • The county in which the equipment was installed or to which the equipment was relocated; and • The county from which the equipment was relocated(if applicable). 20 .0315 "Limitation to Avoid" — Synthetic Minor Condition To avoid Title V, the facility needs to limit potential CO, S02 and NOx emissions below 100 tons per year. The facility likes to have the flexibility to burn No. 2 and No. 4 fuel oils (virgin or recycled) as desired by keeping the annual emissions below the TV thresholds. Compliance has been indicated during through inspections and annual reports. The Synthetic Minor Condition is not affected by this change as long as the facility does not emission more than the limits in the permit. 20 .0317 "Recycled Asphalt Shingle Requirements" This facility is also permitted to use post-consumer reclaimed asphalt roofing shingles(also known as PRAS and herein called recycled shingles). This Rule also allows for the avoidance of certain Rules and requirements if they demonstrate the recycled shingles are equivalent to their virgin or unadulterated counterparts. The requirements are included in the Permit. Through testing and recordkeeping, the facility must also demonstrate that the recycled shingles and roofing materials are certified to be free of asbestos containing material (ACM). So far the facility has not started using recycled shingles. (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 5 20 .0317 "Recycled No. 2 & No. 4 Fuel Oil Requirements" This Rule allows for the avoidance of certain Rules and requirements. This facility uses recycled fuel. It is under this Rule that a facility can avoid the applicability of 2Q .0700 requirements if they demonstrate the recycled fuel is equivalent to unadulterated fuel. The fuel requirements are included in the Permit. The facility will need to keep records of the recycled fuel delivered to the site and submit annual reports of any analytical testing performed and the amount of fuel delivered. The plant has been using Recycled No. 4 fuel and compliance with this requirement has been indicated. Other Stipulation Issues—All stipulations are updated by using Permit Writer and covered in the regulatory review. 9. Conclusions, Comments and Recommendations: Issue Permit No. 03707R20. (SharePoint\Facilities\Bertie08\00018\20210511r20.docx) Page 6