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HomeMy WebLinkAboutAQ_F_0900009_20200908_PRMT_PmtApp_.20E �r r � 1 � �J �'` ► � '*. ice:, t I [ , , r., IIrT �� -- .►� Document details The details entered below are automatically shown on the cover and the main page footer. PLEASE NOTE:This table must NOT be removed from this document. Document title Title V Operating Permit Renewal Application Document subtitle The Chemours Company—Fayetteville, North Carolina Project No. 0544370 Date 2 September 2020 Version 1.0 Author Kevin Eldridge Client Name The Chemours Company—Fayetteville, North Carolina Document history ERM approval to issue Version Revision Author Reviewed by Name Date Comments 1 0 Kevin Eldridge Christy Jeff Twaddle 00.00.0000 Text Richardson I www.erm.corn Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Signature Page 2 September 2020 Title V Operating Permit Renewal Application The Chemours Company — Fayetteville, North Carolina Jeff Twaddle, PE Kevin Eldridge Partner Project Manager ERM NC, Inc. 4140 Parklake Ave Suite 110 Raleigh, NC 27616 ©Copyright 2020 by ERM worldwide Group Ltd and/or its affiliates("ERM"). All rights reserved.No part of this work may be reproduced or transmitted in any form, or by any means,without the prior written permission of ERM www.enn.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 TITLE V OPERATING PERMIT RENEWAL APPLICATION CONTENTS The Chemours Company—Fayetteville,North Carolina CONTENTS 1. INTRODUCTION ................................................................................................................................1 2. PROCESS OVERVIEW......................................................................................................................2 3. TITLE V PERMIT CHANGES.............................................................................................................9 3.1 Permit Changes Since Last Title V Permit Renewal.............................................................................9 3.2 Proposed Permit Changes..................................................................................................................13 4. ACTUAL EMISSIONS......................................................................................................................19 5. AIR REGULATORY APPLICABILITY ANALYSIS..........................................................................20 5.1 Federal Regulations............................................................................................................................20 5.1.1 Permitting Programs..........................................................................................................20 5.1.2 New Source Performance Standards,40 CFR Part 60......................................................21 5.1.3 National Emission Standards for Hazardous Air Pollutants,40 CFR Part 61.....................23 5.1.4 National Emission Standards for Hazardous Air Pollutants,40 CFR Part 63.....................23 5.1.5 Compliance Assurance Monitoring(CAM),40 CFR Part 64..............................................26 5.1.6 Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r), 40 CFR Part 68.............................................................26 5.1.7 Protection of Stratospheric Ozone,40 CFR Part 82..........................................................26 5.2 State of North Carolina Regulations...................................................................................................27 5.2.1 15A NCAC 02D .0202—Registration of Air Pollution Sources...........................................29 5.2.2 15A NCAC 02D .0503—Particulates from Fuel Burning Indirect Heat Exchangers...........29 5.2.3 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes................29 5.2.4 15A NCAC 02D.0516—Sulfur Dioxide Emissions from Combustion Sources..................29 5.2.5 15A NCAC 02D.0521 -Control of Visible Emissions........................................................29 5.2.6 15A NCAC 02D.0524—New Source Performance Standards..........................................30 5.2.7 15A NCAC 02D .0530—Prevention of Significant Deterioration........................................30 5.2.8 15A NCAC 02D .0541 —Control of Emissions from Abrasive Blasting..............................30 5.2.9 15A NCAC 02D.1100—Toxic Air Pollutant Emission Limitation and Requirements and 15A NCAC 02Q.0711 —Toxic Air Pollutant Procedures.............................................31 5.2.10 15A NCAC 02D.1111 —Maximum Achievable Control Technology..................................31 5.2.11 15A NCAC 02D.1806—Control and Prohibition of Odorous Emissions............................31 5.2.12 15A NCAC 02Q .0317—Avoidance Conditions.................................................................31 APPENDIX A DAQ APPLICATION FORMS APPENDIX B REDLINED PERMIT APPENDIX C CAM PLAN APPENDIX D EMISSION CALCULATIONS FOR I-RICE-05 www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page iii TITLE V OPERATING PERMIT RENEWAL APPLICATION CONTENTS The Chemours Company-Fayetteville,North Carolina List of Tables Table 2-1. List of Emission Sources .............................................................................................................5 Table 2-2. List of Insignificant Activities........................................................................................................7 Table 3-1. Permit Changes Since Last Renewal........................................................................................10 Table 3-2. Proposed Permit Changes.........................................................................................................14 Table 4-1. Summary of Actual Controlled Emissions (tpy)a........................................................................19 Table 5-1. Summary of NSPS Requirements.............................................................................................22 Table 5-2 Summary of MACT Requirements..............................................................................................25 Table 5-3 Applicable North Carolina Air Regulations .................................................................................28 List of Figures Figure 2-1. Chemours—Fayetteville Works Site Property Boundary and Fenceline...................................4 Figure 2-2. Thermal Oxidizer and Scrubber System Layout.........................................................................8 www,erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page iii TITLE V OPERATING PERMIT RENEWAL APPLICATION CONTENTS The Chemours Company-Fayetteville,North Carolina Acronyms and Abbreviations Name Description Acfm actual cubic feet per minute AERO Air Emissions Reporting On-line Btu British thermal unit CAA Clean Air Act CaF2 calcium fluoride CFR Code of Federal Regulations CH4 methane CO carbon monoxide CO2 carbon dioxide CO2e carbon dioxide equivalent DAQ Division of Air Quality DEQ North Carolina Department of Environmental Quality dscf dry standard cubic feet dscfm dry standard cubic feet per minute EAF Electric Arc Furnace eGGRT Electronic Greenhouse Gas Reporting Tool EPA United States Environmental Protection Agency F fluorides gr grains HAP Hazardous Air Pollutant HCI hydrogen chloride HF hydrogen fluoride hp horsepower lb(s) pounds LMF ladle metallurgical furnace MACT Maximum Achievable Control Technology MM Million MSRM1 melt shop roof monitor NCAC North Carolina Administrative Code NESHAP National Emission Standards for Hazardous Air Pollutants NOx nitrogen oxides NSPS New Source Performance Standards N20 nitrous oxide PM particulate matter PM10 particulate matter with an aerodynamic diameter less than 10 microns PM2.5 particulate matter with an aerodynamic diameter less than 2.5 microns PSD Prevention of Significant Deterioration RMP Risk Management Plan scfm standard cubic feet per minute S02 sulphur dioxide tph tons per hour tpy tons per year VOC volatile organic compounds www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page iii TITLE V OPERATING PERMIT RENEWAL APPLICATION INTRODUCTION The Chemours Company—Fayetteville,North Carolina 1. INTRODUCTION The Chemours Corporation (Chemours) owns and operates a chemical manufacturing facility located at 22828 NC Highway 87 West in Fayetteville, Bladen County, North Carolina(Chemours Company— Fayetteville Works). The facility currently operates under Title V Operating Permit Number 03735T48 issued by North Carolina Department of Environmental Quality(DEQ), Division of Air Quality (DAQ) on 13 May 2020 and effective on 12 July 2020. Title V Operating Permit Number 03735T48 expires on 31 March 2021. As provided in Title V Permit Condition 3.K and 15A North Carolina Administrative Code (NCAC) 02Q .0513, the permittee must submit a complete Title V renewal application at least six months prior to the date of permit expiration. This application is intended to satisfy all the requirements of Title V of the 1990 Clean Air Act(CAA)as encoded in 40 Code of Federal Regulations (CFR) Part 70 and in 15A NCAC 02Q .0500, "Title V Procedures." Section 503(d) of the CAA and Title V Permit Condition 3.K provides that, once a timely and complete application for an operating permit has been filed, the applicant is shielded from enforcement action for operating without a permit until the permit has been issued or other action has been taken on the application. Therefore, by submitting this application, Chemours cannot be subject to enforcement action for operating without a permit during the period in which this permit application is under review if the current permit expires before a new permit is issued. This application is organized as follows: ■ Section 2 includes a process overview of the Chemours Company—Fayetteville Works facility. • Section 3 includes a detailed description of changes that occurred since the last permit renewal, along with a list of proposed changes to the Title V Permit. ■ Section 4 provides a facility-wide summary of actual controlled emissions in tons per year(tpy)for the previous five year period. ■ Section 5 includes a facility-wide regulatory applicability for federal and state air quality rules and regulations. ■ Appendix A includes relevant NC DEQ application forms. ■ Appendix B contains a redlined version of the existing Title V Permit which specifies proposed changes. ■ Appendix C includes Compliance Assurance Monitoring (CAM) plans, as applicable. ■ Appendix D contains emission calculations for a diesel-fired emergency engine. www.errn.com Version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page 1 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company—Fayetteville,North Carolina 2. PROCESS OVERVIEW Chemours Company—Fayetteville Works manufactures chemicals, plastic resins, plastic sheeting and plastic film at its facility located at 22828 NC Highway 87 West, Fayetteville, Bladen County, North Carolina (the facility). A site map detailing the location of the site with property boundaries and fencelines is included in Figure 2-1. The facility is a major source of criteria pollutants under the Part 70 (Title V) Operating Permit Program and a major source of Hazardous Air Pollutants (HAP). Specific materials produced at the Fayetteville facility are: * ChemoursT""Nafion®Membrane (plastic film) used in the chloroalkali industry and in electrochemical fuel cells. ChemoursTm Nafion(D Polymer Dispersions used in the fabrication of thin films and coating formulations for fuel cells membranes, catalyst coatings, sensors, and a variety of electrochemical applications. HFPO monomer and Vinyl Ether monomers used to manufacture various fluorochemical products such as ChemoursTm Teflon@. t, Fluorocarbon intermediates for Nafion@ membranes and other fluorocarbon products, and 15 Fluoropolymer Processing Aids (PPA) used in the manufacturing of fluoropolymers and fluorinated telomers. Production of these materials occurs in several manufacturing or processing areas throughout the plant site, including Hexafluoropropylene Oxide (HFPO) Process, Vinyl Ethers North Process, Vinyl Ethers South Process, RSU Process, MMF Process, IXM Resins Process, Semiworks Polymerization Operations, E-2 Process, TFE/CO2 Separation Process, and Polymer Processing Aid (PPA) Process. In addition to the manufacturing operations, Chemours operates two natural gas-fired boilers and a wastewater treatment plant(WWTP)for the treatment of process and sanitary wastewaters from Chemours, Kuraray, and DuPont(both Kuraray and DuPont are also located on the site). However, no wastewater is discharged currently from the Chemours facility to the WWTP, except reject water from making filtered, deionized/degassed water at the power plant. At this time, all process wastewater generated from the Chemours Company—Fayetteville Works manufacturing facility is collected and shipped off-site for disposal. Chemours also operates several additional ancillary activities such as research laboratories, paint shops, abrasive blasting operations, and emergency generators and fire water pumps. A list of permitted emission sources are included in Table 2-1 and a list of insignificant activities are included in Table 2-2. While Section 3 details proposed changes to the Title V Permit, any emissions source descriptions that vary from the existing Title V Permit are also noted in bold, italicized font in Tables 2-1 and 2-2. Since the last Title V Permit renewal, Chemours has added several additional air emission control devices, primarily for the capture and control of GenX Compounds',while additional VOC reductions are also realized. The additional air emission control devices include a Thermal Oxidizer and 4-Stage Scrubber System (CD Nos. NCD-Q1 and NCD-Q2)for the control of process emissions from several process areas. Figure 2-2 details the sources controlled by the Thermal Oxidizer and 4-Stage Scrubber ' "GenX Compounds"means HFPO Dimer Acid,also known as C3 Dimer Acid(CAS No. 13252-13-6);HFPO Dimer Acid Fluoride, also known as C3 Dimer Acid Fluoride(CAS No.2062-98-8);and HFPO Dimer Acid Ammonium Salt,also known as C3 Dimer Acid Ammonium Salt(CAS No.62037-80-3). www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 2 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company—Fayetteville,North Carolina System. In addition to the Thermal Oxidizer and 4-Stage Scrubber System, Chemours has installed several carbon adsorbers for various process emissions and indoor fugitive emissions. The control devices utilized for each emission source is detailed in the table of emission sources (Table 1-1). www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 3 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company-Fayetteville,North Carolina Figure 2-1. Chemours — Fayetteville Works Site Property Boundary and Fenceline 3860000•- 385950<= 3859000 :3858500 3858000 3857500 i 3857000 � w 38565 385600( 385550 ` 6 3855000 3854 opOp95 "� � • - 000 695500 696000 696500 69•'000 697500 69,5000 698500 699000 699500 700000 www.erm.com version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page 4 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company—Fayetteville,North Carolina Table 2-1. List of Emission Sources Emission Control Control Device Description Source ID Emission Source Description Device ID 1 Natural gas/No. 2 fuel oil-fired boiler(139.4 million Btu per hour maximum PS-A heat input)equipped with an oxygen trim system N/A NIA PS-B Natural gas/No.2 fuel oil-fired boiler(88.4 million Btu per hour maximum N/A N/A heat input)equipped with an oxygen trim system Natural gas/No.2 fuel oil-fired boiler(97 million Btu per hour maximum heat PS-C input)equipped with a low-NOx burner and an oxygen trim system N/A NIA PS-Temp Natural gas/No.2 fuel oil-fired temporary boiler(less than 100.0 million Btu N/A N/A per hour maximum heat input) NS-A Hexafluoropropylene oxide(HFPO)process NS-B Vinyl Ethers North process Thermal Oxidizer(10 million Btu per hour, NS-C Vinyl Ethers South process NCD-Q1 natural gas-fired) i - - - - ----- — And And NS-D-1 RSU Process(except S03 System) NCD-Q2 4-Stage Scrubber: Countercurrent Packed Bed Stages 1, 2, and 3; Caustic Stage 4 NS-E FPS Liquid waste stabilization NS-F MMF process NS-G-2 IXM Resins Process Fluorinator NCD-G2 Caustic scrubber NS-D-2 RSU Process S03 System: NCD-D Wet scrubber with mist eliminator S03 Storage Tank, Vaporizer, S03 Truck Unloading, Reservoir Tank NS-H IXM membrane process N/A N/A NS-1 IXM membrane coating N/A N/A www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 5 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company—Fayetteville,North Carolina SW-1 Semiworks polymerization operation SCD-SW1 Carbon Adsorber SW-2 Semiworks laboratory hood NSG-1 — IXM Resins Process(except Fluorinator) -- - NS-K E-2 Process Thermal Oxidizer(10 million Btu per hour, NCD-Q1 natural gas-fired) NS-M TFE/CO2 separation process -- And And NS-N HFPO product container decontamination process INCD-Q2 4-Stage Scrubber: Countercurrent Packed Bed Stages 1,2, and 3; Caustic Stage 4 NS-O Vinyl Ethers North product container decontamination process NS-P Vinyl Ethers South product container decontamination process NS-B-2 Vinyl Ethers North Indoor Fugitives NCD-Q3 Carbon Adsorber NS-C-2 Vinyl Ethers South Indoor Fugitives NCD-Q4 Carbon Adsorber ACID-Al Wet scrubber AS-A Polymer Processing Aid Process And and ACID-A2 Carbon Adsorber WTS-A Extended aeration biological wastewater treatment facility N/A N/A WTS-B, Two(2)Indirect steam-heated rotary sludge dryers WTCD-1 Wet scrubber with mist eliminator WTS-C NS-R1 Lime Silo NCD-R1 Pulse Jet Baghouse NS-R2 Lime Slaker NCD-R2 Wet Particulate Scrubber www.erm.com Version:1.0 Project No.:D544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 6 TITLE V OPERATING PERMIT RENEWAL APPLICATION PROCESS OVERVIEW The Chemours Company—Fayetteville,North Carolina Table 2-2. List of Insignificant Activities Source ID No. Emission Source Description 1-02 Waste DMSO Storage Tank 1-03 Fugitive Emissions of Methylene Chloride 1-04 Chlorination of Riverwater to control mussel growth in equipment 1-05-1 Sitm ide Laboratory Emissions(not including VE Research Laboratory Hood and VE Research Laboratory Chemical Storage Cabinet) 1-05-2 VE Research Laboratory Hood and VE Research Laboratory Chemical Storage Cabinet routed to a Carbon Adsorber(ID No. SCD-SW1) 1-06 Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension 1-07 Paint shop 1-08 Self-contained abrasive blasting cabinets 1-09 Paint spray booths 1-10 Abrasive blasting and painting building 1-12 IXM Dispersion Process I-CT Cooling Tower(6,000 gallons per minute, expandable to 8,000 gallons per minute) I-RICE-01 Diesel Engine for Stack Blower Emergency Electrical Generator I-RICE-02 Diesel Engine for Emergency Fire Water Pump I-RICE-03 Diesel Engine for HFPO Barricade Emergency Electrical Generator I-RICE-04 Diesel-Fired Emergency Generator for Thermal Oxidizer System(320 hp) I-RICE-05 Diesel-Fired Emergency Generator for Remediation Treatment System(540 hp) www.erm.com Version:1.0 Project No.:0544370 Client:i'he Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 7 PROCESSTITLE V OPERATING PERMIT RENEWAL APPLICATION OVERVIEW indoorThe Chemours Company—Fayetteville,North Carolina Figure 2-2. Thermal Oxidizer and Scrubber System Layout VES VES Carbon Adsorber(NCD-04) IndoorVEN VEN Carbon Adsorber(NCD-Q3) NS-A: HFPO NS-B: Vinyl Ethers North NS-C: Vinyl Ethers South NS-D-1: RSU(except SOs System) NS-E: FPS Liquid Waste Stabilization Gas Accumulator NS-F: MMF (Monomers and Precursors) NS-N: HFPO Product Container Decontamination NS-O: VEN Product Container Decontamination NS-P: VES Product Container Decontamination Thermal Oxidizer/ Scrubber System (NCD-Q1 and Q2) NS-G-1: IXM Resins(except Fluorinator) Gas Accumulator NS-K: E-2 (Polymer and TFE) NS-M: TFE/COz Separation 05443702020 Page B TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina 3. TITLE V PERMIT CHANGES The Chemours Company—Fayetteville Works facility has applied for and received several Title V Permit modifications since the last Title V Permit renewal application was submittal. Those changes are detailed throughout Section 3.1. Chemours is also requesting additional changes, updates, and/or corrections to the existing Title V Permit application as part of this renewal application. Those proposed changes are detailed throughout Section 3.2. 3.1 Permit Changes Since Last Title V Permit Renewal Chemours submitted the last Title V Permit renewal application in April 2014, which was processed and those changes incorporated in Permit No. 03735T42 with an effective date of April 22, 2016. Since the issuance of Permit No. 03735T42, Chemours has requested modifications which include increase in membrane spray coating throughput, installation of carbon adsorbers, installation of the Thermal Oxidizer/4-Stage Scrubber System, and additional changes as summarized in Table 3-1. www.enn.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 9 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-1. Permit Changes Since Last Renewal Permit# Application Effective Date Changes Date Spray Coating Throughput Increase Project 03735T43 28 October 2016 14 December 2016 ■ Added a row to the summary of limits and standards table for the VOC 15A NCC 02D .0530(u)condition and ■ Added new Section for the use of projected actual emissions to avoid applicability requirements. Thermal Oxidizer/4-Stage Scrubber System Project,VE-North Carbon Adsorber, and PPA 03735T44 13 March 2019 29 May 2019 Carbon Adsorber ■ Added Thermal Oxidizer and 4-Stage Scrubber System as the control device under the alternative operating scenario(AOS); and associated regulations ■ Added a new Diesel-Fired Emergency Generator; ■ Added Cooling Tower ■ Divided DCM Resins Process into two sources: IXM Resins Process(except Fluorinator) and Resins Process Fluorinator; ■ Renamed existing baffle plate scrubbers installed on FPS/IXM Process Area Sources as primary operating scenario (POS); ■ Added sources from Lime Processing: Lime Silo controlled by a bin vent baghouse and Lime Slaker controlled by a wet particulate scrubber; and associated regulations ■ Added VE-North Indoor Fugitives to be controlled by Carbon Adsorber; ■ Added Carbon Adsorber as a control device to Polymers Processing Aid Process; ■ Updated PSD VOC emission calculations,to include POS and AOS calculations and corrected scrubber control efficiency for POS; www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 10 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-1. Permit Changes Since Last Renewal Permit# Application Effective Date Changes Date ■ Reworded/revised PSD VOC conditions to account for the acid fluoride and VOC removal efficiencies; ■ Added to include regulation 15A NCAC 02Q .0519 for reduction of PFAS emissions; ■ Updated toxic emission limits for HF to account for the Thermal Oxidizer;and ■ Added a condition requiring the Permittee to comply with a GenX emissions limitation in the Consent Order. Change of Boiler MACT Subcategory for PS-B from 'Units designed to burn light liquid fuel'to 03735T45 13 March 2019 29 May 2019 'Units designed to burn gas V ■ Revised summary of limits and standards table to remove reference to emission limits associated with units designed to burn light liquid fuel; and Revised to add Boiler PS-B to existing source requirements under the Subpart DDDDD units designed to bum gas I fuels subcategory. Addition of RSU S03 System and Part II Application for the IXM Membrane Spray Coating 03735T46 26 April 2018 6 December 2019 Throughput Increase Project and ■ Added RSU process S03 System as a separate source under the RSU Process;and associated regulations 27 August 2018 ■ Removed the requirement for submittal of a Title V permit application for the throughput increase in the IXM Membrane Coating Process Change Performance Test Report Due Dates to 45 Days 03735T47 20 November 2019 8 January 2020 ■ Added a sentences in various permit conditions specifying that the performance test reports shall be submitted not later than 45 days, instead of the general 30 day period.These changes align the reporting period for performance test reports with the Chemours Consent Order. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 11 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-1. Permit Changes Since Last Renewal Permit# Application Effective Date Changes Date Addition of VE-South Carbon Adsorber and Semiworks Carbon Adsorber, Revision to Lime 03735T48 13 February 2020 13 May 2020 Slaker Scrubber Minimum Flow Rate, and Clarified Requirement for Inspection of the Thermal Oxidizer/4-Stage Scrubber System And rr Split emission source Site-wide Laboratory Emissions into two sources to distinguish 21 April 2020 between those routed to the carbon adsorber and those that remain uncontrolled; • Added carbon adsorber as control device for Semiworks Polymerization Operation and Semiworks Laboratory Hood as well as the VE Laboratory Hood and VE Research Laboratory Chemical Storage Cabinet; ■ Added emission source for VE-South Indoor Fugitives and associated carbon adsorber; ■ Changed scrubber minimum flow rate for Lime Slaker Scrubber from 2.9 gallons per minute to 0.84 gallons per minute; ■ Updated table of limits and standards to clarify the affected sources subject to the conditions for all PFAS and GenX compounds; ■ Added a condition to include the carbon adsorbers in the alternative operating scenario; • Corrected condition to reflect DAQ's intention that detailed inspections need to be conducted when the Thermal Oxidizer and 4-Stage Scrubber System are nonoperational for a minimum of 72 hours. wvw.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 12 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina 3.2 Proposed Permit Changes As previous discussed, the Chemours Company— Fayetteville Works facility currently operates under Title V Permit No. 03735T48, which became effective on 12 July 2020. Chemours has conducted a thorough review of the current Title V Permit and developed a list of proposed changes to the permit which is detailed in Table 3-2. The majority of the proposed changes are related to the removal of permit conditions that are no longer applicable, such as: ■ Case-by-Case MACT requirements for the boilers. The boiler are now subject to the requirements of the federal Boiler MACT(40 CFR 63, Subpart DDDDD); therefore, the Case-by-Case MACT requirements are no longer applicable. * Primary Operating Scenarios(POS). Chemours is currently operating under the Alternative Operating Scenario (AOS), which includes operation of the Thermal Oxidizer and 4-Stage Scrubber System; therefore, reference to the POS can now be removed from the permit. ■ Completed Compliance Requirements. There are several permit conditions that contain initial compliance requirements that have been satisfied. To avoid confusion, Chemours is requesting removal of those requirements from the permit. Additional changes such as clarification to the carbon bed testing requirements, updates to Toxic Air Pollutant reporting requirements, and additional minor changes throughout for clarification purposes are also detailed in the list of proposed permit changes in Table 3-2. A redlined version of Title V Permit No. 03735T48 is also included in Appendix B. Chemours is also requesting the addition of a Diesel-Fired Emergency Generator for the Remediation Treatment System, with a rating of 540 horsepower(ID No. I-RICE-05). The emergency generator qualifies as an insignificant activity under 15A NCAC 02Q .0503(8) since potential emissions of criterial pollutants are less than 5 tons per year and potential emissions of HAPs are less than 1,000 pounds per year. Potential emission calculations for the diesel-fired emergency engine are included in Appendix D. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 13 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-2. Proposed Permit Changes Permit Condition Proposed Change Insignificant Activities Table Add descriptor to I-RICE-04"Diesel-Fired Emergency Generator for Thermal Oxidizer System(320 hp)" Add I-RICE-05 540 hp Diesel-Fired Emergency Generator for the Remediation Treatment System Section I Table of Emission Sources Remove reference to the Case-by-Case MACT for PS-A, PS-B and PS-C. Change"VE-North Indoor Fugitives"to"Vinyl Ethers North Indoor Fugitives" Change"VE-South Indoor Fugitives"to"Vinyl Ethers South Indoor Fugitives" Remove POS throughout table, as it no longer exist. NS-M remove note. It is no longer applicable. NS-N remove note. It is no longer applicable. NS-O remove note. It is no longer applicable. NS-P remove note. It is no longer applicable. Remove footnote for the Lime Slaker.The condition is no longer applicable. Section 2.1 (A)(6) Remove condition, compliance date is in the past. Section 2.1 (A)(7)(e)(1)and(ii) Change the condition as follows: The Permittee shall comply with the GAA§112(j)Stan ards; m—SeGl,ig-2Tn s 4k—, 6A„y 10 2019 rnn GFR 63 7495(a)and(b) 63 56(b)] i. On And after AA y 20 201- 11 oo. shall GGFnply..,:+r,the requirements of Section 2.1 A.7 for the boilers (ID Nos. PS-A and PS-B) ii. The Permittee shall comply with the requirements of this section for boiler(ID No. PS_C)an May 0, www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 14 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-2. Proposed Permit Changes Permit Condition Proposed Change 201 A of upon startup,whf..h..yei: late f Boiler PS-C has not been installed. Section 2.1 (A)(7)(f) Change the condition as follows: As specified in 40 CFR 63.9(b)(4)and(5), if the initial sta to ^^f for the boiler(ID No. PS-C)ice, May '^2^' ,the Permittee shall submit an Initial Notification not later than 15 days after the actual date of startup of the boiler. [40 CFR 63.7545(c)] Boiler PS-C has not been installed. Section 2.1 (A)(7)(g) Change condition as follows: The Permittee shall submit a Notification of Compliance Status for the boilers(ID Nos. oc a PS o and PS- C).The notification must be signed by a responsible official and postmarked before the close of business within 60 days of the startup of the boiler.the GerRplq2RGe daie peo+fe441-see}„ 2.1 A4.e, above. The notification shall contain the following: NOCS for PS-A and PS-B has already been submitted. Boiler PS-C has not been installed. Section 2.1 (A)(7)(g)(i) A description of the boilers(ID Nos. PS A,oc_Q and PS-C), including a statement that the boilers afe is in "the unit designed to burn gas 1 subcategory,"the design heat input capacity of the boilers, and description of the fuel(s)burned. The NOCS for PS-A and PS-B has already been submitted. Boiler PS-C has not been installed. Section 2.1 (A)(7)(g)(ii)(A) A signed certification that the facility completed the required initial tune-up for the boiler(ID No. PS-C)all of the boilers covered by 40 CFR Part 63, Subpart DDDDD according to the procedures Section 2.1 A.7.j, below;and Section 2.1 (A)(7)(k)(i) Remove condition, initial tune-up for PS-A and PS-B has already occurred. Section 2.1 (A)(7)(n) Remove condition,the one-time energy assessment has already occurred. www.erm.com Version:1.0 Project No.:0544370 Client:1'he Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 15 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-2. Proposed Permit Changes Permit Condition Proposed Change Section 2.1 (A)(7)(r) I The Permittee shall submit the annual compliance report via the CEDRI. (CEDRI can be accessed throughthe EPA's Central Data Exchange, CDX.) As specified in 40 CFR 63.7550(b), "For units that are subject only to a requirement to conduct subsequent annual, biennial, or 5-year tune-up according to§63.7540(a)(10), (11), or(12), respectively, and not subject to emission limits or Table 4 operating limits, you may submit only an annual, biennial, or 5-year compliance report, as applicable, as specified in paragraphs(b)(1)through (4)of this section, instead of a semi-annual compliance report." Since PS-A, PS-B, and PS-C are not subject to emission limits or operating limits and tune-ups are required every 5 years,the compliance report is required to be submitted on a 5-year basis. Section 2.1 (B) Remove all references to POS and AOS as these are no longer applicable since the facility is operating solely under the AOS. Section 2.1 (B)(1) Remove condition since the facility is now operating under the AIDS. Section 2.1 (B)(3)(a) Remove reference to AOS. Remove reference to AOS and POS. Change to" Calculate the VOC emissions(Ev)from the process Section 2.1 (13)(5)(c)(ii) vents during the previous calendar month(in lb/month)using the following equation: Ev = 0.0001 x(QAF+ QAFY Section 2.1 (13)(6)(c)(v) Remove reference to AOS and POS. Change to"Calculate the VOC emissions(E)from the affected facility during the previous calendar month(in ton/month)using the following equation: E=(1-0.9999)*(M- P-WfS)*(2.21b/kg)/(2,0001b/tony' Section 2.1 (B)(7(c)(iii) Remove condition (A)and delete reference to AOS Section 2.1(B)(7(c)(iv) Remove condition(A)and delete reference to AOS Section 2.1 (B)(B)(c)(ii)(B) Delete reference to AOS www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 16 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-2. Proposed Permit Changes Permit Condition Proposed Change Section 2.1 (B)(11) Remove the Title"Alternative Operating Scenario'above condition. Section 2.1 (13)(11)(a)(i) Remove"No later than December 31, 2019"since the Thermal Oxidizer/Scrubber System is operational. Section 2.1 (B)(11)(a)(i) Change"install and begin normal operation of a"to'operate a". Section 2.1 (13)(11)(b) Removed the requirements to conduct initial performance testing since initial performance testing has been completed and submitted to NC DEQ. Section 2.1 (B)(11)(b) Remove the sentence"The Permittee shall install sampling ports in compliance with 15A NCAC 02D.2600"since unit is operational and ports were previously installed. Section 2.1 (B)(11)(c) Remove condition since initial compliance report has been submitted. Section 2.1 (13)(11)(d) Remove phrase"After the initial performance test is conducted,"since initial performance testing has been conducted. Section 2.1 (B)(11)(d)(ii) Remove phrase"After the initial performance test is conducted as specified in Section 2.1.13.11.b,above,"since initial performance testing has been conducted. Section 2.1 (B)(11)(g) Change the phrase"develop, and submit to DAQ for approval'to"follow". The site specific monitoring plan has already been developed and submitted to the DAQ. Section 2.1 (B)(11)(g)(i) Remove the phrase"Initial and any"since the initial calibration of the CMS has already occurred. Section 2.1 (B)(11)(k) Remove phrase"Prior to the operation of the Thermal Oxidizer and 4 Stage Scrubber System" i Section 2.1 (E)(5) Remove this condition since Case-by-Case MACT is no longer applicable. Section 2.1 (F)(1)(c) Second sentence change the word"each"to"the" www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 17 TITLE V OPERATING PERMIT RENEWAL APPLICATION TITLE V PERMIT CHANGES The Chemours Company—Fayetteville,North Carolina Table 3-2. Proposed Permit Changes Permit Condition Proposed Change Section 2.1 (17)(2)(c) Remove the last sentence that states"The Permittee shall establish"normal'for the Lime Slaker in the first 30 days following the beginning operation"as this has already been completed. Section 2.2(113)(1)(c) Change reporting requirements from quarterly to annually based on history of compliance with toxics limits. Section 2.2(13)(2)(a) Remove Primary Operating Scenario associated equipment references and emission limits from the table. Delete the phrase"Alternative Operating Scenario"as it is no longer relevant. Delete the title"Primary and Alternative Operating Scenario"from the second to last line of the table as it is no longer relevant. Section 2.2(B)(2)(b)(i) Delete condition as it is no longer relevant. Section 2.2(B)(2)(b)(ii) Delete the phrase"AOS"as it is no longer relevant. Section 2.2(B)(2)(c)(i) Delete condition as it is no longer relevant. Section 2.2(13)(2)(c)(ii) Delete the phrase"AOS"as it is no longer relevant. Section 2.2(13)(2)(e) Change reporting requirements from quarterly to annually based on history of compliance with toxics limits. Section 2.2(D)(1)(c) Made various changes for clarification purposes. Refer to the redlined permit. Section 2.2(D)(1)(f)(1) Remove the phrase"Initial and any subsequent'since the initial calibration of the CMS has already occurred. Section 2.2(D)(1)(g) Change the phrase"No later than April 13, 2019, the Permittee shall develop,and submit to DAQ for approval'to "The Permittee shall maintain"since the plan has been developed and submitted. Section 2.2(D)(1)(h) Delete the first sentence since development and submittal of the plan has already occurred. Section 2.2(D)(1)(h) Second sentence, change the phrase"the approved program"to"an approved enhanced leak detection and repair program"for clarification. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 18 TITLE V OPERATING PERMIT RENEWAL APPLICATION ACTUAL EMISSIONS The Chemours Company-Fayetteville,North Carolina 4. ACTUAL EMISSIONS The manufacturing processes at the Chemours-Fayetteville Works facility emits various pollutants to the atmosphere, including the following: = filterable particulate matter(PM), z particulate matter with an aerodynamic diameter less than 10 microns (PM1o), TM particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5), nitrogen oxides (NOx), carbon monoxide(CO), sulfur dioxide (S02), l� volatile organic compounds (VOC), carbon dioxide (CO2), carbon dioxide equivalent(CO2e), - methane (CH4), l nitrous oxides (N20), fluorides(F) and HAPs Chemours develops annual Air Emission Inventories and submits to DAQ in Air Emissions Reporting On- Line (AERO)by June 30 of each calendar year. Along with those submittals are detailed calculation narratives, including calculation methodologies, emission factors, and rationale, for each process area. A summary of the facility-wide actual controlled emissions in tons per year(tpy)for the last five year period in provided in Table 4-1. Table 4-1. Summary of Actual Controlled Emissions (tpy)a CY S02 NOx ` VOC CO I PM10 PM2.5 Total Largest HAP HAP 2019 0.21 62.47 281.28 28.97 1.00 0.34 22.82 15.26 [Methanol] 2018 0.21 65.87 299.95 29.83 0.94 0.32 27.49 17.93 [Methanol] 2017 0.20 61.63 239.09 33.86 3.97 3.97 34.00 17.29 [Methanol] 2016 0.21 65.19 237.76 36.45 4.16 4.16 33.27 18.44 f [Methanol] ......-....-.........---{------- ...._._.... ---- ------ ------ ------- --------....-- ------------- 2015 i 0.20 55.45 290.39 42.10 1 8.94 8.94 36.82 17.06 [Methanol] a Emissions obtained from Air Emissions Reporting On-line(AERO)system submittal. www-erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page 19 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina 5. AIR REGULATORY APPLICABILITY ANALYSIS The applicability determinations made for potentially applicable federal and state air quality regulations are described in this section for the sources located at the Chemours—Fayetteville Works facility. Federal regulations are reviewed first, followed by North Carolina regulations. A summary detailing applicability of each regulation is provided throughout this section. 5.1 Federal Regulations 5.1.1 Permitting Programs 5.1.1.1 Prevention of Significant Deterioration (PSD) of Air Quality, 40 CFR Part 52 The federal PSD program, codified in 40 CFR Part 52.21, requires any new major stationary source of air pollutants to obtain a major source air construction permit before commencing construction. North Carolina has incorporated the federal PSD program in 15A NCAC 2Q .0300. The PSD program applies to a facility if potential emissions exceed applicable major source thresholds. The facility is considered a chemical process plant,which is one of the 28 listed PSD source categories specified in §52.21(b)(1)(i)(a) with a 100-tpy PSD major source threshold for regulated New Source Review(NSR) pollutants. Since the existing facility is a major source with respect to the PSD program, modifications at the facility must undergo major source review if the proposed project will increase emissions of one of the PSD regulated pollutants in excess of the applicable pollutant Significant Emission Rate (SER)threshold. The current permit has numerous PSD avoidance conditions which will remain in the Title V permit. Chemours opted to take a PSD avoidance limit specified in Permit Condition 2.1 (B)(9) by using projected emissions for the IXM Membrane Process (ID No. NS-1).As such, Permit Condition 2.1 (13)(9)(b)(ii) requires that Chemours submit a report 60 days after the end of each calendar year for the actual VOC emissions from IXM Membrane Coating Process (ID No. NS-1). The report must contains the items listed in 40 CFR 51.166(r)(6)(v)(a), as follows: a The name, address and telephone number of the major stationary source; The annual calculated VOC emissions; and * Any other information that Chemours wishes to include in the report. 5.1.1.2 Nonattainment Area New Source Review (NNSR) NNSR is applicable to construction of a new major stationary source or a project that is a major modification at an existing major stationary source in an area designated as nonattainment for the National Ambient Air Quality Standards (NAAQS). The facility is located in Bladen County which is classified as an attainment or unclassifiable county for NSR pollutants. Thus, the facility is not subject to NNSR. 5.1.1.3 Title V Operating Permit Programs, 40 CFR Part 70 A Title V(Part 70) operating permit is required for facilities that meet the definition of a major source according to 40 CFR Part 70.2.A facility with criteria pollutant emissions greater than 100 tpy, 10 tpy of a single HAP, or 25 tpy of a combination of HAPs is considered a major source under the Title V permitting program. The facility is considered a major source with respect to the Title V permitting program and operates under the current Permit 03735T48. The permit requires that a Title V renewal application be submitted at least six months before the date of permit expiration. This application satisfies the requirements for submittal of a complete renewal application. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September2020 Page 20 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina 5.1.2 New Source Performance Standards, 40 CFR Part 60 New Source Performance Standards (NSPS), codified in Title 40 CFR Part 60, establish pollutant emission limits and monitoring, reporting, and recordkeeping requirements for various emission sources based on source type and size. NSPS applies to new, modified, or reconstructed sources as defined by the particular standard. North Carolina has incorporated the federal NSPS in 15A NCAC 02D .0524. 5.1.2.1 40 CFR Part 60 Subpart A: General Provisions 40 CFR 60 Subpart A conditions are referenced by specific NSPS subparts and as such as mentioned throughout the permit. Chemours will continue to comply with these requirements as applicable. 5. 1.2.2 40 CFR Part 60 Subpart Dc: Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units NSPS Subpart Dc applies to the PS-C boiler which has not yet be installed at the facility. Table 5-1 provides a reference to the permit conditions and applicable NSPS Subpart Dc requirements to the PS-C boiler. 5. 1.2.3 40 CFR Part 60 Subpart Ill/. Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Diesel-fired emergency engines (ID Nos. I-RICE-03, I-RICE-04 and I-RICE-05) are subject to the requirements of NSPS Subpart[Ill. Since these units are listed as insignificant activities, the permit does not identify specific requirements. NSPS Subpart III[ includes requirements, such as emission standards, work practices, and recordkeeping for each emission source, as applicable. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 21 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina Table 5-1. Summary of NSPS Requirements Emission Emission Unit Description NSPS Permit Summary of Requirements Unit ID Subpart Condition PS-C 97 MMBtu/hr Natural gas/No. 2 oil- Dc 2.1 (A)(4) ■ Emissions limitations include maximum fuel sulfur content and fired boiler visible emission limitations. X Records must be maintained for fuel sulfur monitoring and routine opacity monitoring,the amounts and types of each fuel burned during each month, and the occurrence and duration of any startup, shutdown, or malfunction event. ■ Initial notifications for construction and startup shall be submitted as detailed in the permit. ■ Summary reports must be submitted semiannually www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 22 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina 5.1.3 National Emission Standards for Hazardous Air Pollutants, 40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants (NESHAP)are generally applicable to sources of specified HAPs. The NESHAP regulations in 40 CFR 61 are on a pollutant-specific basis. None of the NESHAP regulations in 40 CFR 61 apply to the Chemours facility. 5.1.4 National Emission Standards for Hazardous Air Pollutants, 40 CFR Part 63 The NESHAP regulations in 40 CFR 63 are established based on Maximum Achievable Control Technology(MACT)determinations for particular source types. The facility is a major source of HAP emissions as defined in 40 CFR 63.2. Several emission sources at the facility are subject to 40 CFR 63 MACT requirements. 5.1.4.1 40 CFR 63 Subpart A. General Provisions 40 CFR 63 Subpart A conditions are referenced from specific subparts and are mentioned throughout the permit. Chemours will continue to comply with these requirements as applicable. 5.1.4.2 40 CFR Part 63 Subpart FFFF: National Emission Standards for Miscellaneous Organic Chemical Manufacturing The HFPO, Vinyl Ethers North,Vinyl Ethers South, and IXM Resins processes (ID Nos. NS-A, NS-B, NS- B-2 NS-C, NS-C-2, NS-G-1 and NS-G2)are subject to the requirements of 40 CFR 63, Subpart FFFF, "National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing"(also referred to as the Miscellaneous Organic NESHAP, or MON). The MON includes emission limitations, work practice standards, continuous compliance requirements, recordkeeping, and reporting requirements for various affected sources. The compliance status of the facility was included with the Notification of Compliance Status. Permit Condition 2.1 (13)(10) details the site specific MON requirements. The facility does not operate any Group 1 process vents, Group 1 storage tanks, or transfer racks or loading arms. The facility has Group 2 continuous process vents, one Group 2 wastewater stream, and two heat exchange systems requiring monitoring. There are process streams in all four of the process units that are subject to the equipment leak provisions, or MON LDAR requirements. Chemours has elected to follow 40 CFR Subpart UU for LDAR compliance. Table 5-2 provides an overview of the requirements of Subpart FFFF. 5.1.4.3 40 CFR Part 63 Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 CFR Subpart ZZZZ applies to each of the five emergency engines located at the facility(ID Nos. I- RICE-01, 02, 03, 04, and 05). Since these emissions sources are listed as insignificant activities, the specific requirements of Subpart ZZZZ are not included in the permit. Table 5-2 provides a summary of the requirements for Subpart ZZZZ. For emergency engines that are also subject to the requirements of 40 CFR 60 Subpart III] and have a site rating of less than 500 brake hp, the emission units comply with the requirements of this subpart by meeting the requirements in 40 CFR 60 Subpart IIII in accordance with 40 CFR 63.6590(c)(6). In accordance with 40 CFR 63.6590(b)(1)(i), a new or reconstructed emergency RICE with a rating greater www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 23 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina than 500 brake hp located at a major source of HAPs (i.e., I-RICE-05)does not have to meet the requirements of NSPS Subpart ZZZZ, with the exception of the initial notification requirements. 5.1.4.4 40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major Sources. Industrial, Commercial, and Institutional Boilers and Process Heaters 40 CFR Part 63 Subpart DDDDD applies to the two existing boilers (ID Nos. PS-A and PS-13) and will apply to the new boiler(ID Nos. PS-C) upon installation. This subpart will not apply to the temporary boiler(ID No. PS-TEMP) if installed as long as the boiler does not remain on-site for more than 12 consecutive months. Table 5-2 provides a summary of the requirements of Subpart DDDDD. In 2011, the State of North Carolina implemented a Case-by-Case MACT under the CAA Section 1120), since Subpart DDDDD was not implemented in a timely manner by the US EPA. These conditions were added to the permit in 12 December 2010 (Permit No. 03735T36). The requirements of Subpart DDDDD now replace those conditions and Chemours is requesting the Case-by-Case MACT conditions be removed from the permit. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 24 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina Table 5-2 Summary of MACT Requirements Emission Emission Unit Description MACT Permit Summary of Requirements Unit ID Condition NS-A, HFPO,Vinyl Ethers North, FFFF 2.1 (B)(10) ■ Monitor applicable equipment at frequencies specified per component NS-B, Vinyl Ethers South, Resins type and leak rate and repair leaks as detailed in 40 CFR 63.1024. NS-B-2, a Monitor applicable heat exchange systems quarterly and repair leaks as NS-C, detailed in 40 CFR 63.104. NS-C-2, a Maintain records to demonstrate compliance as detailed in 40 CFR NS-G-1, and 63.2525. NS-G-2 a Submit a semiannual summary report in accordance with 40 CFR 63.2520. PS-A, Boiler A-Natural gas/No.2 DDDDD 2.1 (A)(7) ■ Conduct initial tune-up and subsequent tune-ups every 5 years, in fuel oil-fired boiler(139.4 million Btu per hour maximum accordance with 40 CFR 63.7540(a)(10). PS-B,and heat input)equipped with an a Conduct a one-time energy assessment in accordance with Table 3 of oxygen trim system Subpart DDDDD. PS-C Boiler B-Natural gas/No.2 ■ Maintain records to demonstrate compliance as detailed in 40 CFR fuel oil-fired boiler(88.4 million 63.7555. Btu per hour maximum heat input)equipped with an oxygen a Submit compliance reports every 5 years to DAQ and via CEDRI in trim accordance with 40 CFR 63.7550. System Boiler C Natural gas/No.2 fuel oil-fired boiler(97 million Btu per hour maximum heat input) equipped with a low-NOx burner and an oxygen trim system www.erm.com Version:1.0 Project No.:0544370 Client:7'he Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 25 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company-Fayetteville,North Carolina 5.1.5 Compliance Assurance Monitoring (CAM), 40 CFR Part 64 Under 40 CFR Part 64, Compliance Assurance Monitoring (CAM), facilities are required to prepare and submit monitoring plans for certain emission units with certain Title V permit applications. Specifically CAM applies to any unit that meets all three of the following criteria: * be subject to an emission limitation or standard, * use a control device to achieve compliance, and • have pre-control emissions that exceed or are equivalent to the major source threshold. Uncontrolled particulate matter emissions from the lime slaker(ID No. NS-R2) does not exceed 100 tpy; therefore, a CAM plan is not required for the lime slaker system. Uncontrolled particulate matter emissions from the lime silo (ID No. NS-R1) could exceed 100 tpy, is subject to an emission standard in 15A NCAC 02D .0515, and uses a control device to achieve compliance with the standard. As such, a CAM plan is required for the lime silo. CAM plans compliant with the requirements of 40 CFR Part 64 must accomplish the following: ■ Describe the indicators to be monitored; ■ Describe the ranges or the process to set indicator ranges or conditions; ■ Describe the performance criteria for the monitoring, including - Specifications for obtaining representative data, - Verification procedures to confirm the operational status of the monitoring device, - Quality assurance and control procedures, and - Monitoring frequency and data averaging period; ■ Provide a justification for the use of parameters, ranges, and monitoring approach; and r Provide emissions test data, if necessary The monitoring approach, which addresses each of the aforementioned plan requirements, for the source (i.e., lime silo)and associated control device (i.e., pulse jet baghouse)that is subject to CAM is summarized in Appendix C. 5.1.6 Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r), 40 CFR Part 68 As specified in Permit Conditions 2.2 (13)(3) and Section 3(DD) and (EE), Chemours is subject to Section 112(r)of the Clean Air Act and is in compliance with all applicable requirements in accordance with 40 CFR Part 68. Chemours is subject to 112 (r)for sulfur trioxide and tetrafluoroethylene. Chemours submits updates to the EPA as required via EPA's CDX system. The last submittal was submitted on 24 July 2019. 5.1.7 Protection of Stratospheric Ozone, 40 CFR Part 82 Permit Condition 3(CC) specifies that if Chemours has appliances or refrigeration equipment, including air conditioning equipment,which use Class I or II ozone-depleting substances such as that Chemours must service, repair, and maintain such equipment according to the work practices, personnel certification requirements,and certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F: "Recycling and Emissions Reduction". In addition, Chemours must not www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page 26 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina knowingly vent or otherwise release any Class I or II substance into the environment during the repair,servicing,maintenance, or disposal of any such device except as provided in 40 CFR Part 82 Subpart F. Chemours must also comply with the reporting requirements of 40 CFR 82.166 "Reporting And Recordkeeping Requirements For Leak Repair". Chemours will continue to comply with these requirements. 5.2 State of North Carolina Regulations Potentially applicable standards under 15A North Carolina Administrative Code (NCAC) Chapter 02, Environmental Management are discussed in the following section. Table 5-3 provides a summary of the applicable state requirements for the Chemours facility. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 27 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina Table 5-3 Applicable North Carolina Air Regulations Regulation (15A NCAC) Applicability Comment 02D.0503 Particulates from Fuel Burning Applicable Applicable to PS-A, PS-B, PS-C and PS-TEMP Indirect Heat Exchangers 02D.0515 Particulate Emissions from Applicable Applicable to NS-I, NS-D-2, NS-R1 and NS-R2 Miscellaneous Industrial Processes 02D .0516 Sulfur Dioxide Emissions from Applicable Applicable to PS-A, PS-B, PS-C, PS-TEMP, Combustion Sources NS-I, NS-D-2, NS-R1, NS-R2, and NCD-Q1 02D.0521 Control of Visible Emissions Applicable Applicable to PS-A, PS-B, PS-C, PS-TEMP, and NCD-Q1 02D.0524 New Source Performance Applicable 40 CFR 60 Subparts Dc and IIII apply to certain Standards operations at the Chemours facility. 02D.0530 Prevention of Significant Applicable Chemours is a major source with respect to Deterioration PSD, and has requested several PSD avoidance limitations 02D .0531 Sources in Nonattainment Not Applicable Chemours is located in an attainment area Areas 02D .0540 Particulate from Fugitive Dust Applicable Facility-wide. See permit condition Section Emission Sources 3(MM) Facility-wide. See permit condition Section 02D.0541 Control of Emissions from Applicable Abrasive Blasting 22(B)(4) 02D .0614 Compliance Assurance Applicable Applicable to NS-R2 Monitoring 02D .1100 Control of Air Toxics Applicable Facility-wide. 02D.1110 National Emission Standards for Not Applicable Chemours does not operate any sources Hazardous Air Pollutants subject to 40 CFR 61 02D.1111 Maximum Achievable Control Applicable 40 CFR 63 Subparts FFFF,ZZZZ, and DDDDD Technology apply to certain operations at the Chemours facility. 02D .1800 Control of Odors Applicable Facility-wide. See permit condition Section 2.1 (D)(1)and Section 2.2(13)(5) 02D .2100 Risk Management Program Applicable As specified in Section 5.1.6 of this report. 02D .2600 Source Testing Applicable As specified in permit condition Section 3(JJ) 02Q.0700 Toxic Air Pollutant Procedures Applicable Facility-wide www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 28 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina 5.2.1 15A NCAC 02D .0202— Registration of Air Pollution Sources Permit Condition 3(HH) specifies that the DAQ may require Chemours to register a source of air pollutants. If requested, Chemours will provide the registration for applicable sources. 5.2.2 15A NCAC 02D .0503— Particulates from Fuel Burning Indirect Heat Exchangers This section regulates particulate emissions from indirect-fired fuel combustion sources. Condition 2.1 (A)(1) of the current permit limits particulate emissions from boilers PS-A and PS-B to 0.2667 Ibs/MMBtu. Particulate emissions from PS-C are limited to 0.2268 Ibs/MMBtu. Condition 2.1 (E)(1)details a particulate emissions limit of 0.2426 Ib/MMBtu for PS-Temp. No monitoring, recordkeeping, or reporting are required to demonstrate compliance. 5.2.3 15A NCAC 02D .0515— Particulates from Miscellaneous Industrial Processes This rule established particulate matter emissions based off of process weight rates for miscellaneous industrial processes as follows: ). E=4.10xPa.s7 Where: E =allowable emission rate in pounds per hour P = process weight in tons per hour As detailed in Conditions 2.1 (13)(2) and 2.1 (F)(1), the membrane coating process (ID No. NS-1), the S03 system (ID No. NS-D-2), the lime silo (ID No. NS-RI) and the lime slaker(NS-R2) are subject to 15A NCAC 02D .0515. Chemours is required to maintain production records such that'P' in the above equation can be determined for the membrane coating process(ID No. NS-1) and the S03 system (ID No. NS-D-2). Additional requirements, including monitoring of scrubber flow rate and performing inspections and maintenance on the relevant control devices are required for the lime silo (ID No. NS-R1) and the lime slaker(NS-R2). Chemours is required to submit semiannual reports summarizing the monitoring and recordkeeping requirements. 5.2.4 15A NCAC 02D .0516— Sulfur Dioxide Emissions from Combustion Sources This rule establishes a sulfur dioxide emission limit of 2.3 Ibs/MMBtu from combustion sources. As detailed in Conditions 2.1(A)(2), 2.1 (13)(3), and 2.1 (E)(2) boilers PS-A and PS-B, boiler PS-C (while firing natural gas only), the thermal oxidizer(ID No. NCD-Q1), and the temporary boiler(ID No. PS-Temp)are subject to 15A NCAC 02D .0516. No monitoring, recordkeeping, or reporting are required to demonstrate compliance. 5.2.5 15A NCAC 02D .0521 - Control of Visible Emissions This rule applies to"industrial processes where an emission can reasonably be expected to occur". For sources manufactured as of July 1, 1971, visible emissions shall not be more than 40 percent opacity when averaged over a six-minute period. However, except for sources required to comply with Paragraph (g) of this Rule, six minute averaging periods may exceed 40 percent opacity if: (1) No six-minute period exceeds 90 percent opacity; (2) No more than one six-minute period exceeds 40 percent opacity in any hour; and (3) No more than four six-minute periods exceed 40 percent opacity in any 24-hour period. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 29 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company-Fayetteville,North Carolina For sources manufactured after July 1, 1971, visible emissions shall not be more than 20 percent opacity when averaged over a six-minute period. However, except for sources required to comply with Paragraph (g) of this Rule, six minute averaging periods may exceed 20 percent opacity if: (1) No six-minute period exceeds 87 percent opacity; (2) No more than one six-minute period exceeds 20 percent opacity in any hour; and (3) No more than four six-minute periods exceed 20 percent opacity in any 24-hour period. As detailed in Condition 2.1 (A)(3), visible emissions from boiler PS-A are limited to 40% opacity and boilers PS-B and PS-C are limited to 20% opacity. Boiler PS-Temp also has an opacity limit of 20% as specified in Condition 2.1 (E)(3). Per Condition 2.1 (B)(4), the membrane coating process (ID No. NS-I), the S03 system (ID No. NS-D-2), and the 4-Stage Scrubber exhaust(ID No. NCD-Q2) are subject to an opacity limit of 20%. No monitoring, recordkeeping, or reporting are required to demonstrate compliance for these sources. Condition 2.1 (F)(2) limits visible emissions from the lime silo (ID No. NS-R1) and lime slaker(ID No. NS- R2)to 20% opacity and requires visual inspection of the emission point at least once per week. A summary report of these monitoring activities are required to be submitted in a semiannual compliance report.. 5.2.6 15A NCAC 02D .0524— New Source Performance Standards NSPS requirements and applicability are addressed in the federal regulatory applicability discussion in Section 5.1.2. 5.2.7 15A NCAC 02D .0530— Prevention of Significant Deterioration As discussed in section 5.1.1, the current facility is a major source with respect to the PSD regulations.As such, an increase in emissions associated with any modification at the facility must be assessed against the appropriate SER thresholds. 5.2.7.1 15A NCAC 02D .0530(u) - Use of Projected Actual Emissions to Avoid Applicability of Requirements of PSD 15A NCAC 02D .0530(u) requires the facility to maintain records of annual VOC emissions from the IXM Membrane Coating Process(ID No. NS-I)for 10 years following the startup of the modified process. As detailed in Condition 2.1 (13)(9), an annual report is required within 60 days after the end of the calendar year. If the projected actual emissions of 67.27 tons per year, as stated in the permit application, are exceeded, an explanation as to why the actual rates exceeded the projection must be included in the annual report. 5.2.8 15A NCAC 02D .0541 — Control of Emissions from Abrasive Blasting In accordance with 15A NCAC 02D. 0541 and Condition 2.2 (B)(4), any abrasive blasting operation that is conducted outside a building or conducted indoors and vented to the atmosphere must be performed in accordance with the requirements set forth in 15ANCAC 02D .0521, Control of Visible Emissions.Any visible emissions reading for abrasive blasting performed outside a building shall be taken at a spot approximately one meter above the point of abrasive blasting with a viewing distance of approximately five meters. All abrasive blasting operations at the site is conducted within a building, except as follows: ■ Abrasive blasting of an item that exceeds eight feet in any dimension;or, www.erm.com Version:9.0 Project No.:0544370 Client:The Chemours Company-Fayetteville,North Carolina 2 September 2020 Page 30 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina 2 Abrasive blasting of a surface situated at its permanent location or not further away from its permanent location than is necessary to allow the surface to be blasted. For abrasive blasting operation conducted outside a building, Chemours will use appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being conducted. 5.2.9 15A NCAC 02D .1100- Toxic Air Pollutant Emission Limitation and Requirements and 15A NCAC 02Q .0711 - Toxic Air Pollutant Procedures The Toxic Air Pollutant Procedures require a permit for any facility with emissions of an Air Toxic Pollutant listed in 15A NCAC 02D .1104 in excess of the applicable Toxic Pollutant Emission Rates (TPER) Requiring a Permit presented in 15A NCAC 02Q. 0711. The current permit for the Chemours facility contains facility-wide emission limits for each of the applicable pollutants emitted at the facility in Section 2.2(B)(1) and 2.2(B)(2). These emission limits are based on air toxics modeling conducted in 1995 which developed a 'worst- case' unit impact and backed into facility-wide allowable emission rates. Conditions Section 2.2 (13)(1)(c) and 2.2 (13)(2)(e) requires Chemours to submit quarterly air toxics reports. Since these quarterly reports have consistently shown over the past several years that Chemours does not exceed the air toxic limits in the report and that the installation of the thermal oxidizer and scrubber system will further reduce air toxic emissions, Chemours is requesting to reduce the reporting frequency to submittal on an annual basis. In addition Condition 2.1 (C)(1) requires that PPA(ID No.AS-A) be controlled by a wet scrubber(ID No. ACD-Al)to ensure compliance with this rule. To demonstrate proper performance of the scrubber, the liquid flow rate should be a minimum of 30 gallons per minute and the differential pressure across the packed bed section of the scrubber should be a maximum of 12 inches of water. Chemours is required to maintain records of the inspections on the scrubber. Reporting is not required to demonstrate compliance with Condition 2.1 (C)(1). 5.2.10 15A NCAC 02D .1111 — Maximum Achievable Control Technology MACT requirements and applicability are addressed in the federal regulatory applicability discussion in Section 5.1.4. 5.2.11 15A NCAC 02D .1806— Control and Prohibition of Odorous Emissions In accordance with 15A NCAC 02D. 1806 and Condition 2.2 (13)(5) requires that a facility not operate without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. Permit Condition 2.1 (D)(1)(a)further specifies that the wastewater treatment sludge dryers (ID Nos. WTS-B and WTS-C) shall be controlled by a caustic injection scrubber(ID No. WTCD-1). Chemours is required to perform periodic inspection and maintenance as recommended by the scrubber manufacturer. Condition Section 2.1(D)(1)(d) requires and inspection and maintenance logbook be kept for the scrubber. Reporting is not required to demonstrate compliance with this rule. 5.2.12 15A NCAC 02Q .0317— Avoidance Conditions This rule allows a facility to obtain avoidance conditions from specific permitting requirements. Chemours has taken conditions to avoid PSD requirements for multiple sources and pollutants as detailed in the current permit. Conditions 2.1 (A)(5), 2.1 (13)(5), 2.1 (13)(6), 2.1 (13)(7), 2.1 (13)(8), 2.1 (E)(4), and 2.2 www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September2020 Page 31 TITLE V OPERATING PERMIT RENEWAL APPLICATION AIR REGULATORY APPLICABILITY ANALYSIS The Chemours Company—Fayetteville,North Carolina (A)(1) provides PSD avoidance limits for Boiler PS-B, Vinyl Ethers North (ID No. NS-B), IXM Resins Process (ID Nos. NS-G-1 and NS-G-2), HFPO (ID No. NS-A), HFPO Production Decontamination Process (ID No. NS-N), Boiler PS-Temp, and all boilers combined, respectively. These conditions require monthly emission calculations and fuel use tracking, along with semiannual reporting. www.erm.com Version:1.0 Project No.:0544370 Client:The Chemours Company—Fayetteville,North Carolina 2 September 2020 Page 32 APPENDIX A DAQ APPLICATION FORMS f The business of sustainability E FORM A GENERAL FACILITY INFORMATION REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A NOTE-APPLICATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING: ❑ Local Zoning Consistency Determination (new or modification only) ® Appropriate Number of Copies of Application Application Fee(please check one option below) ❑ Responsible Official/Authorized Contact Signature ❑ P.E.Seal(if required) 0 Not Required❑ ePayment ❑ Check Enclosed GENERAL INFORMATION Legal Corporate/OwnerName: The Chemours Company FC,LLC Site Name: The Chemours Company-Fayetteville Works Site Address(911 Address)Line 1: 22828 NC Highway 87 West Site Address Line 2: City: Fayetteville Slate: North Carolina Zip Code: 28306.7332 County. Bladen CONTACT INFORMATION Responsible Official/Authorized Con fact: Invoice Contact: Namerfitle: Brian D.Long/PlantManager Namerritle: Christel Compton/Program Manager Mailing Address Line 1: 22828 NC High way 87 West Mailing Address Line 1: 22828 NCHighway 87 West Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: North Carolina Zip Code: 28306-7332 City. Fayetteville State: North Carolina Zip Code: 28306-7332 Primary Phone No.: 910-678-1415 Fax No.: 910.678.1247 Primary Phone No.: 910.678.1213 Fax No.: 910.678.1247 Secondary Phone No.: Secondary Phone No.: Email Address: Brfarr.D.Long@chemours.com Email Address: Christel.E.Compton@chemours.com Facflitypnspectfon Contact: Permit/Technical Contact: Namerfitle: ChristelCompton/Program Manager Namerfitle: Christel Compton/Program Manager Mailing Address Line 1: 22828 NC High way 87 West Mailing Address Line 1: 22828 NC Highway 87 West Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: North Carolina Zip Code: 28306.7332 City: Fayetteville State: North Carolina Zip Code: 28306.7332 Primary Phone No.: 910.679,1213 Fax No.: 910.678.1247 Primary Phone No.: 910.678.1213 Fax No.: 910.678.1247 Secondary Phone No.: I Secondary Phone No.: Email Address: Christel.E.Compton@cltemours.com Email Address: ChristeLE.Compton@clremours.com APPLICATION IS BEING MADE FOR ❑ New Nan-permitted Facility/Greenfield ❑ Modification of Facility(permitted) 0 Renewal Title V ❑ Renewal Non-Title V ❑ Name Change ❑ Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification FACILITY CLASSIFICATION AFTER APPLICATION(Check Only One) General Small LJ Prohibitory Small Synthetic Minor W Title V FACILITY(Plant Site)INFORMATION Describe nature of(plant site)operation(s):Manufacturer of chemicals,plastic resins,plastic sheeting and plastic film. Facility ID No. 900009 Primary SICINAICS Cade: 2821,3081,30831326113 Current/Previous Air Permit No. 0373ST48 Expiration Date: 31-Mar-2021 Facility Coordinates: Latitude: 34.843934 Longitude: -78.836834 Does this application contain """If yes,please contact the DAQ Regional Office priorto submitting this application.— confidential data? ❑ YES 0 NO (See Instructions) PERSON OR FIRM THAT PREPARED APPLICATION Person Name: Kevin Eldridge Firm Name: ERMNC,Inc. Mailing Address Line 1:4140ParklakeAvenue Mailing Address Line 2: Suite 110 City: Raleigh State:NC Zip Code: 27612 County. Wake Phone No.: 919.233.4501 Fax No.: Email Address:Kevin.Eldridge@erm.com SIGNATURE OF RESPONSIBLE OFFICIAIJAUTHORIZED CONTACT Name(typed):Brian D. a g Title: Platt Manager X Signature(Blue Ink): Date: /] ach Additional Sheets As Neci Page 1 of 2 Received 4 ", SEP 0 AIN Air Picrmiti4 gpctiOr FORM A (continued, page 2 of 2) GENERAL FACILITY INFORMATION REVISED 09/22/16 NCDEO/Division of Air Quality-Application for Air Permit to Construct/Operate A SECTION AA1-APPLICATION FOR NON-TITLE V PERMIT RENEWAL (Company Name)hereby formally requests renewal of Air Permit No. There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued. Is your facility subject to 40 CFR Part 68'Prevnetion of Accidental Releases"-Section 112(r)of the Clean Air Act? ❑ YES I] NO If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? ❑ YES 0 NO Date Submitted: Did you attach a current emissions inventory? ❑ YES ❑ NO If no,did you submit the inventory via AERO or by mail? ❑ Via AERO ❑ Mailed Date Mailed: SECTION AA2-APPLICATION FOR TITLE V PERMIT RENEWAL In accordance with the provisions of Title 15A 2Q.0513.the responsible official of The Chemours Company FC,LLC (Company Name) hereby formally requests renewal of Air Permit No. 0373ST48 (Air Permit No.)and further certifies that: (1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the North Carolina Title V regulations at 15A NCAC 2Q.0500; (2) The current air quality permit cites all applicable requirements and provides the method or methods for determing compliance with the applicable requirements; (3) The facility is currently in compliance,and shall continue to comply,with all applicable requiremets, (Note: As provided under 15A NCAC 2Q.0512 compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit); (4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis; (5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64. The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief formed after reasonable inquiry,are true,accurate,and complete. SECTION AA3-APPLICATION FOR NAME CHANGE New Facility Name: Former Facility Name: An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if Cher has been an ownership change associated with this name change. SECTION AA4-APPLICATION FOR AN OWNERSHIP CHANGE By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below. The transfer of permit responsibility,coverage and liability shall be effective (immediately or insert date.)The legal ownership of the facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally permitted facility that would require an air quality permit since the last permitwas issued. Si nature of New iBuv+�r�Responsible Official/Authorized Contact fas typed on pwe 1 X Signature(Blue Ink): Date: New Facility Name: Former Facility Name: Signature of Former(Seller'Responsible Official/Authorized Contact: Name(typed or print): Title: X Signature(Blue Ink): Date: Former Legal Corporate/Owner Name: In lieu of the seller's signature on this form,a letter may be submitted with the seller's signature indicating the ownership change SECTION AA5-APPLICATION FOR ADMINISTRATIVE AMENDMENT Describe the requested administrative amendment here(attach additional documents as necessary): Attach Additional Sheets As Necessary Page 2 of 2 FORMS A2, A3 EMISSION SOURCE LISTING FOR THIS APPLICATION -A2 112r APPLICABILITY INFORMATION -A3 REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A2 _ EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted EMISSION SOURCE EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE ID NO. DESCRIPTION ID NO. DESCRIPTION Equipment To Be ADDED By This Application(New, Previously Unpermitted, or Replacement) f i Existing Permitted Equipment To Be MODIFIED By This Application Equipment To Be DELETED By This Application ••• -•• NCD-Hdr1 Baffle-Plate Scrubber NCD-Hdr2 Baffle-Plate Scrubber 112(r)APPLICABILITY INFORMATION A3 Is your facility subject to 40 CFR Part 68"Prevention of Accidental Releases"-Section 112(r)of the Federal Clean Air Act? 0 Yes ❑ No If No,please specify in detail how your facility avoided applicability: If your facility is Subject to 112(r),please complete the following: A. Have you already submitted a Risk Management Plan(RMP)to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150? 0 ❑ If submitted,RMP submittal date: Original 8 june 1999, Yes No Specify required RMP submittal date: 301une 1999 last updated 24 July 2019 B. Are you using administrative controls to subject your facility to a lesser 112(r)program standard? ❑ Yes 0 No If yes,please specify: C. List the processes subject to 112(r)at your facility: PROCESS LEVEL MAXIMUM INTENDED PROCESS DESCRIPTION (1,2,or 3) HAZARDOUS CHEMICAL INVENTORY(LBS) SO,Process 3 sulfur trioxide 59,400 TFE Process 1 tetrafluoroethylene 61,000 Attach Additional Sheets As Necessary FORM D1 FACILITY-WIDE EMISSIONS SUMMARY REVISED 09122/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D 1 CRITERIA AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/ LIMITATIONS) LIMITATIONS) LIMITATIONS) AIR POLLUTANT EMITTED tons/yr tons/yr tons/yr PARTICULATE MATTER(PM) <2 >100 <30 PARTICULATE MATTER<10 MICRONS(PM10) <2 <100 <20 PARTICULATE MATTER<2.5 MICRONS(PM2_5) <2 <100 <15 SULFUR DIOXIDE(S02) <0.50 <2 <2 NITROGEN OXIDES(NOx) <100 >100 >100 CARBON MONOXIDE(CO) ' <50 <100 <100 VOLATILE ORGANIC COMPOUNDS(VOC) >100 >100 >100 LEAD <I <I <1 GREENHOUSE GASES(GHG)(SHORT TONS) <75,000 <200,000 <200,000 OTHER EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS I (BEFORE CONTROLS/ (AFTER CONTROLS/ LIMITATIONS) LIMITATIONS) LIMITATIONS) HAZARDOUS AIR POLLUTANT EMITTED CAS NO. tons/yr tcns/yr tons/yr toluene 108-88.3 <0.2 <0.5 c0.5 ethylbenzene 100-41-4 <0.01 <0.01 <0.01 xylene 1330-020.7 <0.01 <0.01 <0.01 methanol 67-56-1 <20 <20 <20 benzene 71-43-2 <0.01 <0.03 <0.03 methylene chloride 75.09.2 <0.01 <0.01 <0.01 acetenitrile 75.05.8 <0.2 <I <0.3 hdyrogen chloride 7647-01-0 <0.5 <20 <20 hydrogen fluoride 7664.39.3 <0.5 NA° <1 sulfuric acid 7664-93-9 <0.5 <0.5 <1 otherHAPs <1 >25 <2 Total HAPs 1 <20 >25 >25 TOXIC AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE(fPER)IN 15A NCAC 2Q.0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY. Modeling Required? TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day Ib/year Yes No Toxic air pollutant emissions will not increase above permitted limits with this project COMMENTS: The thermal oxidizer will create hydrogen fluoride by the chemical conversion of the fluoronated hydrocarbons being controlled by the thermal oxidizer.The hydrogen fluoride produced in the thermal oxidzer will then be controlled by the scrubber. Attach Additional Sheets As Necessary FORM D4 EXEMPT AND INSIGNIFICANT ACTIVITIES SUMMARY REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D4 ACTIVITIES EXEMPTED PER 2Q .0102 OR INSIGNIFICANT ACTIVITIES PER 2Q .0503 FOR TITLE V SOURCES SIZE OR PRODUCTION BASIS FOR EXEMPTION OR INSIGNIFICANT DESCRIPTION OF EMISSION SOURCE _RATE _ _ ACTIVITY 1. Diesel-Fired Emergency Generator for Remediation 540 hp 15A NCAC 02Q.0503(8) Treatment System(I-RICE-05) 2. 3. 4. 5. 6. 7 8. 9. 10. Attach Additional Sheets As Necessary FORM E1 TITLE V GENERAL INFORMATION REVISED 06/01/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E1 IF YOUR FACILITY IS CLASSIFIED AS"MAJOR"FOR TITLE V YOU MUST COMPLETE THIS FORM AND ALL OTHER REQUIRED"E"FORMS(E2 THROUGH E5 AS APPLICABLE) Indicate here if your facility is subject to Title V by: 0 EMISSIONS ❑ OTHER If subject to Title V by"OTHER",specify why: ❑ NSPS 0 NESHAP(MACT) ❑ TITLE IV ❑ OTHER(specify) If you are or will be subject to any maximum achievable control technology standards(MACT)issued pursuant to section 112(d)of the Clean Air Act,specify below: EMISSION SOURCE EMISSION SOURCE ID DESCRIPTION MACT I-RICE-01,I-RICE-02,1-RICE-03,1- Diesel-Fired Engines for Fire Water Pumps and RICE-04,and I-RICE-05 Emergency Generators ZZZZ PS-A,PS-B,and PS-C Natural Gas/No.2 Fuel Oil-Fired Boilers DDDDD NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS- HFPO,Vinyl Ethers North,Vinyl Ethers South,and G-1,and NS-G-2 IXM Resins FFFF List any additional regulation which are requested to be included in the shield and provide a detailed explanation as to why the shield should be granted: REGULATION EMISSION SOURCE(include ID) EXPLANATION 40 CFR Part 63,Subpart D Temporary Baiter(PS-TEMP) The National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and Process Heaters(40 CFR Part 63,Subpart DDDDD)and 15A NCAC 02D.1111 are not applicable to the naturalgas/No.2 fuel oil- fired temporary boiler(10 No.PS-Temp)because the boiler is a temporary boiler,as defined in§63.7575 Comments: Attach Additional Sheets As Necessary FORM E2 EMISSION SOURCE APPLICABLE REGULATION LISTING REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E2 EMISSION EMISSION OPERATING SCENARIO SOURCE SOURCE INDICATE PRIMARY(P) APPLICABLE ID NO. DESCRIPTION OR ALTERNATIVE(A) POLLUTANT REGULATION ES 9 CoalJWood Boiler P-Coal PM NCAC 2D.0503 A-Wood PM NCAC 2D.0504 See accompanying Title V renewal application report Attach Additional Sheets As Necessary FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 09/22/16 NCDEQ/Division Of Air Quality-Application for Air Permit to Construct/Operate E3 Regulated Pollutant Emission Source ID NO. Applicable Regulation Alternative Operating Scenario(ADS)NO: Refer to the Title V renewal application report. ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS MONITORING REQUIREMENTS Is Compliance Assurance Monitoring(CAM)40 CFR Part 64 Applicable? ❑YES ❑ NO If yes,is CAM Plan Attached(if applicable,CAM plan must be attached)? ❑ YES ❑ NO Describe Monitoring Device Type: Describe Monitoring Location: Other Monitoring Methods(Describe In Detail): Describe the frequency and duration of monitoring and how the data will be recorded(i.e.,every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): RECORDKEEPING REQUIREMENTS Data(Parameter)being recording: Frequency of recordkeeping(How often is data recorded?): REPORTING REQUIREMENTS Generally describe what is being reported: Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER(DESCRIBE): TESTING Specify proposed reference test method: Specify reference test method rule and citation: Specify testing frequency: NOTE-Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary FORM E4 EMISSION SOURCE COMPLIANCE SCHEDULE REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E4 COMPLIANCE STATUS WITH RESPECT TO ALL APPLICABLE REQUIREMENTS Will each emission source at your facility be in compliance with all applicable requirements at the time of permit issuance and continue to comply with these requirements? ❑� YES ❑ NO If NO,complete A through F below for each requirement for which compliance is not achieved. Will your facility be in compliance with all applicable requirements taking effect during the term of the permit and meet such requirements on a timely basis? 0 YES ❑ NO If NO,complete A through F below for each requirement for which compliance is not achieved. If this application is for a modification of existing emissions source(s),is each emission source currently in compliance with all applicable requirements? ❑ YES ❑ NO If NO,complete A through F below for each requirement for which compliance is not achieved. A. Emission Source Description(Include ID NO.) B. Identify applicable requirement for which compliance is not achieved: C. Narrative description of how compliance will be achieved with this applicable requirements: D. Detailed Schedule of Compliance: Ste s Date Ex.iected E. Frequency for submittal of progress reports(6 month minimum): F. Starting date of submittal of progress reports: Attach Additional Sheets As Necessary FORM E5 TITLE V COMPLIANCE CERTIFICATION (Required) REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E5 In accordance with the provisions of Title 15A NCAC 2Q.0520 and.0515(b)(4)the responsible company official of.- SITE NAME: The Chemours Company-Fayetteville Works SITE ADDRESS: 22828 NC Highway 87 West CITY,NC: Fayetteville,NC COUNTY: Bladen PERMIT NUMBER: 03735T48 CERTIFIES THAT(Check the appropriate statement(s): 0 The facility is in compliance with all applicable requirements In accordance with the provisions of Title 15A NCAC 2Q.0515(b)(4)the responsible company official certifies that the proposed minor modification meets the criteria for using the procedures set out in 2Q.0515 and requests that these procedures be used to process the permit application. ❑ The facility is not currently in compliance with all applicable requirements If this box is checked,you must also complete Form E4"Emission Source Compliance Schedule" The undersigned certifies under the penalty of law,that all information and statements provided in the application, based on information and belief formed after reas able inquiry,are true,accurate,and complete. Signature of resp sibl omp official(REQUIRED,USE BLUE INK) Brian D.Long,Plant Manager Name,Title of responsible company official(Type or print) Attach Additional Sheets As Necessary Received SEA' Q 8 Ail pe rnl4 SiaCf1Cr FORM E6 COMPLIANCE ASSURANCE MONITORING (CAM) PLAN (4 pages) REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E6-1 For CAM-affected emission units,the applicant must submit additional information in the form of a CAM Plan as required under 40 CFR 64. For information about the CAM rule and this form,please refer to 40 CFR 64 and 15A NCAC 2D.0614. Additional information(including guidance documents may be found at the following URLs: https://w,&w3.en,a.gomfftn/emc/cam.html h s://d .nc. ov/about/divisions/air- ualit /air- uali -enforcement/com liance-assurance-monitorin SOURCE INFORMATION 1. Facility Name: Chemours Comp as -Fa etteville Works 2. Permit Number: 03735T48 3. Date Form Prepared: 812612020 BASIS OF CAM SUBMITTAL 4. Mark the appropriate box below as to why this CAM Plan is being submitted as part of this application: 0 Renewal Application: ALL Emission Units(Pollutant Specific Emission Units[PSEUs]considered separately with respect to EACH regulated air pollutant)for which a CAM Plan has NOT yet been approved needs to be addressed in this CAM Plan submittal. See Renewal Procedures per 15 A NCAC 2Q.0513. ❑ Initial Application(Submitted after 4/20/1998): Only large PSEUs(PSEUs with potential post control device emissions of an applicable regulated air pollutant that are equal to or greater than major source threshold levels)need to be addressed in this CAM Plan submittal. See Initial Application Procedures per 15A NCAC 2Q.0505(1). ❑ Significant Modification to Large PSEUs: Only large PSEUs(PSEUs with potential post control device emissions of an applicable regulated air pollutant that are equal to or greater than major source threshold levels)being modified after 4/2 011 9 9 8 need to be addressed in this CAM Plan submittal. For large PSEUs with an approved CAM Plan,only address the appropriate monitoring requirements affected by the significant modification. See Significant Modification Procedures per 15 A NCAC 2Q.0516. CAM APPLICABILITY DETERMINATION 5. To determine CAM applicability,a PSEU must meet ALL of the following criteria(If not,then the remainder of this form need not be completed): A. The PSEU is located at a major source; B. The PSEU is subject to an emission limitation or standard for the applicable regulated air pollutant that is NOT exempt; List of EXEMPT Emission Limitations or Standards below OR as provided in 15A NCAC 2b7.0614(b)l1): • NSPS(40 CFR Part 60)or NESHAP(40 CFR Part 61 and 63)proposed after 1 111 5/1 990. • Stratospheric ozone protection requirements. • Acid Rain program requirements. • Emission limitations or standards for which a Title V permit specifies a continuous compliance determination method,as defined in the CAM rule(40 CFR 64.1),Continuous Compliance Determination Method. • An emission cap that meets the requirements specified in 40 CFR 70.4(b)(12). If the PSEU is subject to both Exempt and Not Exempt emission standards for the same pollutant,then the facility is required to determine the CAM applicability for Not Exempt emission standards. C. The PSEU uses an add-on control device to achieve compliance with an emission limitation or standard; D. The PSEU has potential pre-control device emissions of the applicable regulated air pollutant that are equal to or greater than major source threshold levels;and E. The PSEU is NOT an exempt backup utility power emission unit that is municpally owned and appropriately documentd as provided in 15A NCAC 2D.0614(b)(2). Attach Additional Sheets As Necessary Page 1 of 4 BACKGROUND DATA AND INFORMATION E6-2 6. Complete the following table for ALL PSEUs that need to be addressed in this CAM Plan submittal. This section is to be used to provide background data and information for each PSEU in order to supplement the submittal requirements specified in 40 CFR 64.4. If additional space is needed,please attach and label Eadditional sheets as appropriate. 'Emission PSEU PSEU Control Limitation OR bMonitoring Designation Description Pollutant Device Standard Requirement 15NC4CO2D Peiform monthly visual NS-R1 LimeSilo Particulate Matter PulsefetBaghouse .0515 fnspectionof the system and (NCD-Rl) 0.67 annual internal inspection of E=4.IOxP haghouse structural integrity a Indicate the emission limitation or standard for any applicable requirement that constitutes an emission limitation,emission standard,or standard of performance. Examples of emission limitations or standards may include a permitted emission limitation,applicable regulations,work practices,process o- control device parameters,or other forms of specific design,equipment,operational or maintenance requirements. b Indicate the monitoring requirements for the control device that are required by an applicable regulation or permit condition. Attach Additional Sheets As Necessary Page 2 of 4 CAM MONITORING APPROACH CRITERIA I E6-3 7. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may be copied as needed for each PSEU. This section is to be used to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional space is need,attach and label with the appropriate PSEU designation,pollutant,and indicator Nos. PSEU DESIGNATION POLLUTANT 'INDICATOR NO. 1 b INDICATOR NO.2 Visible Emissions Inspection and Maintenance NS-R1 Program Visible emissions from the baghouse will be monitored to evaluate for the Monthly visual inspection of the presence of visible emissions. If system ductwork and material visible emissions are present collection unit for leaks and 7a. General Criteria Chemouurs will determine visible annual internal inspection of Describe the monitoring approach used to emissions by conducting a Method 9 baghouse'sstructural integrity measure the indicators. opacity reading for 12 minutes. Any visible emissions will trigger a An excursion is identified as °Establish the appropriate indicator ran-le or f 12 minute Method 9 evaluation. failure to conduct the monthly the procedures for establishing the indicator Opacity readings greater than 20% or,annual inspections. range which provides a reasonable opacity will be an excursion. assurance of compliance Excisions below the indicator range d Provide Quality Improvement Plan(QIPI for-no more than 3 days during the Not Applicable semi-amoral report period. Threshold levels. 7b. Performance criteria Particulate Matter Measurements will be taken at the Baglronrses and associated Provide the Specification for Obtaining emission release point(exhaust of ductwork will be inspected Representative Data(Such as detector the baghouse). visually forsigns of deterioration. location and installation specifications). Provide Quality Assurance and Quality Control QA/QCI Practices that are adequate The certified observer will perform Maintenance,or other qualified to ensure the continuing validity of the data, any Method 9 evaluations,if personnel,will perform inspection and baghouse considering manufacturer's requiredmairntenance. recommendations The visible emission observation will Monthly visual irnspection and be conducted once per-day when silo annual internal inspection. The Provide the Monitoring Freguengy loading is occurring. The results will results will be maintained in a Provide the Data Collection Procedures that be maintained in a logbook. logbook will be used Provide the Data Averaging Period for the purpose of determining whether an Not applicable Not Applicable excursion or exceedance has occurred. e If a Continuous Emission Monitoring System(GEMS),Continuous Opacity Monitoring System(COMS),or Predictive Emission Monitoring System(PEMS)is used,then this section need not be completed ONLY for the CEMS,COMS,or PEMS,EXCEPT that the Special Criteria Information of 40 CFR 64.3(d)must be provided. Special Criteria Information may be provided on a separate sheet. b Describe all indicators to be monitored which satisfy 40 CFR 64.3(a). Indicators of emission control performance for the control device and associated capture system may include measured or predicted emissions(including visible emissions or opacity),process and control device operating parameters that affect control device(and capture system)efficiency or emission rates,or recorded findings of inspection and maintenance activities. Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly different operating conditions, expressed as a function of process variables,expressed as maintaining the applicable indicator in a particular operational status or designated condition,or established as interdependent between more than one indicator. In addition,unless specifically stated otherwise by an applicable requirement,the owner or operator shall monitor the indicators to detect any bypass of the control device(or capture system)to the atmosphere. d The QIP threshold is based on the number of excursions identified in a reporting period. (Example: if the historical monitoring data for a facility indicates that the indicator range was exceeded 10 times in a 6-month period,the threshold could be established at no more than 10 excursions outside the indicator range during a 6-month reporting period.) The threshold levels also could be established based on the duration of excursions as a percentage of operating time. e At a minimum,the owner of a large PSEU must collect four or more data values equally spaced over each hour and average the values. All other PSEUs must collect data at least once per 24-hour period or possibly more to provide reasonable assurance of compliance over the anticipated range of operating conditions. Attach Additional Sheets As Necessary Page 3 of 4 RATIONALE AND JUSTIFICATION I E6-4 8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may be copied as needed. Use this section to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional space is needed,attach additional sheets and label with the appropriate PSEU designation,pollutant,and indicator Nos. PSEU DESIGNATION POLLUTANT NS-R1 Particulate Matter 9. INDICATORS AND THE MONITORING APPROACH: Provide the rationale and justification for the selection of the indicators and the monitoring approach used to measure the indicators. Also provide any data supporting the rationale and justification. Explain the reasons for any differences between the verification of operational status or the quality assurance and control practices proposed and the manufacturer's recommendations. (If additional space is needed,attach and label with the appropriate PSEU designation and pollutant). Visible emissions were selected as the performance indicator because it is indicative ofoperation of the baghouse in a manner necessary to comply with the particulate emission standard. When the baghouse is operating properly,there will not be any visible emissions from the exhaust. Any increase in visible emissions indicates reduced performance of a particulate control device;therefore,the presence of visible emissions is used as the performance indicator. An inspection and maintenance program was chosen as a performance indicator due to the high reliability of properly maintained baghouses at controlling particulate emissions.A key element of the program is bag filter reliability,which is why an amoral internal inspection of baghouse was selected as a performance indicator. 10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges. The rationale and justification shall indicate how EACH indicator range was selected by either a Compliance or Performance Test,a Test Plan and Schedule,or by Engineering Assessments. Depending on which method is being used for each indicator range,include the specific information required below for that specific indicator range. (If additional space is needed, attach and label with the appropriate PSEU designation and pollutant): • COMPLIANCE or PERFORMANCE TEST(Indicator ranges determined from control device operating parameter data obtained during a compliance or performance test conducted under regulatory specified conditions or under conditions representative of maximum potential emissions under anticipated operating conditions. Such data may be supplemented by engineering assessments and manufacturer's recommendations). The rationale and justification shall include a summary of the compliance or performance test results that were used to determine the indicator range and documentation indicating that no changes have taken place that could result in a significant change in the control system performance or the selected indicator ranges since the compliance or performant test was conducted and approved by DAQ. • TEST PLAN AND SCHEDULE(Indicator ranges will be determined from a proposed implementation plan and schedule for installing,testing,and performing any other appropriate activities prior to use of the monitoring). The rationale and justification shall include the proposed implementation plan and schedule that will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan,but in no case shall the schedule for completing installation and beginning operation of the monitoring exceed 180 days after approval. • ENGINEERING ASSESSMENTS(Indicator ranges or the procedures for establishing indicator ranges are determined from engineering assessments and other data,such as manufacturer's design criteria and historical monitoring data,because factors specific to the type of monitoring,control device,or PSEU make compliance or performance testing unnecessary). The rationale and justification shall include documentation demonstrating that compliance testing is not required to establish the indicator range. RATIONALE AND JUSTIFICATION: The selected indicator range is visible emissions in excess of 20%opacity,which was selected because an increase in visible emissions is indicative ofan increase in particulate emissions. The initial step to evaluating visible emissions will be conducting a visible/no visible emissions observation because it does not require a Method 9 certified observer. . Due to the high reliability of baghouses in this type of application,an indicator range of monthly visual and annual internal inspections is considered adequate enough to identify potential degradations in bag filter pen fo•mance before failure.As a result of these inspections,corrective actions will be initiated and repairs made as required. Attach Additional Sheets As Necessary Page 4 of 4 APPENDIX B REDLINED PERMIT The business of sustainability ERR ROY COOPER " Cw M" Vt MICHAEL S.PECAN ri $KY?laYy MICHAEL ABRACZINSKAS DPreeevr NORTH CAROLING itnvimrimental Quality May 13,2020 Mr.Brian D.Long Plant Manager Chemours Company-Fayetteville Works 22828 NC Highway 87 West Fayetteville,North Carolina 28306 SUBJECT: Air Quality Permit No.03735T48 Facility ID:0900009 Chemours Company-Fayetteville Works Fayetteville Bladen County Fee Class:Title V Dear Mr.Long: In accordance with your completed Air Quality Permit Applications for a State-only modification of your Title V permit under 15A NCAC 02Q.05 t 5(h)received February 13,2020,and a minor modification of your Title V permit under 15A NCAC 02Q.0515 received April 21,2020,we are forwarding herewith Air Quality Permit No. 03735T48 to Chemours Company—Fayetteville Works, located at 22828 NC Highway 87 West,Fayetteville,Bladen County,North Carolina authorizing the construction and operation of the emission source(s) and associated air pollution control device(s) specified herein. Additionally,any emissions activities determined from your Air Quality Permit Application as being insignificant per 15A North Carolina Administrative Code 02Q.0503 have been listed for informational purposes.Please note the requirements for the annual compliance certification are contained in General Condition P in Section 3.The current owner is responsible for submitting a compliance certification for the entire year regardless of who owned the facility during theyear. The monitoring requirements for the Lime Slaker(ID No.NS-R2)and wet particulate scrubber(ID No.NCD-R2)is part of a minor modification per ISA NCAC 02Q.0515.The compliance certification as described in General Condition P is required.Unless otherwise notified by NC DAQ,the affected terms of this permit(excluding the permit shield as described General Condition R)for this source shall become final on July 12,2020.Until this date,the affected permit terms herein reflect the proposed operating language that the Permittee shall operate this source under pursuant to 15A NCAC 02Q.0515(f). As the designated responsible ofl iicial,it is your responsibility to review,understand,and abide by all ofthe terms and conditions of the attached permit.It is also your responsibility to ensure that any person who operates any emission source and associated air pollution control device subject to any term or condition of the attached permit reviews, understands,and abides by the condition(s)of the attached permit that are applicable to that particular emission source. If any parts,requirements,or limitations contained in this Air Quality Permit are unacceptable to you,you have the right to request a formal adjudicatory hearing within 30 days following receipt of this D North Caol"Depanntenr or Environncnial Quality I Division or Air Quality 217 West Iones Street 11641 Mail Service Cm—I Raleigh North Carolew 27699.1641 919.7DT.B400 Mr.Brian D.Long May 13,2020 Page 2 pernvt,identifying the specific issues to be contested.This hearing request must be in the form of a written petition,conforming to NCGS(North Carolina General Statutes)150B-23,and filed with both the Office of Administrative Hearings,6714 Mail Service Center,Raleigh,North Carolina 27699-6714 and the Division of Air Quality,Permitting Section,1641 Mail Service Center,Raleigh,North Carolina 27699-1641.The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing. Unless a request for a hearing is made pursuant to NCGS 150B-23,this Air Quality Permit shall be final and binding 30 days after issuance.You may request modification of your Air Quality Permit through informal means pursuant to NCGS 150B-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 this Air Quality Permit will become final and binding regardless of a request for informal modification unless a request for a hearing is alsomade under NCGS 150B-23. The construction of new air pollution emission source(s)and associated air pollution control device(s), or modifications to the emission source(s)and air pollution control device(s)described in this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to construction unless the Permittee has fulfilled the requirements of NCGS 143-215.108A(b)and received written approval from the Director of the Division of Air Quality to commence construction.Failure to receive an Air Quality Permit or written approval prior to commencing construction is a violation of NCGS 143-215.108A and may subject the Pemvttee to civil or criminal penalties as described in NCGS 143-215.114A and 143-215.114B. Bladen County has triggered increment tracking under PSD for PMio and S02. This permit modification will not result in an increase of PM10 or SO2. This Air Quality Permit shall be effective from May 13, 2020 until March 31, 2021, is nontransferable to future owners and operators,and shall be subject to the conditions and limitations as specified therein.Should you have any questions concerning this matter,please contact Heather Sands at (919)707-8725 or heather.sands@ncdenr.gov. Sincerely yours, I , b,�',AL� William D.Willets,RE,Chief,Permitting Section Division of Air Quality,NCDEQ Enclosure cc: Kelly Fortin,EPA Region 4 Fayetteville Regional Office Connie Home(cover letter only) Central Files Mr.Brian D.Long May 13,2020 Page 3 ATTACHMENT to Permit No.03 m-TT'°03735T49 Insignificant Activities per 15A NCAC 02Q.0503(8) Source ID No. Emission Source Description I-02 Waste DMSO Storage Tank I-03 Fugitive Emissions of Methylene Chloride I-04 Chlorination of Riverwater to control mussel growth in equipment I-05-1 Sitewide Laboratory Emissions(not including VE Research Laboratory Hood and VE Research Laboratory Chemical Storage Cabinet) 1-05-2 VE Research Laboratory Hood and VE Research Laboratory Chemical Storage Cabinet routed to a Carbon Adsorber(ID No.SCD-SW 1) I-06 Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension I-07 Paint shop I-08 Self-contained abrasive blasting cabinets I-09 Paint spray booths I-10 Abrasive blasting and painting building I-12 IXM Dispersion Process I-CT Cooling Tower(6,000 gallons per minute,expandable to 8,000 gallons per minute) I-RICE-01 Diesel Engine for Stack Blower Emergency Electrical Generator MACT ZZZZ I-ACTT ZZZZ C Diesel Engine for Emergency Fire Water Pump ZZ ZZ I-RICE-03 NSPS IIII Diesel Engine for HFPO Barricade Emergency Electrical Generator MACT ZZZZ I-RICE-04 -- Formatted Table NSPS IIII Diesel-Fired Emergency Generator for Thermal Oxidizer System(320 hp) MACT ZZZZ 1-RICE-05 Diesel-Fired Emergency Generatorlxxx hp3 _-- Formatted:Highlight MACT ZZZZ 1. Because an activity is insignificant 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 02D.1100,"Control of ToxicAir Pollutants",or 15A NCAC 02Q.0711,"Emission Rates Requiring a Permit". 3. For additional information regarding the applicability of MACT or GACT see the DAQ page titled"Specific Permit Conditions Regulatory Guide."The link to this site is as follows:htmn Hdea.nc.%ov/about/divisions/air- uuality/air-carality-nermi is/soecifi c-nermi t-conditions-rmtlatory-guide. Mr.Brian D.Long May 13,2020 Page 4 Summary of Changes to Permit The following changes were made to the Chemours Company—Fayetteville Works,Air Pemut No.03735T47. Old Page New Page Condition No. Description of Change(s) No. No. GOVOF'eftff PSIr-FI-R@1 Amended flppliea�an type.Peffflit revision Rufflbefs afid dates. .,.,h. ont ARaehme..t r....:gnifio Split 111c.cr,....,:.t..i mil...._... zxanenmvvs �re'!'>F1.``�i�B2-r�+ .,.� +ma..+�c-.e adSObef(ID NO.SC2,P C-�x�did tittlesee Ellat FCwlais cic�}ltrcrtrll �il AL.. I Q9 t 9 J=abefatei,,-Emissions(net moluding VIE-RaseaFeli T=abeiatop,,Peed and VE nr.ear l:� I a=3 Chem Gal Stafage Cab' ,al=d 1B Ne.1 05-2 Ur-.' _,.1,LA—me., ead....d VE Reseafeli I abef.taFyi Gh,,.,-.ieal ctafage a---m..-o czm.r+crcocrccc-cvho.+--.a oca- 4 a ss 71 1411 Updated perm_ rev.ieni....,bete:n header 1 3-4 3- 9!'fHen It o a m No.cnr cwl RS EBR401 a .,: a. Added emission.,attFee-.o:—V€nth lndee€-Fabitivas F1B No.V6 G 2) and asseeiated ....h,...,, a. I,n.l, ..,a adz..:,.,.. F1`c_mac c....a,1.1,1,,,.E c....:ti VeSa,^td-- .,the-end:t:,..,,f,4 all nC 1 C.,.,d peil2k.e,..,,.,aund.. nt,dR*d n.,..d:a,..,B.10 t„,.,..ao..t« ,,JhRt R-11 40d vc N eAl,.,.,d vc o«--�JFo�.aroa.�av�.- � Satith Indoor c weFe hiitially:.papal..-...,d.,t th„4foad.,t yr N 8411...,d yr c,,..h e...:....:.... sewees r1t-1 N es Ns and Ns C2i Milliffitlill Of 72 I.E)..... 40 43 nn rn 11 c.,.tiAn I t ...d.,..mn nc1 -54 41 49 43 48 Section—2—n .i the table in eeHditien B2, ted ,,th vc nr,,..t.I..dpsf Fugitives Ire Ne ate.,NS B 1 to NS n I 51 544 =50 53 Seet;on 2.2 1)1) D,.,:sed Good:«t.,.,rN 1 to include_e,..:telrei.tS for the carbon ad.eAeFs «,..,,,,mot euff--t QE -;;�A State ofNorth Carolina Q Department of Environmental Quality Dep�rfinental Fa�Wramnmtsl Ou- % e Division of Air Quality AIR QUALITY PERMIT Permit No. Replaces Permit No.(s) Effective Date Expiration Date 0373ST180 0 5T4T^703735T48 July 12,2020 March 31,k021� _-- Commented[KEl]:Update dates 3735T49 'he effective date listed above applies only to changes made as a result of this modification.All other terms and conditions of this permit are applicable as of the issuance date. Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct and operate the emission source(s)and associated air pollution control device(s)specified herein,in accordance with the terms,conditions, and limitations within this permit.This permit is issued under the provisions of Article 21 B of Chapter 143,General Statutes of North Carolina as amended,and Title 15A North Carolina Administrative Codes(15A NCAC),Subchapters 02D and 02Q,and other applicable Laws. Pursuant to Title 15A NCAC,Subchapter 02Q,the Permittee shall not construct,operate,or modify any emission source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application to the permitting authority and received an Air Quality Permit,except as provided in this permit. Permittee: Chemours Company-Fayetteville Works Facility ID: 0900009 Facility Site Location: 22828 NC Highway 87 West City,County,State,Zip: Fayetteville,Bladen County,NC,28306 Mailing Address: 22828 NC Highway 87 West City,State,Zip: Fayetteville,NC,28306 Application Number: 0900009.20A and.20C Complete Application Date: February 14,2020,and April 21,2020 Primary SIC Code: 2821,3081,3083 Division of Air Quality, Fayetteville Regional Office Regional Office Address: 225 Green Street,Suite 714 Fayetteville,NC 28301 Permit issued this the 13"day of May,2020 William D.Willets,P.E.,Chief,Air Permits Section By Authority of the Environmental Management Commission Table of Contents SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS 2.1 Emission Source(s)Specific Limitations and Conditions(Including specific requirements, testing,monitoring,recordkeeping,and reporting requirements 2.2 Multiple Emission Source(s)Specific Limitations and Conditions(Including specific requirements,testing,monitoring,recordkeeping,and reporting requirements) 2.3 Permit Shield for Nonapplicable Requirements SECTION 3: GENERAL PERMIT CONDITIONS ATTACHMENT List of Acronyms Permit No./1Y]2�PT49 03735T49 Page 3 SECTION 1-PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances. Page Emission Source Emission Source Description Control Nos. ID No. Device ID No. Control Device Description 5 to 15, PI-A Natural gas/No.2 fuel oil-fired boiler N/A N/A 37,42 lease (139.4 million Btu per hour maximum heat MACT input)equipped with an oxygen trim MACT DDDDD system PS-B Natural gas/No.2 fuel oil-fired boiler N/A N/A Gm (88.4 million Btu per hour maximum heat N'tkGF input)equipped with an oxygen trim MACT DDDDD system PS-C Natural gas/No.2 fuel oil-fired boiler(97 NIA N/A NSPS Dc million Btu per hour maximum heat input) ^^ ;2 equipped with a low-NOx burner and an .. �T oxygen trim system MACT DDDDD 5,37 to PS-Temp Natural gas/No.2 fuel oil-fired temporary N/A N/A 39,42, boiler(less than 100.0 million Btu per 54 hour maximum heat input) 16 to 34, NS-A Hexafluoropropylene oxide(HFPO) P89 P9S 46 to 47, MACT FFFF process Nrr,�_O r,i,dr! Baffle plate-,,....b bef:(7,000 50 to 53 NS-B Vinyl Ethers North process kilems am,'h -liquid in e Gti8fl Fate MALT FFFF averaged over^z 1.0.-period) NS-C Vinyl Ethers South process MACT FFFF -era Baffle la4e Sell bbe_(7,909 ki!8 n.,... NS-D-1 RSU Process(except S03 System) � '' FRi _u,...:d:.;ee fish Fate NS-E FPS Liquid waste stabilization NS-F MMF processc Thermal Oxidizer(10 million Btu AA9& per hour,natural gas-fired) NCD-QI 4-Stage Scrubber:Countercurrent -and- Packed Bed Stages 1,2,and 3; NCD-Q2 Caustic Stage 4 with minimum scrubber liquor flow of 40 gallons per minute and minimum pH of 7.1 16 to 34 NS-G-2 D34 Resins Process Fluorinator NCD-G2 Caustic scrubber MACT FFFF 16 to 34 NS-13-2 RSU Process S03 System: NCD-D Wet scrubber with mist eliminator S03 Storage Tank,Vaporizer,S03 Truck (minimum liquid injection rate of Unloading,Reservoir Tank 0.5 gallons per minute) 16 to 18 NS-H I 04 membrane process N/A N/A NS-I IXM membrane coating NIA N/A 16 to 18, SW-1 Semiworks polymerization operation SCD-SWl Carbon Adsorber 50 to 53 SW-2 Semiworks laboratory hood Permit No.03�T'i Q-r 8 03735T49 Page 4 Page Emission Source Emission Source Description Control Control Device Description Nos. ID No. Device ID No. 16 to 34, NS-G-1 IXM Resins Process(except Fluorinator) P99 P9S 46 to 47, MACT FFFF -NI ++N;A 50 to 53 NS-K E-2 Process AE& AOS NS-M TFE/CQ separation process NCD-Ql Thermal Oxidizer(10 million Btu AWn,:.. a r,r.....r.a. .,,:.. -and- per hour,natural gas-fired) - ,..,,.�we r.,.a%...,„,. ,,eFi,.r,..., ra Dn i NCD-Q2 4-Stage Scrubber:Countercurrent u, r�,P,t, Packed Bed Stages 1,2,and 3; n....... ... .. ...s'.,.,,,, ,. ....•....................•:.•,.r..... • '"'"" Caustic Stage 4 with minimum scrubber liquor flow of 40 gallons NS-N HFPO product container decontamination per minute and minimum pH of process 7.1 ,.r,A,o v A..,,..,..,d....,....r, n..,.ri-iowye frc-Fvr NS-O Vinyl Ethers North product container decontamination process ,n,n rr. .1 r.,.......,,nro n r......,.,...,,r_........,. n............:...:....r,.....r.,,so?...,.....,......,, ....,..,.,, d.............r.,,..i NS-P Vinyl Ethers South product container decontamination process m,nA.. .i,,,.,,..,.,,n,c n;.,.,.,..,,.r,..,,„d, u., r .,.,144)u,,n d,. „ oeitl ,...&,..an's r,.. .r.'....................: ...............:...e,..,..,....>beo. 16 to 34, NS-B-2 Vinvl Ethers-North Indoor Fugitives NCD-Q3 Carbon Adsorber 46 to 47, MACT-FFFF 51 to 54 NS-C-2 Vinyl Ethers€--South Indoor Fugitives NCD-Q4 Carbon Adsorber MACT-FFFF 35, AS-A Polymer Processing Aid Process ACD-Al Wet scrubber(30 gallons per 46 to 47, minute water injection rate 50 to 53 averaged over a 3-hour period) State-enforceable only -and- ACD-A2 Carbon Adsorber 36 WTS-A Extended aeration biological wastewater N/A N/A treatment facility WTS-B, Two(2)Indirect steam-heated rotary WTCD-I Wet scrubber with mist eliminator WTS-C sludge dryers State-en orceable only 40 to 41, NS-RI Lime Silo NCD-Rl Pulse Jet Baghouse(300 square 49 feet of filter area) NS-R2" Lime Slakert NCD-R2 Wet Particulate Scmbber (minimum liquid injection rate of _ 0.84 gallons per minute) > > a - Permit No.03 5-1T''8 03735T49 Page SECTION 2-SPECIFIC LIMITATIONS AND CONDITIONS 2.1-Emission Source(s)and Control Devices(s)Specific Limitations and Conditions The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to the following specific terms,conditions,and limitations,including the testing,monitoring,recordkeeping,and reporting requirements as specified herein: A. Three natural gas/No.2 fuel oil-fired boilers(ID Nos.PS-A,PS-B,and PS-C) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate Matter Affected Sources:PS-A and PS-B 15A NCAC 02D.0503 0.2667 pounds particulate per million Btu heat input Affected Sources:PS-C 0.2268 pounds particulate per million Btu heat input Sulfur Dioxide Affected Sources:PS-A and PS-B 15A NCAC 02D.0516 2.3 pounds SO>per million Btu heat input,each Sulfur Dioxide Affected Source:PS-C(when firing fuel oil) 15A NCAC 02D.0524 Fuel oil sulfur content shall not exceed 0.5%by weight. (40 CFR Part 60,Subpart Dc Visible Emissions Affected Source:PS-A 15A NCAC 02D.0521(c) 40 percent opacity Affected Source:PS-B and PS-C(when firing natural gas) 15A NCAC 02D.0521(d) 20 percent opacity Visible Emissions 15A NCAC 02D.0524 Affected Source:PS-C(when firing fuel ail) (40 CFR Part 60,Subpart 20 percent opacity Dc) Nitrogen Oxides, Affected Source:PS-B 15A NCAC 02Q.0317 Sulfur Dioxide Nitrogen oxide<40 tons per year (PSD Avoidance) Sulfur dioxide<40 tons 2er vear Sulfur Dioxide Affected Sources:PS-A,PS-B,PS-C,and PS-Temp 15A NCAC 02Q.0317 Sulfur dioxide<702.5 tons per year. (PSD Avoidance) See Section 2.2 A.1 of this permit Hazardous Air Pollutants Affected Sources:PS-A,PS-B,and PS-C 15A NCAC 02D.I I11(40 Work Practices CFR Part 63,Subpart DDDDD) 1. 15A NCAC 02D.0503:PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter from the combustion of natural gas and No.2 fuel oil that are discharged from the affected boilers(ID Nos.PS-A and PS-B)into the atmosphere shall not exceed 0.2667 pounds per million Btuheat input. b. Emissions of particulate matter from the combustion of natural gas and No.2 fuel oil that are discharged fromthe affected boiler(ID No.PS-C)into the atmosphere shall not exceed 0.2268 pounds per million Btu heat input. Testine[15A NCAC 02Q.0508(f)] c. If emissions testing is required,the testing shall be performed in accordance General Condition JJ.If the results of this test are above the limits given in Section 2.1 A.La or A.l.b,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0503. Permit No.037 z iT-19 03735T49 Page 6 Monitorine/Recordkeeoine/Renortina[15A NCAC 02Q.0508(f)] d. No monitoring/recordkeepingireporting is required for particulate emissions from the firing of natural gas or No.2 fuel oil in these boilers(ID Nos.PS-A,PS-B and PS-C). 2. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from the affected boilers(ID Nos.PS-A and PS-B)when firing natural gas or No.2 fuel oil,and from the affected boiler(ID No.PS-C)when firing natural gas only,shall not exceed 2.3 pounds per million Btu heat input.Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining compliance with this standard. Testin [15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 A.2.a,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0516. Monitorine/Recordkeeoine/Recordkeeuine[15A NCAC 02Q.0508(f)] c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of natural gas or fuel oil in these boilers(ID Nos.PS-A,PS-B and PS-C). 3. 15A NCAC 02D.0521:CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the affected boiler(ID No.PS-A)shall not be more than 40 percent opacity when averaged over a six-minute period.However,six-minute averaging periods may exceed 40 percent not more than once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 90 percent opacity. b. Visible emissions from the affected boiler(ID No.PS-B)shall not be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 87 percent opacity. c. Visible emissions from the affected boiler(ID No.PS-C)shall not be more than 20 percent opacity when averaged over a six-minute period when natural gas is fired in the boiler.However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 87 percent opacity. Testine[15A NCAC 02Q.0508(f)] d. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 A.3.a through A.3.c,above,the Permittee shall bedeemed in noncompliance with 15A NCAC 02D.0521. Monitorine/RecordkeeI)ine/Reoortine[15A NCAC 02Q.0508(f)] e. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas or No.2 fuel oil in these boilers(ID Nos.PS-A,PS-B and PS-C). 4. 15A NCAC 02D.0524:New Source Performance Standards(40 CFR 60,Subpart Dc) a. For the affected boiler(ID No.PS-C),while firing No.2 fuel oil only,the Permittee shall comply with all applicable provisions,including the notification,testing,recordkeeping,and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 02D.0524,"New Source Performance Standards" (NSPS)as promulgated in 40 CFR 60,Subpart Dc,including Subpart A,"General Provisions." Emission Limitations b. The maximum sulfur content of any fuel oil received and fired in the affected boiler(ID No.PS-C)shall not exceed 0.5 percent by weight.[40 CFR 60.42c(d)] c. Visible emissions from the affected boiler(ID No.PS-C)shall not be more than 20 percent opacity when averaged over a six-minute period,except for one six-minute period per hour of not more than 27 percent opacity.[40 CFR 60.43c(c)] Permit No.03'11�PT4 9 03735T49 Page 7 d. The opacity standards in Section 2.1 A.4.c,above,applies at all times when firing No.2 fuel oil,exceptduring periods of startup,shutdown or malfunction.[40 CFR 60.43c(d)] e. No fuel sulfur limits or opacity limits apply under 15A NCAC 02D.0524 when firing natural gas in the affected boiler(ID No.PS-Q. Testing[15A NCAC 02Q.0508(o] f. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limits given in Section 2.1 A.4.b or A.4.c,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524. g. The Permittee shall conduct an initial performance test using Method 9 of Appendix A-4 of 40 CFR Part 60 and in accordance with General Condition JJ to demonstrate compliance with the opacity limit in Section 2.1 A.4.c,above, and as follows.[40 CFR 60.47c(a)] i. The Pcnnittee shall conduct the performance test within 180 days of initial startup. ii. The Permittee shall conduct subsequent Method 9 of Appendix A-4 of 40 CFR Part 60 performancetests according to the schedule specified in Section 2.1 A.4.i,below. iii. The observation period for Method 9 of Appendix A-4 of 40 CFR Part 60 performance tests may be reduced from 3 hours to 60 minutes if all 6-minute averages are less than 10 percent and all individual 15-second observations are less than or equal to 20 percent during the initial 60 minutes of observation. If the results of this test are above the limits in Section 2.1 A.4.c,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524. Fuel Sulfur Monitorin¢[15A NCAC 02Q.0508(t)] h. To assure compliance with the fuel sulfur limit in Section 2.1 AA.b,above,the Permittee shall retain a copy of the fuel supplier certification for any fuel oil fired at the affected boiler(ID No.PS-C).The fuel supplier certification shall include the following information: i. The name of the oil supplier; ii. The sulfur content of the oil(in°/by weight);and iii. A statement from the oil supplier that the oil complies with the specification under the definition ofdistillate oil in 40 CFR 60.41c. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if the sulfur content of the oil exceeds the limit provided in Section 2.1.A.4.b of this permit or if fuel supplier certifications are not retained as described above.[40 CFR 60.46c(e),40 CFR 60.48c(flJ Opacity Monitoring[15A NCAC 02Q.0508(f)] i. After completion of the initial performance testing in Section 2.1 A.4.g,above,the Permittee shall complywith visible emissions monitoring according to the following: i. The Permittee shall conduct subsequent Method 9 performance tests using the applicable schedule in Section 2.1 A.4.i(i)(A)through A.4.i(i)(D),below,or within 45 days of switching fuel combustion from natural gas to No.2 fuel oil,whichever is later,as determined by the most recent Method 9 performance test results.The observation period for Method 9 performance tests may be reduced from 3 hours to 60 minutes if all 6-minute averages are less than 10 percent and all individual 15-second observations are less than or equal to 20 percent during the initial 60 minutes of observation.[40 CFR 60.47c(a)(1)J A. If no visible emissions are observed,a subsequent Method 9 performance test must be completed within 12 calendar months from the date that the most recent performance test was conducted; B. If visible emissions are observed but the maximum 6-minute average opacity is less than or equal to 5 percent,a subsequent Method 9 performance test must be completed within 6 calendar months fromthe date that the most recent performance test was conducted; C. If the maximum 6-minute average opacity is greater than 5 percent but less than or equal to 10 percent,a subsequent Method 9 performance test must be completed within 3 calendar months from the date thatthe most recent performance test was conducted;or D. If the maximum 6-minute average opacity is greater than 10 percent,a subsequentMethod 9 performance test must be completed within 45 calendar days from the date that the most recent performance test was conducted. ii. If the maximum 6-minute opacity is less than 10 percent during the most recent Method 9 performance test,the Permittee may,as an alternative to performing subsequent Method 9 performance tests,elect to perform Permit No.0"z�Ta ee 03735T49 Page 8 subsequent monitoring using Method 22 according to the procedures specified in Section 2.1 A.4.i(ii)(A)and A.4.i(ii)(B)below.[40 CFR 60.47c(a)(2)] (A)The Permittee shall conduct 10 minute observations(during normal operation)each operating day the affected boiler(ID No.PS-C)fires No.2 fuel oil using Method 22 and demonstrate that the stun of the occurrences of any visible emissions is not in excess of 5 percent of the observation period(i.e.,30 seconds per 10 minute period).If the sum of the occurrence of any visible emissions is greater than 30 seconds during the initial 10 minute observation,immediately conduct a 30 minute observation.If the sum of the occurrence of visible emissions is greater than 5 percent of the observation period(i.e.,90 seconds per 30 minute period),the owner or operator shall either document and adjust the operation of the facility and demonstrate within 24 hours that the sum of the occurrence of visible emissions is equal to or less than 5 percent during a 30 minute observation(i.e.,90 seconds)or conduct a new Method 9 performance test using the procedures in condition(i)(i)above within 45 calendar days. (B) If no visible emissions are observed for 10 operating days during which No.2 fuel oil is fired,observations can be reduced to once every 7 operating days during which No.2 fuel oil is fired.If any visible emissions are observed,daily observations shall be resumed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if the opacity monitoring is not conducted as specified. Recordkeenin¢[15A NCAC 02Q.0508(f)and 40 CFR 60.48c(g)(2)] j. The Permittee shall record and maintain records of the amounts of each fuel fired during each month.ThePermittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if records of the amount of each fuel fired during each month are not maintained. k. The Permittee shall maintain records of No.2 fuel oil supplier certifications as specified in Section 2.1 A.4.h.i, above.[40 CFR 60-48c(e)(11),(i7(I)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if records of fuel sulfur content monitoring are not maintained. 1. The Permittee shall keep the following opacity monitoring records:[40 CFR 60.48c(c)(1),(2)] i. For each performance test conducted using Method 9 of appendix A-4 of 40 CFR Part 60,the Permittee shall keep the records including the following: (A) Dates and time intervals of all opacity observation periods; (B) Name,affiliation,and copy of current visible emission reading certification for each visible emission observer participating in the performance test;and (C) Copies of all visible emission observer opacity field data sheets. ii. For each performance test conducted using Method 22 of appendix A-4 of 40 CFR Part 60,the Permittee shall keep the records including the following: (A)Dates and time intervals of all visible emissions observation periods; (B) Name and affiliation for each visible emission observer participating in the performance test; (C) Copies of all visible emission observer opacity field data sheets;and (D)Documentation of any adjustments made and the time the adjustments were completed to the affected facility operation by the Permittee to demonstrate compliance with the applicable monitoringrequirements. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if these opacity monitoring records are not maintained. m. The Permittee shall maintain records of any occurrence and duration of any startup,shutdown,or malfunction in the operation the affected boiler(ID No.PS-C).[40 CFR 60.7(b)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if the records of startups,shutdowns, and malfunctions are not maintained. o. All records required under Section 2.1 AA j through A.4.m shall be maintained by the Permittee for a period of two years following the date of such record.[40 CFR 60.48c(i)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if the records are not maintained for the duration of 2 years. Permit No.03 73 4 8Tn o0 03735T49 Page 9 Initial Notification[15A NCAC 02Q.0508(f)] p. The Permittee shall submit a construction notification of the date construction of the affected boiler(ID No.PS-C) is commenced,postmarked no later than 30 days after such date.[40 CFR 60.7(a)(1)] q. The Permittee shall submit an initial notification to the Regional Supervisor within 15 days of actual startup ofthe affected boiler(ID No.PS-C).The notification shall include: i. The actual date of initial startup;and, ii. The design heat input capacity of the boiler and identification of fuels to be combusted in the boiler. [40 CFR 60.48c(a),40 CFR 60.7(a)(3)] Reoortine[15A NCAC 02Q.0508(f)] r. The Permittee shall submit a semiannual summary report postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June.All instances of noncompliance from the requirements of this permit and excess emissions must be clearly identified.The summary report shall include the following information: i. Fuel supplier certifications)for distillate fuel oil,as provided in Section 2.1.A.4.e of this permit;and ii. A certified statement signed by the Permittee that the records of fuel supplier certification(s)submitted represents all of the fuel fired at the affected boiler(ID No.PS-C)during the semiannual period. iii. Records from any subsequent performance tests conducted as required in Section 2.1 A.4.1,above. 5. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,theaffected boiler(ID No.PS-B only)shall discharge into the atmosphere less than the following,per consecutive 12-month period. Pollutant Emission Limitation tons per ear Nitrogen Oxide 40 Sulfur Dioxide 40 Testine[15A NCAC 02Q A508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 A.5.a,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530. MonitorinORecordkeenina[15A NCAC 02Q.0508(f)] c. The Permittee shall keep monthly records of fuel usage in a logbook(written or in electronic format),asfollows: i. The total quantity(in million standard cubic feet)of natural gas fired at the affected boiler; ii. The total quantity(in 1,000 gallons)of No.2 fuel oil fired at the affected boiler;and, iii. The fuel oil supplier certification for any fuel oil fired at the affected boiler(ID No.PS-B),including the sulfur content of the fuel oil(in percent by weight). The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the fuel usage and fuel oil sulfur contents are not created and retained as required above. d. The Permittee shall calculate monthly and 12-month rolling NOx emissions from the affected boiler(ID No.PS-B) within 30 days after the end of each calendar month.Calculations shall be recorded in a logbook(written or electronic format),according to the following formulas: i. Calculate NOx emissions from the previous calendar month using the following equation: E,�=20•Qr r+100•Q„s Where, ENoc = NOx emissions(pounds)during the previous calendar month; Qr� = Quantity of fuel oil fired during the previous calendar month(1,000 gallons); and, Pemrit No.0 T4 Q^Q 03735T49 Page10 Qs = Quantity of natural gas fired during the previous calendar month(million standard cubic feet). H. Sum the NOx emissions from the affected boiler for the previous 12-month period to determine the 12-month rolling emission total. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations listed above are not retained or if the 12-month rolling NOx emission totals are greater than the NOx emission limit provided in Section 2.1 A.5.a of this permit. e. The Permittee shall calculate monthly and 12-month rolling SO_,emissions from the affected boiler within 30 days after the end of each calendar month.Calculations shall be recorded in a logbook(written or electronic format), according to the following formulas: i. Calculate SO2 emissions from the previous calendar month using the following equation: Eso=142*Sfa*Qf,+0.6*Q„g Where,ES02 = SO,emissions(pounds)during the previous calendar month; S r = Sulfur content in the fuel oil(percent by weight). Qr„z = Quantity of fuel oil fired during the previous calendar month(1,000 gallons); and, Q„g = Quantity of natural gas fired during the previous calendar month(million standard cubic feet). ii. Sum the SO-,emissions from the affected boiler for the previous 12-month period to determine the 12-month rolling emission total. The Pemrittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations listed above are not retained or if the 12-month rolling SO,emission totals are greater than the S02 emission limit provided in Section 2.1 A.5.a of this permit. Reuortine[15A NCAC 02Q.0508(f)] f The Pemuttee shall submit a semi-annual summary report of monitoring and recordkeeping activities postmarkedon or before January 30 of each calendar year for the preceding six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: i. The monthly NOx and S02 emissions from the affected boiler for the previous 17 calendar months; ii. The 12-month rolling NOx and SO,emissions for each 12-month period ending during the reportingperiod; and, iii. All instances of noncompliance from the requirements of this permit must be clearly identified. 6. 1 NA NGAG 020.4 r on.Case 6. ease MALT r9 M3 c r each boiler rrn Nos nc � nc u-.ad oe n� fagH:rementS-l+sfea bele.. 'S-B1.09}H BF-1_,l- .. ��. e imp rune� _. . Permit No.0T]^vT mTT 4 9 03735T49 Page 11 include the fellowliBg.� i. hispeet,ti_,,WmeF,and clewn erfepiaee my eempenewitseftlie ili i the all-te f4el t it "� system e C t B,anti PS shall be ma fltaimied in a leebeek(,Arittedi ar eleetreme format)oil site and wadp.evnilabla tA ii Tl.o Fe It..,.a....,.1,:aspeetioni ..a n. The...,....a..... ..y ..a....ar..an.rr Yr..unnru v.,the-beilwncrs ^••••rt7n••��c n err-AC-urn 0jog(f)l .4h I yr> nn c 1. 1net reat en is1. a i. Gemp3'H_y-Home an, addFess, ii. Statement by a fespeasible effiei84 with that affietal's Hama,title,alid signatkife,eei4ib-iiig Vie fRtth,aeewae�, c-Tcpof*iii. Date ofrapon and beg4naia,-and ending dates efthe Fepei4ing peFied�and, a:6_15A NCAC 02D.1111:MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY_ Auolicabilitv a. For the boilers(ID Nos.PS-A,PS-B,and PS-C),the Permittee shall comply with all applicable provisions for the "writ designed to bum gas 1 subcategory,"including the monitoring,recordkeeping,and reporting contained in Environmental Management Commission Standard 15A NCAC 02D.1111"Maximum Achievable Control Technology"(MALT)as promulgated in 40 CFR 63,Subpart DDDDD."National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and Process Heaters" and Subpart A"General Provisions." [40 CFR 63.7485,63.7490(d),63.7499(1)] b. In order for the boilers(ID Nos.PS-A,PS-B,and PS-C)to be considered in the"unit designed to bum gas 1 subcategory,"the Permittee shall only burn liquid fuel for periodic testing of liquid fuel,maintenance,or operator training,not to exceed a combined total of 48 hours during any calendar year,and during periods of gas curtailment or gas supply interruptions of any duration.The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the No.2 fuel oil is burned in the boilers(ID Nos.PS-A,PS-B,and PS-C)for periodic testing of liquid fuel,maintenance or operator training for more than 48 hours during any calendar year or if No.2 fuel oil is burned in the boilers(ID Nos.PS-A,PS-B,and PS-C)during any periods other than gas curtailment or gas supply interruption.[40 CFR 63.7575] Definitions and Nomenclature c. For the purpose of Section 2.1 TA,the definitions and nomenclature contained in 40 CFR 63.7575 shall apply. Permit No.n'-"� iT4 e 03735T49 Page 12 40 CFR Part 63 Subpart A-General Provisions d. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A,General Provisions,according to the applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63,Subpart DDDDD.[40 CFR 63,75651 Compliance Date e--The Permittee shall comply with the''. " "120)standards:..Seeti.n 2.1 .,6 thfeugh May r9,2�1 mow-FR ----- - i-e. Qi;and.#eF,,r.y 2Q ,m o-th&Penuittee,sh& ,.,......�,....:,�.a,e requirements of Section 2.1 A;6_fo_r the boilers ��Formatted-Highlight (ID Nos.PS-A and PS-B) +i i_The Permittee shall comply with the requirements of this section for boiler(ID No.PS-C)an May 20,2�'n a Formatted:Right: 0.63",Line spacing: single,Tab upon startup,wb ate. stops:0.9",Left+ 0.9",Left+Not at 1.15"+ 1.15" The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the compliance dates are not met. Notifications f. As specified in 40 CFR 63.9(b)(4)and(5), r tlor the boiler(ID No.PS-C'� n, 204-9,the Permittee shall submit an Initial Notification not later than 15 days after the actual date of startup of the boiler.[40 CFR 63.7545(c)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the Initial Notification is not submitted. g. The Permittee shall submit a Notification of Compliance Status for the boilers(ID Nos.oo `,"r 4 ro,^K4 PS-C). The notification must be signed by a responsible official and postmarked before the close of business within 60 days of the eamplimee date spee:a-a, c etion 2.' ^' abov,start-rip date of the boiler.The notification shall contain the following: i. A description of the boilers(ID Nos.D° `,o aQ, PS-C),including a statement that the boilers axis in "the unit designed to bum gas 1 subcategory,"the design heat input capacity of the boilers,and description of the fuel(s)burned. ii. The following certification(s)of compliance,as applicable: A. A signed certification that the facility completed the required initial tune-up for the boiler t ID No.PS-C1 ell- f flie la e,:.._s covered by 40 CFR Part 63,Subpart DDDDD-ua an o�•����t�according to the procedures Section 2.1 A,�6.j,below;and ___ _________________________ _. Formatted:Highlight B. A signed certification that either the energy assessment performed according to Section 2.1 A;b.n, - -------—--below,and that the assessment is an accurate depiction of the facility at the time of the assessment,or Formatted:Highlight that the maximum number of on-site technical hours specified in the definition of energy assessment applicableto the facility has been expended. [40 CFR 63.7545(e)(8)and 63.7530(e),and(f)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1 I I I if the Notification of Compliance Status is not submitted. h. The Permittee shall submit a notification of intent to fire an alternative fuel within 48 hours of the declaration of each period of natural gas curtailment or supply interruption.The notification must include the following information: i. Company name and address; ii. Identification of the affected boiler; iii. Reason the Permittee is unable to use natural gas or equivalent fuel,including the date when the natural gas curtailment was declared or the natural gas supply interruption began; iv. The type of alternative fuel the Permittee intends to use;and v. Dates when the alternative fiiel use is expected to begin and end. [40 CFR 63.7545(f)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the notification of intent to fire an alternative fuel is not submitted. General Compliance Re+tuirements i. The Permittee shall comply with the work practice standards in Section 2.1 A;b.j,below,at all times the boilers _._____ Formatted-Highlight (ID Nos.PS-A,PS-B,and PS-C)are operating.[40 CFR 63.7500(f)and 63.7505(a)] Permit No.037zo�Tn 8 03735T49 Page 13 Work Practice Standards[15A NCAC 02Q.0508(f)] j. The Permittee shall conduct each tune-up of the boilers(ID Nos.PS-A,PS-B,and PS-C)as specified below.The Permittee shall conduct each boiler tune-up while burning the type of fuel that provided the majority of the heat input to the boiler of the 12 months prior to the tune-up. i As applicable,the Permittee shall inspect the burner,and clean or replace any components of the burner as necessary.The Permittee may perform the burner inspection at any time prior to the tune-up or delay the burner inspection until the next scheduled or unscheduled shutdown,but each burner must be inspected at least once every 72 months. ii. Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame pattern.The adjustment should be consistent with the manufacturer's specifications,if available; iii. Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctlycalibrated and functioning properly.The Permittee may delay the inspection until the next scheduled unit shutdown. iv. Optimize total emissions of carbon monoxide.This optimizationshould be consistent with the manufacturer's specifications,if available,and with any NOx requirement to which the unit is subject. v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by volume,and oxygen in volume percent,before and after the adjustments are made(measurements may be either on a dry or wet basis,as long as it is the same basis before and after the adjustments are made).Measurements may be taken using a portable CO analyzer. vi. The oxygen level shall be set no lower than the oxygen concentration measured during the most recent tune-up. [40 CFR 63.7500(a),63.7540(a)(10)and(12)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if these work practice standards are not met. k. The tune-ups for the boilers(ID Nos.PS-A,PS-B,and PS-C)shall be conducted according to thefollowing schedule.[Table 3 of Subpart DDDDD] ii-i. The initial tune-up for the new boiler(ID No.PS-C)shall be no later than 61 months after initial startup ofthe unit.[40 CFR 63.7510(g)and 63.7515(d)] iii-ii. Subsequent tune-ups for each boiler(ID Nos.PS-A,PS-B,and PS-C)shall be conducted every 5 years and no more than 61 months after the previous tune-up.[40 CFR 63.7540(a)(12),63.7515(d)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the initial and annual tune-ups are not conducted as specified. 1. If the boilers(ID Nos.PS-A,PS-B,and PS-C)are not operating on the required date for a tune-up,the tune-up must be conducted within 30 calendar days of startup.[40 CFR 63.7515(g)and 63.7540(a)(13)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the delayed tune-up is not conducted within 30 calendar days of startup. m. At all times,the Permittee shall operate and maintain the boiler,including associated air pollution control equipment and monitoring equipment,in a manner consistent with safety and good air pollution control practices for minimizing emissions.Determination of whether such operation and maintenance procedures are being used will be based on information available to DAQ that may include,but is not limited to,monitoring results,review of operation and maintenance procedures,review of operation and maintenance records,and inspection of the source. [40 CFR 63.7500(a)(3)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the boiler is not operated in a manner consistent with safety and good air pollution control practices for minimizing emissions. n. Te demeiistmte ini6a!eempliaiiee,the Peiimttee shall alse eendHet a one tifne energy assessment fer the existing evaluaiiemi for the F4311ow g _OR site teelinieal hetifs as dagned in 40 GrR 63.7575. 63 7cnna,ul l Tab" i. :4-yistta4 inspe,.tiwi of-the boiler or process heater system. ..a. oa fia al .`aj� vj.�... .bzs. e o Permit No.9373§T4 03735T49 Page 14 lags,and fiael usage. )'Oaf- between '-008 and May ,- the Oflffff as Recordkee sine Reouirements[15A NCAC 02Q.0508(f)] o-n_The Permince shall keep the following records: i. A copy of each notification and report submitted to comply with Section 2.1 A;6,including all documentation ______- Formatted:Highlight supporting any Initial Notification or Notification of Compliance Status,or semiannual compliance reportthat has been submitted,according to the requirements in 40 CFR 63.10(b)(2)(xiv).[40 CFR 63.7555(a)(1)] ii. A report,maintained on-site and submitted to DAQ if requested,containing the information in paragraphs(A) through(C)below[40 CFR 63.7540(a)(10)(vi)]: (A)The concentrations of carbon monoxide in the effluent stream of each boiler(ID Nos.PS-A,PS-B,and PS-C)in parts per million by volume,and oxygen in volume percent,measured before and after the tune- ups of the boilers; (B) A description of any corrective actions taken as a part of the tune-up;and (C) The type and amount of fuel used over the 12 months prior to the tune-ups,but only if the boilers were physically and legally capable of using more than one type of fuel during that period.Units sharing afuel meter may estimate the fuel use by each unit. iii. The associated records for compliance with the work practice standards in Section 2.1 A_;6.i through Ay 6.m, ____ - Formatted:Highlight above,including the occurrence and duration of each malfunction of operation(i.e.,process equipment)orthe required air pollution control and monitoring equipment.[40 CFR 63.10(b)(2)] Formatted:Highlight iv. Records of the total hours per calendar year that alternative fuel is burned in the boilers(ID Nos.PS-A,PS-B, and PS-C)and the total hours per calendar year that the boilers operated during periods of gas curtailment or gas supply emergencies.[40 CFR 63.7555(h)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I11 if these records are not maintained. ",:Me Permittee shall: i. maintain records in a form suitable and readily available for expeditious review; ii. keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective action,report,or record;and iii. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance, corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if records are not maintained as specified above.[40 CFR 63.7560 and 63.10(b)(1)] Reoortine Requirements[15A NCAC 02Q.0508(o] tl-p_The Permittee shall submit compliance reports to the DAQ every five years.The first report shall cover theperiod beginning on the compliance date specified in Section 2.1 A 76.e,above,and ending on December 31 within five __ __ - Formatted:Highlight years after the compliance date in Section 2.1 A.7,�6_e,above.Subsequent reports shall cover the five-year periods________. from January 1 to December 31.The compliance reports shall be postmarked on or before January 31. Formatted:Highlight [40 CFR 63.7550(a),(b)and 63.10(a)(4),(5)] Fg_The Permittee shall submit the witial-compliance report via the CEDRI.(CEDRI can be accessed throughthe EPA's Central Data Exchange,CDX.)The Permittee shall use the appropriate electronic report in CEDRI 40 CFR Part 63, Subpart DDDDD.Instead of using the electronic report in CEDRI for this 40 CFR Part 63,Subpart DDDDD,the Permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html),once the YJAL schema is available.If the reporting form specific to Permit No.03 73 4 Q 03735T49 Page 15 40 CFR Part 63,Subpart DDDDD is not available in CEDRI at the time that the report is due,the Permittee shall submit the report to DAQ.The Permittee shall begin submitting reports via CEDRI no later than 90 days afterthe form becomes available in CEDRI.[40 CFR 63.7550(h)(3)] +r_The Permittee shall include the following information in the annual compliance report: i. Company and facility name and address; ii. Process unit information,emissions limitations,and operating parameter limitations; iii. Date of report and beginning and ending dates of the reporting period; iv. The date of the most recent tune-up for each boiler(ID Nos.PS-A,A-B,and PS-C)required according to Section 2.1 Aj .j_Include the date of the most recent burner inspection if it was not done as scheduled and - Formatted:Highlight was delayed until the next scheduled or unscheduled unit shutdown;and v. If there are no periods of noncompliance from the requirements of the work practice requirements in Section2.1 AA.j,above,a statement that there were no deviations from the work practice standards during the reporting Formatted:Highlight period. --------------------------- [40 CFR 63.7550(a)and(c)(1),(c)(5)(i)through(iii),(c)(5)(xiv),(c)(5)(xvii),and Table 9] 4-s_If the Permittee has a period of noncompliance with a work practice standard for periods of startup andshutdown during the reporting period,the compliance report must also contain the following information: i. A description of the period of noncompliance and which work practice standard from which the Permittee was in noncompliance;and ii. Information on the number,duration,and cause of periods of noncompliance(including unknown cause),as applicable,and the corrective action taken. [40 CFR 63.7540(b),63.7550(a)and(d)and Table 9] Permit No.0z"�T^ 03735T49 Page16 B.FPS/IXM Process Area consisting of: a.,:...^_. n..,._..t: ..c^^......:^tone Alt^.. otiye Operating seenario(t OS) _ are: tFollw,,._,,._p o f two The following emission units are controlled by a thermal 6^en,.^�...^�'_..tir.^_..nn.,^- N CP 14dr,or Nv^n ua..o, oxidizer(ID No.NCD-Ql)in series with a 4-stage scrubber (ID No.NCD- 2) NS rs^..^n..^_^pr9p. tiro^ NS-A Hexafluoropropylene oxide(HFPO)Process NS B .1.^-.-t.^-^N1 th^^ n•^^^ NS-B Vinyl Ethers North Process NS E Vinyl Ethers South Proees NS-C Vinyl Ethers South Process Nicni oar i Process(except ana Syste.•^'r) NS-D-1 RSU Process(except S03 System) yS fs NS-E Liquid Waste Stabilization Process NS h *I,, �F P�---^S NS-F MMF Process NS-G-1 IXM Resins Process—except Fluorinator The a.n,._.:..^ ^.._^ A e9atro"ed in the ti..m^plate NS-K E-2 Process NS G 1 rvn,Resins Process exceptcl..^_:..^t^_ NS-M TFEICO2 Separation Process NS E 2,-,oee„ NS-N HFPO Product Container Decontamination Process I NS VI A'ni Separation Pr^^e^s* NS-0 Vinyl Ethers North Product Container Decontamination Process NS-P Vinyl Ethers South Product Container rfaeogs* Decontamination Process NS Q Vinyl EtheFs NeFth Product Container The following emission unit is controlled by a caustic scrubber(ID No.NCD G2)(POS flH%nS): IXM Resins Process—Fluorinator(ID No.NS-G-2) The following emission units are controlled by a wet scrubber with a mist eliminator(ID No.NCD-D)(1-'OSfind ADIS): S03 System,including S03 Storage Tank,S03 Vaporizer,S03 Truck Unloading,and Reservoir Tank(ID No.NS- D-2) The following emission units are controlled by carbon adsorbers(ASS enly): VE-North Indoor Fugitives(ID No.NS-B-2,Carbon Adsorber ID No.NCD-Q3); VE-South Indoor Fugitives(ID No.NS-C-2,Carbon Adsorber ID No.NCD-Q4);and Semiworks Polymerization Operation and Semiworks Laboratory Hood(ID Nos.SW-1 and SW-2,Carbon Adsorber ID No.SCD-SWI) The following sources are not controlled(PGS- d-. n : IXM Membrane Process(ID No.NS-H);and IXM Membrane Coating(ID No.NS-I) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate Matter Affected Sources:ID Nos.NS-I and NS-D-2 15A NCAC 02D.0515 E=4.10 x Pa 11 for P<30 tons/hour where: E=allowable emission rate in pounds per hour,and P=process weight rate in tons per hour Sulfur Dioxide Affected Source:ID No.NCD-Ql 15A NCAC 02D.0516 2.3 lb SO_,per million Btu heat input Perrmt No.9373 5 A 8 03735T49 Page17 Regulated Pollutant Limits/Standards Applicable Regulation '- Formatted Table Visible Emissions Affected Sources:ID Nos.NS-I,NS-D-2,and 15A NCAC 02D.0521 NCD-Q2 20%visible opacity emissions Odors State-enforceable only 15A NCAC 02D.1806 See Section 2.2 B.5 Toxic Air Pollutants State-enforceable only(all FPM/IXM process 15A NCAC 02D.1100 units) Toxic air pollutant limits shall not be exceeded.See Sections 2.2 B.1 and 2.2 B.2 Volatile Affected Sources:ID No.NS-B VOC 15A NCAC 02Q.0317 Organic emissions<68.9 tons/12-month Affected (PSD Avoidance) Compounds Sources:ID No.NS-G-1 and G-2 VOC emissions<40 tons/12-month Affected Sources:ID No.NS-A VOC emissions<85.3 tons/12-month Affected Sources:ID No.NS-N VOC emissions<40 tons/12-month Volatile Organic Affected Sources:ID No.NS-I 15A NCAC 02D.0530(u) Compounds Reporting for Projected Actual VOC Emissions Hazardous Affected Sources:ID Nos.NS-A,NS-B,N'S-B-2, 15A NCAC 02D.1111 Air NS-C,NS-C-2,NS-G-1,and NS-G-2 (40 CFR 63,Subpart FFFF) Pollutants LDAR,wastewater,and heat exchanger requirements. All PFAS' State-enforceable only 15A NCAC 02Q.0519 (including GenX Affected Sources:ID Nos.NS-A,NS-B,NS-C,NS- Consent Order' Compounds) D-1,NS-E,NS-F,NS-G-1,NS-E,NS-M,NS-N,NS- O,and NS-P 99.99 percent emission reduction of all PFAS (including GenX Compounds) GenX Compounds' State-enforceable only 15A NCAC 02Q.0519 Affected Sources:All FPNMM process area Consent Order sources See Section 2.2 D.1 ) JSJ�'r�Jr n��Jcnu�. 1•rrnn-JTn c nncn JTJv�•c•�•rn JOJnc TJle-f'rrt+i+tt�r-ee3ntzlxyeratreeu;Irwitlt-ltlaking�eltalr�out-f»kenaatir'e�perat+rrl-sse�+taric�-te+u}otl}�1a11-r�tot�3- The PFiina3' Opeiati Seetiaiie(POS)i defined I a v= �, TTsa-.c [c's-aS`rt'�l,�ir•�v n,[� rrr S Tile 1 FPO ll:,,y1 Elhef�s\'..+1, Vill,.I E l,eFs South,RS i CDC Liquid J Waste Stabilization,and\P IF T)Face-ses NGD lid ter.... ,l., w-r•n J 1--,, } - It—T,,, TCCt41E- 2 S ef oerot}rtar»aaation.and-1 E­S- Gantainei- PFae,qqeS(11)Nos.NS M,NS N,. , "'111-==-------=--- "-------- , � -------— Formatted:Font:10pt b—Elie-\#�rttat*+�©perati+wt Sce sari r-f-. s.de., ed as the HrD� o moo- �ss 4 in 1€tbers tic rtlrRroees�ti tt1 _ �.,. .� •�� Formatted:Indent:Left: 0.5",Numbered+Level:1+D 2pF11{ tat .,.,.•yY O moo.,. .� cnn o+.emu,.«r «- rB�� ny not olrPrEx esr Numbering Style:a,b,c,...+Start at:1+Alignment: Left+Aligned at: 1.15"+Indent at: 1A" Formatted:Indent:Left: 0.56",Numbered+Level:1+ WAS means per-and polytluoroalkyl substances. Numbering Style:a,b,c,...+Start at:2+Alignment: '-"Consent Order"means the Consent Order entered on February 25,2019,in State of North Carolina,ex rel.,Michael S.Regan,Secretary,North Carolina Left+Aligned at: 0.4"+Indent at: 0.65" EepaNnem of Environmental Quality v.The Chemours Company FC,LLC,17 CVS 580(Bladen County). 'GenX Compounds"means HFPO Dimer Acid,also known as C3 Dimer Acid(CAS No.13252-13-6);HFPO Dimer Acid Fluoride,also known as C3 Dimer Acid Fluoride(CAS No.2062-98-8);and HFPO Dimer Acid Ammonium Salt,also known as C3 Dimer Acid Ammonium Salt(CAS No.62037-80- 3). Permit No.037]�T 4 8 03735T49 Page18 B,NS C: NS n-D-1,J-S E.xrF Ns'_.+T6 1,%i;k. N r NS ccr-�—.x,-24, o_a.�"c n ....EI--15i-�'jzTrE!-ePnfr�Rza by!h Therniall I b th�I�- die- 08 nrt,r)!1C and r' the 4e ic'�f J!'11ftS"f� 11 �,.. .,n.,.. �__.. --k'� •• ��- "�c�^`���-G'=�-��ne���*��`'�^� Formatted:List Paragraph,Right: 0.46",Numbered+ ssrt l B 1a \E=1?E 2},Er�}t}x 14" a'He-pi:oeessau 1Xk1-k(a k3FaExE atirr (Fla-P o iivi-kll aarrEtt. Level:1+Numbering Style:a,b,c,...+Start at:2+ Alignment:Left+Aligned at: 0.4"+Indent at: 0.65", .NG0 Tab stops: 0.9",Left+ 0.9",Left Formatted:Font:10 pt carbon adso&F QD}Ne:SEA[-SNN44. Formatted:Numbered+Level:1+Numbering Style: - ' a,b,c,...+Start at:2+Alignment:Left+Aligned at: 0.4"+Indent at: 0.65" �n-L4�-dak+t�t�-t��aEntk'-s+vitcltiHg-Ec the-:�S.- 2-.1.15A NCAC 02D.0515:PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from the membrane coating process(ID No.NS-I)and SOa System(ID No.NS-D- 2)shall not exceed an allowable emission rate as calculated by the following equation: E=4.10xPo." Where: E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results ofthis test are above the limit given in Section 2.1 Bkl.a,above,the Pennittee shall be deemed in___-__-_-_-- Formatted:Highlight noncompliance with 15A NCAC 02D.0515. Monitorine/RecordkeepinQ[15A NCAC 02Q.0508(f)] c. The Permittee shall maintain production records such that the process rates"P"in tons per hour,as specified by the formula contained above(or the formula contained in 15A NCAC 02D.0515)can be derived,and shall make these records available to a DAQ authorized representative upon request.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the production records are not maintained or the types of materials and finishes are not monitored. Reportine[15A NCAC 02Q.0508(f)] d. The Permittee shall submit a summary report of monitoring and recordkeeping activities specified in Section 2.1 B,c I.c,above,postmarked on or before January 30 of each calendar year for the preceding six-month period __- 1 Formatted Highlight between July and December and July 30 of each calendar year for the preceding six-month period between January andJune.All instances of noncompliance from the requirements of this permit must be clearly identified. &2.15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. n0c Emissions of sulfur dioxide from the Thermal Oxidizer(ID No.NCD-Ql)shall not exceed 2.3 pounds per million Btu heat input.Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining compliance with this standard. Tes' [15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 B j2.a above the Permittee shall be deemed in_-_--_-____- Formatted:Highlight noncompliance with 15A NCAC 02D.0516. Monitorine/Recordkeepine/Reportine[15A NCAC 02Q.0508(f)] c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of natural gas in the Thermal Oxidizer(ID No.NCD-Ql). Permit No.n x�z�PTl as 03735T49 Page 19 -1:3_15A NCAC 02D.0521:CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the membrane coating process(ID No.NS-I),the S03 System(ID No.NS-D-2),and the outlet of the 4-Stage Scrubber(ID No.NCD-Q2)shall not be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 87 percent opacity. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 B;3.a above,the Permittee shall be deemed in________ _- :Formatted:Highlight noncompliance with 15A NCAC 02D.0521. a Monitorinz/Recardkeeoine/Renor-tine[15A NCAC 02Q.0508(0] c. No monitoring/recordkeeping/reporting is required for visible emissions from these sources. _15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the Vinyl Ethers North process(ID No.NS-B)shall discharge into the atmosphere less than 68.9 tons of VOCs per consecutive 12-month period. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 B; l.a,ab_ov_e,the _ - Formatted Highlight Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530. Monitorine/Recardkeeuine[15A NCAC 02Q.0508(f)] c. To demonstrate compliance with the limit provided in Section 2.1 B�l.a,above,within 30 days of the end of each __• Formatted:Highlight calendar month the Permittee shall create and retain production records and estimate associated VOC emissions for the previous calendar month,as follows: i. Determine the process vent mass flow rates of non-acid fluoride VOC(Q AF)and acid fluoride VOC(QAF)prior to the control device during the previous calendar month(in lb/month); ii. Calculate the VOC emissions(Ev)from the process vents during the previous calendar month(inlb/month) using ena- the following equations: r •-- ' _ � . Formatted:Right:0.67",Tab stops: 1.15",Left+Not ' _ at 1.4" •- os. Formatted:List Paragraph,Left,Indent:Left: 1.38", ..,, ..�.. , - , �} ` Right:0.67",Space Before: 0 pt,Line spacing:single, Tab stops: 1.15",Left Ey=0.0001 X CQAF+QAP) � - Formatted:Right:0.67",Line spacing: single,Tab stops: 1.15",Left+Not at 1.4" iii. Record the total solvents used(M)in the affected facility during the previous calendar month(in lb/month); Formatted:List Paragraph,Line spacing: Exactly 10.7 iv. Record the total solvent waste generation(W)for the affected facility during the previous calendar month(in pt,Tab stops: 1.4",Left lb/month); v. Calculate the solvent VOC emissions(Es)from the affected facility during the previous calendar month(in lb/month)using the following equation: Es-if-W vi. Determine the VOC emissions from maintenance emissions(EM)during the previous calendar month(in lb/month). vii. Calculate the VOC emissions from fugitive emissions(EF)using accepted practices during theprevious calendar month(in lb/month). viii. Record VOC emissions from any accidental releases(EA)during the previous calendar month(in lb/month). ix. Calculate the total process VOC emissions(E)using the following equation(in ton/month): E=(E, Es+EAr+EP+EA)1(2,000lb;9on) Permit No.03 5-T"Q 03735T49 Page 20 Permit No.03 m 4T^o 03735T49 Page 21 x. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC emissions(E),as calculated in Section 2.1 B.,44.c.ix,above,for theprev-ious consecutive 12 months. ______ __ __ - Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are not created and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 13,�4.c.x,above exceeds the_ ___Y Formatted:Highlight --ed -- _- limitinSection2.lB t_aofthis_permit._________________________________________—_-• Formatted:Highlight d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available loan authorized representative upon request.The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the records are not maintained in a logbook on-site and are not available upon request. Reportine[15A NCAC 02Q.0508(f)] e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in Section 2.1 Bj�4_c,and d,abovepos-tmarked on or before January 30 of each calendar year for the preceding__ ___ Formatted:Highlight six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: i. The monthly VOC emissions from the affected facility for the previous 17 calendar months; ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and, iii. All instances of noncompliance from the requirements of this permit must be clearly identified. 6-6.15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the IXM Resins Process(except Fluorinator)and the IXM Resins Process Fluorinator(ID Nos.NS-G-I and NS-G-2)shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-month period. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 B;5.a ab_ov_e,the Formatted Highlight Perm ttee shall be deemed in noncompliance with 15A NCAC 02D.0530. Monitorine/Recordkeeoina[15A NCAC 02Q.0508(f)] c. To demonstrate compliance with the limit provided in Section 2.1 B.6.a,within 30 days of the end of eachcalendar month the Permittee shall create and retain production records and estimate associated VOC emissions for the previous calendar month,as follows: i. Record the total raw materials fed(M)to the affected facility during the previous calendar month(in kg/month); ii. Record the total transformed materials collected(P)for the affected facility during the previous calendar month (in kg/month); iii. Record the total untransformed materials collected(W)for the affected facility during the previous calendar month(in kg/month); iv. Determine the VOC emissions from the filling of storage tanks(S)for the affected facility during theprevious calendar month(in kg/month); v. Calculate the VOC emissions(E)from the affected facility during the previous calendar month(inton/month) using the following equations: E=(1-0.9999)*(M-P-W+S)*(2.21b/kg)/(2,0001b/ton) vi. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC emissions(E),as calculated in Section 2.1 BA .cdv,above,for theprevious consecutive 12_months___-__-______ Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are not created and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 B&.c.v,above,exceeds the---_- __- Formatted:Highlight limit in Section 2.1 13 g5.a of thispermit.___ ---------------------------------- ----—--I Formatted:Highlight Permit No.n3,�Tno 03735T49 Page 22 d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request.The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the records are not maintained in a logbook on-site and are not available upon request. Reporting[15A NCAC 02Q.0508(f)] e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in Section 2.1 B 6,5.c and B,6 .d,above,postmarked on or before January 30 of each calendar year for the preceding ____--— Formatted:Highlight six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: Formatted:Highlight i. The monthly VOC emissions from the affected facility for the previous 17 calendar months; ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and, iii. All instances of noncompliance from the requirements ofthis permit must be clearly identified. -7-.6_15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the HFPO process(ID No.NS-A)shall discharge into the atmosphere less than 85.3 tons of VOCs per consecutive 12-month period. Testing[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results ofthis test indicate annual emission rates in exceedance of the limit given in Section 2.1 B,_G.a,_ab_ov_e,the __, Formatted•Highlight Permittee shall be deemed in noncompliance with 15A NCAC-02D.0530. MonitorinORecordkceping[15A NCAC 02Q.0508(f)] c. To demonstrate compliance with the limit provided in Section 2.1 B;6.a,above,within 30 days of the end of each ______ Formatted:Highlight calendar month the Permittee shall create and retain production records and estimate associated VOC emissions for the previous calendar month,as follows: i. Record the total raw material HFP consumed(MrF)in the affected facility during the previous calendar month; ii. Record the average vent flow rate and composition from the AF column(QAc)and Stripper columns(Qsc) during the previous calendar month; iii. Determine process VOC emissions(EP,in lb/month)using a combination of ratios of vent rates(QAc and Qsc) to HFP consumption(Mmp)from the process flowsheet and actual vent data,determine the process VOC emissions(Ep,in lb/month)from the AF column(EAc),stripper column(Esc),solvent recycle tank(ESRT), solvent reclamation converters(EsRc),and routine decontamination of HFP unloading system(Ecc)using the following equation and the control efficiencies specified in the following paragraphs: Ep=EAC+Esc+ESRr+EDC n) POSi Using she baffle plate bbe.(ID 1�.. NGD Rd or NGP 1Idr2)aeidd Fl en de V/�r Pgntml . o-pcmv czT �,o„ 4 N)489Using a thermal oxidizer and 4-stage scrubber(ID Nos.NCD-QI and NCD-Q2)total VOC control efficiency of 99.99 percent. iv. Calculate the VOC emissions(in lb/month)through diL an 4 the control devices as specified below from maintenance activity(EM)based on vessel volumes and vapor density for each occurrence ofthis activityduring the previous calendar month for> T Iqk 0 fBi AGS=the thermal oxidizer and 4-stage scrubber(ID Nos.NCD_Q1.and.NCD-Q2)using a total_ Formatted:Normal,Indent:Left: 1.13", No bullets or VOC control efficiency of 99.99 percent. numbering v. Calculate the VOC emissions(in lb/month)from fugitive emissions(EF)using accepted practices duringthe previous calendar month. Formatted:Font:10 pt vi. Record VOC emissions(in lb/month)from any accidental releases(EA)during the previous calendar month. vii. Calculate the VOC emissions(E)from the affected facility during the previous calendar month(inton/month) using the following equation: E=(Ep+EM+Er.+EA)/(2,000 lb/ton) Permit No.03 19 03735T49 Page 23 viii.Calculate the 12-month rolling VOC emissions(in ton/month)from the affected facility by summing the monthly VOC emissions(E),as calculated in 2.1 C;6.c.vii,above,for the previous consecutive 12months. Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are-not-created and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 B;6.c.viii,above,exceeds the__-_ __ -. Formatted•Highlight limit in Section 2.1 B; p of this permit.._ Formatted:Highlight d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available toan authorized representative upon request.The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the records are not maintained in a logbook on-site and are not available upon request. Reoortine[15A NCAC 02Q.0508(f)] e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in Section 2.1 B__c and d,above,postmarked on or before January 30 of each calendaryear for thepreceding six-__ _ Formatted Highlight month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: i. The monthly VOC emissions from the affected facility for the previous 17 calendar months; ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and, iii. All instances of noncompliance from the requirements of this perm t must be clearly identified. &7.15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the HFPO Product Container Decontamination Process(ID No.NS-N)shall discharge into the atmosphere less than 40.Otons of VOCs per consecutive 12-month period. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results of this test indicate annual emission rates in exceedance ofthe limit given in Section 2.1 Bi�7.a,abov_ezthe Formatted:Highlight Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530. Monitorina/Recordkeeoine[15A NCAC 02Q.0508(f)] c. To demonstrate compliance with the limit provided in Section 2.1 B 87 a above,within 30 days of the end of each Formatted:Highlight calendar month the Permittee shall create and retain records and estimate associated VOC emissions for theprevious calendar month,as follows: i. Create a record of each container received at the facility including: (A) The date the container was decontaminated;and, (B) The total mass of VOC released from the container(in lb). ii. Calculate the VOC emissions from the process during the previous calendar month(in lb/month)by: (A) Summing the quantity of VOC released from each container decontaminated during the previous calendar month;and (B)A4@9=Using a total VOC control efficiency of 99.99 percent associated with the thermal oxidizer and 4- stage scrubber system(ID No.NCD-QI and NCD-Q2). iii. Calculate the VOC emissions from the process during the previous consecutive 12-month period(in tons/12- months)by summing the quantity of VOC released for the previous twelve(12)calendarmonths. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are not created and retained,or if the 12-month rolling VOC emission rate calculated above exceeds the limit in Section 2.1 Bi37.a____Y Formatted:Highlight of this permit. d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request.The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the records are not maintained in a logbook on-site and are not available upon request. Permit No.n'''2o� 19 03735T49 Page 24 Reuorting[15A NCAC 02Q.0508(f)] e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in Section 2.1 B 8,7.c and B�87 above,Qostmarked on or before January 30 of each calendaryear for the preceding_____--- Formatted:Highlight six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: Formatted:Highlight i. The monthly VOC emissions from the affected facility for the previous 17 calendar months; ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and, iii. All instances of noncompliance from the requirements of this permit must be clearly identified. r3:8_15A NCAC 02D.0530(u):USE OF PROJECTED ACTUAL EMISSIONS TO AVOID APPLICABILITY OF REQUIREMENTS OF PSD a. The Permittee has used projected actual emissions to avoid applicability of prevention of significant deterioration requirements pursuant to application 0900009.16A for the Spray Coating Throughput Increase Project,consisting of an expansion in the capacity of the spray coating process within the IXM Membrane Coating Process(ID No.NS-I). In order to verify the assumptions used in the projected actual emissions calculations,the Permittee shall comply with the requirements in Section 2.1 1398.b,below. ____________________—_- Formatted:Highlight Monitoring/Recordkeeain2/Reportin2[15A NCAC 02D.0530(u)and 02Q.0308] b. The Permittee shall perform the following: i. Upon commencement of regular operation of the modified unit,the Permittee shall maintain records ofannual VOC emissions from the IXM Membrane Coating Process(ID No.NS-I)in tons per year,on a calendar year basis related to the Spray Coating Throughput Increase Project.The Permittee shall calculate these annual emissions for 10 years following startup of regular operations of the modified unit. ii. The Permittee shall submit a report to the director within 60 days after the end of each calendar year during which these records must be generated.The report shall contain the items listed in 40 CFR 51.166(r)(6)(v)(a) through(c). iii. The Permittee shall make the information documented and maintained under this condition available tothe Director or the general public pursuant to the requirements in 40 CFR 70.4(b)(3)(viii). iv. The Permittee shall provide a comparison of the reported actual emissions(post-construction emissions)for each of the ten calendar years to the projected actual emissions(pre-construction projection)as includedbelow: Projected Actual Emissions* Pollutant tons per ear VOC 67.27 *These projections are not enforceable limitations.If projected emissions are e,a ded, consistent with 15A NCAC 02D.0530,the Permittee shall include,in its annual report,an explanation as to why the actual rates exceeded the projection. 44)9. 15A NCAC 02D.1111:MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(MACT), 40 CFR 63,Subpart FFFF:NESHAP for Miscellaneous Organic Chemical Manufacturing(MON) a. For each miscellaneous organic chemical manufacturing process unit,MCPU,(ID Nos.NS-A,NS-B,NS-B-2,NS- C,NS-C-2,NS-G-1,and NS-G-2),the Permittee shall comply with all applicable provisions,including the notification,testing,recordkeeping,and monjtoring requirements contained in Environmental Management Commission Standard 15A NCAC 02D.I 111,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,Subpart FFFF,including Subpart A,"General Provisions". Operating Standards[15A NCAC 02Q.0508(f)] b. Opening a safety device,as defined in 40 CFR 63.2550,is allowed at any time conditions require it to avoidunsafe conditions.[40 CFR 63.2450(p)] Eauiament Identification&Special Desiviiati ns[40 CFR 63.2480(a),40 CFR 63.1022] c. The Permittee shall identify each pump,compressor,agitator,pressure relief device,sampling connection system, open-ended valve or line,valve,connector,and instrumentation system in organic HAP service within each MCPU (ID Nos.NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS-G-1,and NS-G-2).Identification of the equipment does not require physical tagging of the equipment.For example,the equipment may be identified on a plant site plan,in log entries,by designation of process unit or affected facility boundaries by some form of weatherproof identification, or by other appropriate methods. Permit No.n"'�T^4 03735T49 Page25 i. The following additional equipment identification requirements also apply: (A)Connectors need not be individually identified if all affected connectors in a designated area or lengthof pipe are identified as a group,and the number of connectors subject is indicated. (B) Identify pressure relief devices equipped with upstream rupture disks,as described in Section 2.1 BaO ,below;--and ------ ------ -- ---- - ---------- ----- — - Formatted:Highlight (C) The identity,either by list,location(area or group),or other method,of equipment in organic HAP service less than 300 hours per calendar year. ii. The Permittee shall identify unsafe-to-monitor valves,pumps,connectors or agitators.Unsafe-to-monitor valves,pumps,connectors or agitators are equipment for which the Permittee has determined that monitoring personnel would be exposed to an immediate danger as a consequence of complying with the monitoring requirements for valves,pumps,connectors or agitators in this section.The Permittee shall provide an explanation why the equipment is unsafe-to-monitor and record the planned schedule for monitoring this equipment. iii. The Permittee shall identify difficult-to-monitor valves or agitators.Difficult-to-monitor valves or agitators are those that cannot be monitored without elevating the monitoring personnel more than 7 feet above a support surface or is not accessible in a safe manner when it is in organic HAP service.The Permittee shall provide an explanation why the equipment is difficult-to-monitor,and record the planned schedule for monitoring this equipment. iv. The Petmittee shall identify unsafe-to-repair connectors.Unsafe-to-repair connectors are those that cannot be repaired if the Pemuttee determines that repair personnel would be exposed to an immediate danger as a consequence of complying with the repair requirements in Section 2.1 13_489.bb through B+89.cc,below,and _--_ _- Formatted:Highlight if the connector will be repaired before the end of the next process MCPU shutdown.The Permittee shall keep a record ofthe explanation why the connector is unsafe-to-repair. Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if affected equipment is not identified as required above. d. If the Permittee designates equipment as imsafe-to-monitor or difficult to monitor,the Permittee shall create written plans as specified below.The Permittee shall retain the written plans on-site,and make them available to DAQ for review upon request.[40 CFR 63.1022(c)(4)] i. Unsafe-to-monitor.The Permittee shall create and implement a written plan that requires monitoring of the equipment as frequently as practical during safe-to-monitor times,but not more frequently than the periodic monitoring schedule otherwise applicable,and repair procedures that are consistent with the requirements of this permit. ii. Difficult-to-monitor.The Permittee shall create and implement a written plan that requires monitoring of the equipment at least once per calendar year and repair procedures that are consistent with the requirements of this permit. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the required plans are not created, implemented,and retained. Equipment Leak Standards&Inspections[40 CFR 63.2480(a),40 CFR 63,Subpart UU] Standards for Valves in Light Liquid.Gas and Vapor Service[40 CFR 63.1025] e. The instrument reading that defines a leaking valve is 500 ppm or greater. f. Instrument inspection.The Permittee shall monitor valves in each MCPU(ID Nos.NS-A,NS-B,NS-B-2,NS-C, NS-C-2,NS-G-1,and NS-G2)for leaks using the instrument monitoring methods described in 40 CFR63.1023(b) and(c)at the frequency specified below: i. If at least the greater of 2 valves or 2%of the valves in a process unit leak,as calculated according to Section 2.1 B.1 O.g,below,the Pemtittee shall monitor each valve once per month. E At each MCPU with less than the greater of 2 leaking valves or 2 percent leaking valves,monitor eachvalve once each calendar quarter,except as provided in iii.,iv.,or,v.below. iii. At each MCPU with less than 1 percent leaking valves,the Permittee may elect to monitor each valve once every two quarters. iv. At each MCPU with less than 0.5 percent leaking valves,the Permittee mayelect to monitor each valve once every four quarters. v. At each MCPU with less than 0.25 percent leaking valves,the Permittee may elect to monitor each valveonce every 2 years. Permit No.01�5-.-T^Q 03735T49 Page 26 The Permittee may choose to subdivide the valves in the MCPUs or groups of process units and apply theprovisions above to each subgroup.If the Permittee elects to subdivide the valves,it shall comply with the provisions of 40 CFR 63.1025(b)(4).The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not meet the instrument inspection requirements listed above. g. The percentage of leaking valves,used to determine the required monitoring frequency in Section 2.1 By 9.f, _.- Formatted:Highlight above,shall be calculated according to the procedures in 40 CFR 63.1025(c).The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the percentage of leaking valves is not calculated as required.[40 CFR 63.1025(c)] h. The Permittee shall create and retain a record of the monitoring schedule for each process unit.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not keep this record.(40 CFR 63.1025(b)(3)(vi), 40 CFR 63.1038(c)(1)(i)] i. If a leak is identified: i. It shall be repaired as provided in the repair provisions of Section 2.1 B;&9.bb through B,489.cc.___________—_- Formatted:Highlight ii. After a leak has been repaired,the valve shall be monitored at least once within the first 3 months after its '- repair.This requirement is in addition to the monitoring required to satisfy the definition of repaired and first Formatted:Highlight attempt at repair.The required periodic monitoring in Section 2.1 B;89.f,above,maybe used if it satisfies the_______ Formatted:Highlight timing requirement of this condition.If a leak is detected by this follow-up monitoring,follow the provisionsbelow to determine whether that valve must be counted as a leaking valve: (A)If the periodic monitoring was used to satisfy the follow-up monitoring requirement,then the valve shallbe counted as a leaking valve- (B) If other monitoring is used satisfy the follow-up monitoring requirements,then the valve shall be counted as a leaking valve unless it is repaired and shown by periodic monitoring not to be leaking. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I 111 if it does not meet the requirements listed above. j. Unsafe-to-monitor valves.Any valve that is designated unsafe-to-monitor according to Section 2.1 13_-99.c,above, --- == Formatted:Highlight ,89 is exempt from the monitoring and repair requirements specified in Section 2.1 13 .f B_and y 99.i,above,and_the_ Permittee shall monitor the valve according to the written plan in Section 2.1 B,189.d The Permittee_shall-be Formatted:Highlight deemed in noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements. Formatted:Highlight k. Difficult-to-monitor valves.Any valve that is designated as difficult-to-monitor according to Section 2.1 13,199.c, Formatted:Highlight above,is exempt from the monitoring requirements of Section 2.1 B,b09.f and B�09.i,above_and the Permittee_ Formatted:Highlight shall monitor the valve according to the written plan in Section 2.1 BJ1b9.d.The Per_m_ittee shall be deemed[in- noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements. \ Formatted:Highlight Formatted:Highlight Standards for Pumps in Light Liquid Service[40 CFR 63.1026] Formatted Highlight 1. The instrument reading that defines a leaking pump is 1,000 ppm or greater.Repair is not required unless an instrument reading of 2,000 ppm or greater is detected.[40 CFR 63.1026(b)(2)(iii)and(b)(3)J m. Visual inspection.Each pump within the MCPUs(ID Nos.NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS-G-1,and NS- G-2)shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal.The visual inspection shall be consistent with the methods described in 40 CFR 63.1023(d).The Permince shall document that the inspection was conducted and the date of the inspection.If there are indications of liquids dripping from the pump seal at the time of the weekly inspection,follow either of the following procedures: i. Conduct instrument monitoring of the pump using the methods described in 40 CFR 63.1023(b)and(c).Ifthe instrument reading is 1,000 ppm or greater,a leak is indicated and the Permittee shall repair the leak as provided in Section 2.1 B,99.bb through B 409.cc,below_,unless the readingis less than 2 00_Oppm;or _______ - Formatted:Highlight ii. Eliminate the visual indications of liquids dripping. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not monitor and repair Formatted:Highlight pumps as listed above.[40 CFR 63.1026(b)(4),40 CFR 63.1038(c)(2)(i)] n. Instrument inspection.The Permittee shall monitor affected pumps once per calendar month usingthe instrument monitoring methods described in 40 CFR 63.1023(b)and(c).Leaks shall be repaired as provided in Section 2.1 Permit No.037o T-4 Q 03735T49 Page 27 B_I-99.bb. through B- 9.cc, below. The Permittee shall calculate the percent leakin�_pumps usingzthe_ _ _ - Formatted Highlight ------ -- ---------------------- -- t- procedures specified in 40 CFR 63.1026(c). i. If,when calculated on a 6-month rolling average,at least the greater of either 10 percent ofthe pumps in a Formatted:Highlight MCPU or three pumps in a MCPU leak,the Permittee shall implement a quality improvement programfor pumps that meets the requirements in 40 CFR 63.1035. ii. The number of pumps at a MCPU shall be the sum ofall the pumps in organic HAP service,except that pumps found leaking in a continuous process unit within one month after startup of the pump shall not count in the percent leaking pumps calculation for that one monitoring period only. iii. The Permittee shall comply with the quality improvement plan until the number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps,calculated on a 6-month rolling average. [40 CFR 63.1026(b)(1),(c)and(d)) The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not monitor and repair pumps as required above. o. Unsafe-to-monitor pumps.Any pump that is designated as unsafe-to-monitor according to Section 2.1 B499.c, - - Formatted:Highlight B above,is exempt from the inspection requirements provided in Section 2.1 _-89_m and B jr 9.n,above,and the Permittee shall monitor and inspect the pump in accordance with the written plan in Section 2.1 B;}_99.d. The Formatted:Highlight Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements.[40 Formatted:Highlight CFR 63.1026(e)(6)J Formatted:Highlight Standards for Connectors in Gas and Vai3or and Light Liquid Service(40 CFR 63.2480(b)(4),63.1029] p. The Permittee shall comply with the requirements of 40 CFR 63.1027 for connectors in gas/vapor and light liquid service.The Pertnittee may elect to comply with the requirements in Section 2.1 BJ-99.q through LB w199.t,below,_____ - Formatted:Highlight for connectors in heavy liquid service.[40 CFR 63.2480(b)(4)] Formatted:Highlight q. The Permittee shall monitor connectors in each MCPU(11D Nos.NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS-G-1, and NS-G-2)within 5 calendar days for leaks using the instrument monitoring methods described in 40 CFR 63.1023(b)and(c),as applicable,if evidence of a potential leak to the atmosphere is found by visual,audible, olfactory,or any other detection method,unless the potential leak is repaired according to Section 2.1 B;109.s, Formatted Highlight below.[40 CFR 63.1029(b)(1)J The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1 I I I if it does not monitor the connectors as required above. r. If an instrument reading of 500 parts per million or greater is measured as required in Section 2.1 BjT 9_q,above,a____,-- Formatted:Highlight ;_0 leak is detected.The Permittee shall repair the leak according to Section 2.1 B9.bb through B w B9.cc,below. [40 CFR 63.1029(b)(2)]The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the leak Formatted:Highlight isnot repaired as required. For matted:Highlight s. For equipment identified in Section 2.1 B;99.q,above,that is not monitored by the method specified in 40CFR _ Formatted:Highlight 63.1023(b)and(c),as applicable,a leak is considered repaired one of the following conditions is met[40 CFR 63.1029(c)]: i, the visual,audible,olfactory,or other indication of a leak to the atmosphere has been eliminated;or ii. no bubbles are observed at potential leak sites during a leak check using soap solution;or iii. the system will hold a test pressure. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if leaks are not repaired as required above. t. The following are special provisions for connectors: i. Unsafe-to-repair connectors.Any connector that is designated as unsafe-to-repair as described in Section 2.1 BJ1 9.c,above,is exempt from the rgpair requirements in Section 2.1 134&9.bb below_The Pennitt_ee_s-hall_______ - Formatted:Highlight monitor these connectors according to the written plan as specified in Section 2.1 13_99.d,above. _ ____ ii. Inaccessible,ceramic,or ceramic-lined connectors.Any connector that is inaccessible or that is ceramic-lined Formatted:Highlight (e.g.,porcelain,glass,or glass-lined)is exempt from the monitoring requirements specified in 40 CFR Formatted:Highlight 63.1023(b)and(c);from the leak repair requirements of Section 2.1 B_44 9.bb,below;from the recordkeepin� _ and reporting requirements in this section. --------- - —- Formatted:Highlight (A) An inaccessible connector is one of the following:[40 CFR 63.1027(e)] Permit No.0"�5T4T^° 03735T49 Page 28 (1) Buried; (2) Insulated in a manner that prevents access to the connector by a monitor probe; (3) Obstructed by equipment or piping that prevents access to the connector by a monitor probe; (4) Unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold that would allow accessto connectors up to 7.6 meters(25 feet)above the ground. (5) Inaccessible because it would require elevating the monitoring personnel more than 2 meters(7 feet) above a permanent support surface or would require the erection of scaffold; (6) Not able to be accessed at any time in a safe manner to perform monitoring.Unsafe access includes, but is not limited to,the use of a wheeled scissor-lift on unstable or uneven terrain,the use of a motorized man-lift basket in areas where an ignition potential exists,or access would require near proximity to hazards such as electrical lines,or would risk damage to equipment. (B) If any inaccessible,ceramic or ceramic-lined connector is observed by visual,audible,olfactory,or other means to be leaking,the visual,audible,olfactory,or other indications of a leak to the atmosphere shall be eliminated as soon as practical. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the special provisions for connectors are not followed as described above. Standards for Artitators in Gas and Vapor and Light Liquid Service 140 CFR 63.1028 u. The instrument reading that defines a leaking agitator is 10,000 ppm or greater. v. The Permittee shall conduct visual and instrument inspections as provided below[40 CFR 63.1028, 10CFR 63.1038(c)(4)(i)]: i. visual inspection.Each agitator within each MCPU(ID Nos.NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS-G-I, and NS-G-2)shall be checked by visual inspection each calendar week for indications of liquids dripping from the agitator seal.The Permittee shall document that the inspection was conducted and the date of the inspection.If are indications of liquids dripping from the agitator seal at the time of the weekly inspection,the Permittee shall follow one ofthe following procedures:[40 CFR 63.1028(c)(3)J (A)The Permittee shall conduct instrument monitoring of the agitator seal using the methods described in40 CFR 63.1023(b)and(c).If the instrument reading indicates a leak(i.e.,the reading is 10,000 ppm or greater),it shall be repaired as provided in the repair provisions of Section 2.1 13 09_bb thmU h__ ____- Form High B;09.cc,below,or -----------------------------------------------------------'•Formatted:Highlight (B) The Permittec shall eliminate the visual indications of liquids dripping. (C) The Permittee shall document each visual agitator inspection. ii. Instrument inspection.The Permittee shall monitor each affected agitator within each MCPU(ID Nos.NS-A, NS-B,NS-B-2,NS-C,NS-C-2,NS-G-1,and NS-G-2)once per calendar month using the instrument monitoring methods described in 40 CFR 63.1023(b)and(c).Leaks shall be repaired as provided in the repair provisions of Section 2.1 B_09.bb through B�&9.cc,below.____-___------_ __ - Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not monitor and repair agitators as required above. I Formatted:Highlight w. Special provisions for agitators.If the Permittee designates agitator seals as either unsafe-to-monitor ordifficult-to- monitor,the permittee shall comply with the following: i. Unsafe-to-monitor agitator seals.Any agitator seal that is designated as unsafe-to-monitor according to Section 2.1 13,409.c,above,is exempt from the monitoring and rep air requirements in Section 2.1 By409.v,above.The ____ _- Formatted:Highlight Permittee shall monitor the unsafe-to-monitor agitator according to the written plan,as required in Section 2.1 B.- 9_d,above._ a- Formatted:Highlight ii. Diicult-to-monitor agitator seals.Any agitator seal that is designated as difficult-to-monitor according to -' Formatted:Highlight Section 2.1 B_99.c,above,is exempt from the monitoring requirements of Section 2 1 B�109.v,above,and----___- the Permittee shall monitor the agitator seal according to the written plan as required in Section 2.1 B,89.d, Formatted:Highlight above. Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not meet these requirements Formatted:Highlight Standards for Pressure Relief Valves[40 CFR 63.10301 x. The instrument reading that defines a leaking pressure relief valve is 500 ppm or greater.This standard does not apply during pressure releases as provided in Section 2.1 B.,IK.y,below.After each pressure release,the pressnre_ ______ Formatted:Highlight relief device shall be retuned to a condition indicated by an instrument reading ofless than 500 parts per million,as soon as practical,but no later than 5 calendar days after each pressure release. Permit No.0375TA 8 03735T49 Page 29 y. Instrument inspection.The pressure relief device shall be monitored as follows: i. The Permittee shall monitor no later than five calendar days after each pressure release to confirm thecondition indicated by an instrument reading of less than 500 parts per million above background using the instrument monitoring methods described in 40 CFR 63.1023(b)and(c). ii. Record the dates and results ofthe monitoring following a pressure release including the background level measured and the maximum instrument reading measured. iii. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is exempt from the requirements of Section 2.1 B;09.x and B�89.y,provided the Permittee in a replacement_______ _ Formatted Highlight rupture disk upstream of the pressure relief device as soon as practical after each pressure release but no later than 5 calendar days after each pressure release,except as allowed under the delay of repair provisions in Formatted:Highlight Section 2.1B_489.cc,below________________________________ __ Formatted:Highlight The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not monitor and maintain pressure relief valves as required above.(40 CFR 63.1038(c)(5)] Equipment Leak Identification[40 CFR 63.2480(a)] z. When a leak is detected using either sensory or instrument monitoring methods,a weatherproof and readily visible identification shall be attached to the leaking equipment.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if each detected leak is not identified as provided above.[40 CFR 63.1023(e)(1)] aa.Leak identifications that are placed on leaking equipment may be removed as follows[40 CFR 63.1024(c)]: i. Leak identification on a valve in gas/vapor or light liquid service may be removed after it has been re-monitored as required in Section C i 9.i,above and no leak has been detected during that_m_onitoring____ _—_ Formatted Highlight ii. Leak identification on pumps,agitators,connectors(complying with Section 2.1 B, 9.g=above and ____ _ pressure relief valves may be removed after it is repaired. — Formatted:Highight Equipment Leak Repair[40 CFR 63.2480(a),40 CFR 63,SubpartUU] bb.The Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days after it is detected,except where"Delay of Repair"or"Unsafe to Repair"provisions apply.A first attempt at repair shall be made no later than 5 calendar days after the leak is detected.[40 CFR 63.1024] i. First attempt at repair for pumps includes,but is not limited to,tightening the packing gland nuts and/or ensuring that the seal flush is operating at design pressure and temperature. ii. First attempt at repair for valves includes,but is not limited to,tightening the bonnet bolts,and/or replacing the bonnet bolts,and/or tightening the packing gland nuts,and/or injecting lubricant into the lubricatedpacking. cc.Delay of repair.Delay of repair is allowed for any of the conditions listed below.The Permittee shall maintain a record of the facts that explain any delay of repairs and,where appropriate,why the repair was technically infeasible without a process unit shutdown. i. Delay of repair is allowed if repair within 15 days after a leak is detected is technically infeasible without a process unit or affected facility shutdown.Repair of this equipment shall occur as soon as practical,but no later than the end of the next process unit or affected facility shutdown,except as provided in Section 2.1 B,l99.c_c.v, Formatted Highlight below. ii. Delay of repair is allowed for equipment that is isolated from the process and that does not remain in regulated material service. iii. Delay of repair for valves,connectors,and agitators is also allowed where: (A)The Permittee determines that emissions of purged material resulting from immediate repair wouldbe greater than the fugitive emissions likely to result from delay of repair,and (B) When repair procedures are affected,the purged material is collected and destroyed,collected and routedto a fuel gas system or process,or recovered in a control device. iv. Delay of repair for pumps is also allowed where: (A)Repair requires replacing the existing seal design with a new system that the Permittee has determined through a Quality Improvement Plan will provide better performance or one of the following: (1) A dual mechanical seal system will be installed; (2) A pump that meets the requirements of 40 CFR 63.1026(e)(2)will be installed;or (3) A system that routes emissions to a process or a fuel gas system or a closed vent system and control device will be installed;and Pemrit No.93�z�T,i 8 03735T49 Page 30 (B) Repair is completed as soon as practical,but not later than 6 months after the leak was detected. v. Delay of repair beyond a process unit or affected facility shutdown will be allowed for a valve if valve assembly replacement is necessary during the process unit or affected facility shutdown,and valve assembly supplies have been depleted,and valve assembly supplies bad been sufficiently stocked before the supplies were depleted.Delay of repair beyond the second process unit or affected facility shutdown will not be allowed unless the third process unit or affected facility shutdown occurs sooner than 6 months after the first process unit or affected facility shutdown. Equipment Leak Recordkeeoine[40 CFR 63.2480(a),40 CFR 63,Subpart UU] dd.For each leak detected,the following information shall be recorded and maintained: i. The date of first attempt to repair the leak. ii. The date of successful repair of the leak. iii. Maximum instrument reading measured by Method 21 of 40 CFR Part 60,Appendix A at the time the leakis successfully repaired or determined to be non-repairable. iv. 'Repair delayed"and the reason for the delay if a leak is not repaired within 15 calendar days after discoveryof the leak as specified below: (A)The Permittee may develop a written procedure that identifies the conditions that justify a delay of repair. In such cases,reasons for delay of repair may be documented by citing the relevant sections ofthe written procedure. (B) If delay of repair was caused by depletion of stocked parts,there must be documentation that the spareparts were sufficiently stocked on-site before depletion and the reason for depletion. v. Dates of process unit or affected facility shutdowns that occur while the equipment is unrepaired. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I11 if the records listed above are not created and retained.[40 CFR 63.1023(e)(2), 40 CFR 63.10240,40 CFR 63.1038(b)] ee.The Permittee shall create and retain the following general records: i. General and specific equipment identification if the equipment is not physically tagged and the Permittee is electing to identify the affected equipment through written documentation such as a log or other designation; ii. Written plans for any equipment that is designated as unsafe-or difficult-to-monitor,and, iii. A record of the identity and justification of any equipment that is designated as unsafe-to-repair. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if the records listed above are not created and retained.[40 CFR 63.1038(b)] Heat Exchanger Requirements[15A NCAC 02Q.0508(f)] ff.The Permittee shall prepare and implement a monitoring plan that documents the procedures that will be used to detect leaks of process fluids into cooling water. i. The plan shall require monitoring of one or more surrogate indicators(e.g.,pH,conductivity,etc.)or monitoring of one or more process parameters or other conditions that indicate a leak.The plan shall include the following: (A)A description of the parameter or condition to be monitored and an explanation of haw theselected parameter or condition will reliably indicate the presence of a leak; (B) The parameter level(s)or conditions(s)that shall constitute a leak.This shall be documented by data or calculations showing that the selected levels or conditions will reliably identify leaks.The monitoring must be sufficiently sensitive to determine the range of parameter levels or conditions when the system is not leaking.When the selected parameter level or condition is outside that range,a leak is indicated; (C) The monitoring frequency which shall be no less frequent than monthly for the first 6 months and quarterly thereafter to detect leaks; (D)The records that will be maintained to document compliance with the requirements of the monitoring plan. ii. If a substantial leak is identified by methods other than those described in the monitoring plan and the method(s)specified in the plan could not detect the leak,the Permittee shall revise the plan and document the basis for the changes no later than 180 days after discovery of the leak. iii. The Permittee shall maintain a copy of the current monitoring plan on-site or other means that provides access within two hours after a request.If the monitoring plan is superseded,the Permittee shall retain the most recent superseded plan at least until 5 years from the date of its creation.The Permittee shall retain the supersededplan on-site(or accessible from a central location by-computer or other means that provides access within two hours after a request)for at least 6 months after its creation. Permit No.0373�rn 8 03735T49 Page 31 The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not meet the above requirements.[40 CFR 63.2490,40 CFR 63.104(c)] gg.Except as allowed by the delay of repair requirements in Section 2.1 B;89.hh,below,if a leak is detected in any_____ _ Formatted Highlight heat exchanger system,the Permittee shall be repair the leak as soon as practical but not later than 45 calendar days after the Permittee receives results of monitoring tests indicating a leak,unless the Permittee demonstrates that the results are due to a condition other than a leak.Once the leak has been repaired,the owner or operator shall confirm that the.heat exchange system has been repaired within 7 calendar days of the repair or startup,whichever is later. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if leaks are not repaired as required above.[40 CFR 63.2490,40 CFR 63.104(d)] hh.Delay of repair of heat exchange systems is allowed if the equipment is isolated from the process.Delay of repair is also allowed if repair is technically infeasible without a shutdown and any one of the conditions listed in 40 CFR 63.104(e)(1)through(e)(2)is met.(40 CFR 63.2490,40 CFR 63.104(e)]The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the delay of repair provisions are not met. ii. For each affected heat exchanger system,the Permittee shall retain the following records: i. Monitoring data indicating a leak,the date when the leak was detected,and if demonstrated notto be a leak,the basis for that determination; ii. Records of any leaks detected by procedures other than those provided in the written plan according to Section 2.1 B;99.ff,above,including the date the leak was discovered_ _ _ ___- Formatted:Highlight iii. The dates of efforts to repair leaks;and, iv. The method or procedure used to confirm repair of a leak and the date repair was confirmed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the records listed above are not retained.[40 CFR 63.2490,40 CFR 63.10469] Additional Recordkeenina[15A NCAC 02Q.0508(f)] J.The Permittee shall create and retain the following records on each affected MCPU:[40 CFR 63.2525(b)] i. A description of the process and the type of process equipment used; ii. An identification of related process vents(including associated emissions episodes),wastewater points of determination(PODs),and storage tanks; iii. The applicable control requirements pursuant to 40 CFR 63,Subpart FFFF,including the level ofrequired control,and for vents,the level of control for each vent; iv. The control device or treatment process used,as applicable,including a description of operating and/ortesting conditions for any associated control device; v. The process vents,wastewater POD,and storage tanks(including those from other processes)thatare simultaneously routed to the control device or treatment process; vi. The applicable monitoring requirements ofthis subpart and any parametric level that assures compliance for all emissions routed to the control device or treatment process;and, vii. Calculations and engineering analyses required to demonstrate compliance. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the above records are not retained. kk.Create and retain a record of each time a safety device is opened to avoid unsafe conditions.[40 CFR 63.252569] The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if this record is not retained. 11.For each affected Group 2 wastewater stream,the Permittee shall retain the following records:[Table 7 of 40 CFR Part 63,Subpart F and 40 CFR 63.147(b)(8)J i. MCPU identification and description; ii. Stream identification code; iii. Concentration of compounds listed in Table 8 and Table 9 of40 CFR 63,Subpart FFFF(in ppmw),including documentation of the methodology used to determine concentration;and, iv. Stream flow rate(in L/min). The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the records listed above are not retained.[40 CFR 63.2585(a),40 CFR 63.147(b)(8)] Permit No.na7z�Trna 03735T49 Page 32 Process Changes[15A NCAC 02Q.0508(f)] turn.If a Group 2 emission point becomes a Group 1 emission point,the Permittee must be in compliance with the Group 1 requirements beginning on the date the switch occurs.An initial compliance demonstration as specified in 40 CFR Part 63,Subpart FFFF must be conducted within 150 days after the switch occurs.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not meet these requirements.[40 CFR 63.2445(d)] Reporting[15A NCAC 02Q.0508(f)] nn.The Permittee shall submit a semi-annual compliance report of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following:[40 CFR 63.2520(a),(b)and(e)J i. Company name and address; ii. Statement by a responsible official with that official's name,title,and signature,certifying the accuracy ofthe content of the report; iii. Date of report and beginning and ending dates of the reporting period; iv. If there are no periods of noncompliance from any emission limit,operating limit or work practice standard specified in Section 2.1 13,�89,include a statement that there were ngperiods of noncompliance from the_________— Formatted:Highlight emission limits,operating limits,or work practice standards during the reporting period; v. For each period of noncompliance from an emission limit,operating limit,and work practice standard,include the following information: (A)The total operating time of the affected source during the reporting period;and, (B) Information on the number,duration,and cause of noncompliance(including unknown cause,if applicable),as applicable,and the corrective action taken. vi. Identify each new operating scenario which has been operated since the time period covered by the last compliance report and has not been submitted in the previous compliance report.For each new operating scenario,the Permittee shall provide verification that the operating conditions for any associated control or treatment device have not been exceeded and that any required calculations and engineering analyses have been performed.A revised operating scenario for an existing process is considered to be a new operating scenario; viL For the equipment listed below,report in a summary format by equipment type,the number of components for which leaks were detected and for valves,pumps and connectors show the percent leakers,and the totalnumber of components monitored.Also include the number of leaking components that were not repaired as required according to Section 2.1 13 B9.bb through B 499. c,above and for valves and connectors,identify the number Formatted:Highlight of components that are determined to be non-repairable as described in 40 CFR 63.1025(c)(3). (A) Valves in gas and vapor service and in light liquid service; Formatted:Highlight (B) Pumps in light liquid service; (C) Connectors in gas and vapor service and in light liquid service;and, (D)Agitators in gas and vapor service and in light liquid service. viii.Where any delay of repair for leaks is utilized,report that delay of repair has occurred and report the number of instances of delay of repair under Section 2.1 13_A9.cc,above.__ __________________——• Formatted:Highlight ix. For pressure relief devices,report the results of all leak monitoring to show compliance conducted within the semiannual reporting period. x. Report,if applicable,the initiation of a monthly leak monitoring program for valves and pumps. xi. For each affected heat exchanger system for which the Permittee invokes the delayof repair,include the following information:[40 CFR 63.2490 and 68.10469(2)] (A)the presence of the leak and the date that the leak was detected (B) whether or not the leak has been repaired (C) the reason(s)for delay of repair and any supporting emission estimates. (D)If the leak is repaired,the owner or operator shall report the date the leak was successfully repaired. (E) If the leak remains unrepaired,the expected date of repair. Permit No.""'5T^Q 03735T49 Page 33 c noco NG S torn State Onit Requirement 4-.10. 15A NCAC 02Q.0519(a)(7)and CONSENT ORDER a. To carry out the purposes of N.C.G.S.§143 Article 2113 and to ensure that air emissions do not contribute to groundwater violations,and pursuant to the Consent Order?the Permittee shall reduce emissions of all PFAS, including GenX Compounds,from the following sources:HFPO Process,Vinyl Ethers North Process,Vinyl Ethers South Process,RSU Process,FPS Liquid Waste Stabilization Process,MMF Process,E-2 Process,TFElCQ2 Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process, and VES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-D-I,NS-E,NS-F,NS-G-I, NS-K NS-M,NS-N,NS-O,and NS-P)as follows: i >l..later than Deceiubef-'1 �m n «The Permittee shall""tall.,..a beDg...a ffl...1,...,..,.«,...,.a,, operate a Thermal Oxidizer in series with a 4-Stage Scrubber System(ID Nos.NCD-QI and NCD-Q2). I The Thermal Oxidizer and 4-Stage Scrubber System shall reduce emissions of all PFAS,including GenX Compounds,by at least 99.99 percent. Testine II IA NCAC 02Q.1111(a)] b. The AmRittee sl+all conduct an mitial lieFfafmasee test efthe Thamial Q�ddi;-�andA Stage Sefulsber System W Nos NC-D Q!and NCD Q2 When conductinu >enodic ierfonnance tests..Tthe Permittee shall test for all PFAS emissions,including GenX Compounds,atthe inlet of the Thermal Oxidizer and the outlet of the 4-Stage Scrubber: T6.Peamit4ee skal l install sampling paFts compliance with 1 c A NC,P nor, ,<nn Emissions testing shall be performed in accordance with General Condition JJ and in accordance with a testing protocol approved by DAQ. The Permittee shall submit the testing protocol for approval at least 45 days prior to conducting the performance test.The testing protocol shall address how the Permittee will ensure that the Thermal Oxidizer and 4-Stage Scrubber System will achieve the emission reduction specified in Section 2.1 B,1!+.a,above,including the use of a___ _- Formatted:Highlight surrogate for all PFAS,such as hexafluoropropylene oxide(HFPO).Two copies of the final air emission test report shall be submitted to the Director not later than 45 days after each performance test. d-t_A R.-_the initial..,._&_..,...._._test is,.,,...,Hetea t,. The Pennittee shall conduct periodic performance tests to demonstrate compliance with the emission limits in Section 2.1 B.I La,above,as follows: i. The Permittee shall conduct the periodic performance tests using the procedures specified in Section 1.1 Bi04.b•^••'a„H- -.-'1 abov_e. I The Permittee shall conduct periodic performance tests on an annual basis. A a,.. :«:the 4. ..i^.-e•-- .^«,. ____ Formatted::Highlight eeiideeted as..,ee'fi d:_c etiefi,,n,,l ,. ._ jhe Permittee shall conduct all periodic performance tests within a 13-month time period after the date of the previous performance test. iii. The Permittee shall conduct a performance test within 90 days whenever permanent changes are made in production capacity,process feedstock type,or whenever there is a replacement,removal,or addition ofan emission source or control device.Following this performance test,the Permittee shall resume annual performance testing in accordance with the schedule specified in paragraph,&.ii,above __- Formatted:Highlight iv. The permittee shall submit two copies of the final air emission test report to the Director not later than 45 days after each performance test. "_During performance tests conducted according to Section 2.1 B;0+.b,above,the Permittee shall establish or __ _ Formatted:Highlight confirm the operating parameters specified in Section 2.1 B.10+ #and B�104.h,below_If the results of any _____ performance test require changes to the operating parameters specified in Section 2.1 Bjay.>and;lr;below,to ______:.\ Formatted:Highlight demonstrate compliance with the limits in Section 2.113 1 La,above,the Permittee shall submit a permit application "+\. Formatted:Highlight for a minormodification to the permit under 15A NCAC 02Q.0515 to revise these parameters.Any previously established continuous compliance monitoring parameters shall not apply during any required subsequent \+ Formatted:Highlight performance testing. Formatted:Highlight Formatted:Highlight °"Consent Order•"means the Consent Order entered on February 25,2019,in State o£North Carolina,ex ml.,Michael S.Regan,Secretary,North Carolina Department of Environmental Quality v.The Chemows Company FC,LLC,17 CVS 580(Bladen Coanty). Permit No.037�T4 9 03735T49 Page 34 Monitoring[15A NCAC 02Q.0308(a)] €e_Emissions of all PFAS,including GenX Compounds,from the HFPO Process,VEN Process,VES Process,RSU Process,Liquid Waste Stabilization Process,MMF Process,E-2 Process,TFE/CO2 Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-D-1,NS-E,NS-F,NS-G-1,NS-K,NS-M,NS-N,Ns- O,and NS-P)shall be controlled by a Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-Ql and NCD-Q2).To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer.In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include: i. hourly visual or positive detection by flame scanner checks of the Thermal Oxidizer flame and burner whilein operation and annual inspections of the burner assemblies,blowers,fans,dampers,refractory lining,oxidizer shell,fuel lines,and ductwork; ii. annual inspection of scrubber spray nozzles to detect clogging or corrosion damage of nozzles andperform maintenance and repair when necessary to ensure proper operation of the scrubber; iii. annual inspection of scrubber packing material to ensure proper packing depth and to check for clogging;and iv. annual inspection,cleaning,and calibration of all associated instrumentation. v. In addition to annual inspections,the Permittee shall also conduct the inspections required in paragraphs i. through iv.,above,whenever the Thermal Oxidizer and 4-Stage Scrubber System are nonoperational for a minimum of 72 hours. g-f_The Permittee shall de el ap and^ bniit to D.^Q f-appFaN al,fol low a site-specific monitoring plan that addresses design,data collection,and quality assurance/quality control elements for operating each CMS installed according to Section 2.1 B;0+.4a and B J04.ih,below.The monitoring-plan shall,at a minimum,address the following:-_---_---- Formatted:Highlight i. Initial a y s�++4 Cealibrations ofthe CMS; ii. Determination and adjustment ofthe calibration drift ofthe CMS; Formatted:Highlight iii. Preventive maintenance of the CMS,including spare parts inventory; iv. Data recording,calculations,and reporting; v. Accuracy audit procedures,including sampling and analysis methods; vi. Program of corrective action for a malfunctioning CMS; vii. Ongoing operation and maintenance procedures;and viii.Ongoing data quality assurance procedures. 1re`The Permittee shall install,calibrate,maintain,and operate CMS for the Thermal Oxidizer(ID No.NCD-QI).The CMS shall include a continuous recorder capable of taking a measurement at least once every 15 minutes.The Permittee shall operate the CMS according to the approved site-specific monitoring plan specified in Section 2.1 BI04.af above,to ensure the following operational parameters are maintained._ _--- _ formatted:Highlight i. A minimum combustion chamber temperature of 1800 degrees Fahrenheit(3-hour rolling average). (A)The temperature monitor shall record continuously the operating temperature to within 1 percent(relative to degrees Celsius)or+0.50C(±0.9°17),whichever is greater. (B) The temperature monitoring device shall be installed in the firebox of the Thermal Oxidizer or in the ductwork downstream from the firebox and before any substantial heat exchange for the Thermal Oxidizer. I A maximum Thermal Oxidizer inlet gas feed rate 2,200 pounds per hour(3-hour rolling average).The monitoring device used for continuous measurement of the Thermal Oxidizer inlet gas feed rate must be certified by the manufacturer to be accurate within t5 percent of the Thermal Oxidizer inlet gas feed rate. iii. Failure to operate the temperature monitor or inlet feed gas monitoring device identified,above,for at least 97 percent of the total operational time per quarterly reporting period shall constitute noncompliance with the emission limits in Section 2.1 B.1004.a,above. _-—-- f Formatted:Highlight i-h_The Permittee shall install,calibrate,maintain,and operate CMS for the 4-Stage Scrubber System(ID No. NCD-Q2).The CMS shall include a continuous recorder capable oftaking a measurement at least once every 15 minutes.The Permittee shall operate the CMS according to the approved site-specific monitoring plan specified in Section 2.1 B,104�f,aboveto ensure the following operational parameters are maintained-------------- Formatted Highlight i. The scrubber liquor flow shall be a minimum of 40 gallons per minute for the fourth caustic scrubber stage.The monitoring device used for continuous measurement of the scrubber liquor flow rate must be certified by the manufacturer to be accurate within t5 percent of the scrubber liquid flow rate. ii. A minimum scrubber liquor pH,no less than 7.1(3-hour rolling average)for the fourth scrubber stage. Permit No.nz�z�T4 8 03735T49 Page 35 iii. Failure to operate the scrubber liquor flow meter or pH meter,identified in i.and ii.,above,for at least 97 percent of the total operational time per quarterly reporting period shall constitute noncompliance withthe emission limits in Section 2.1 B IQk.a,above. __ _____________ _________--- Formatted:Highlight Shutdown and Malfunction[15A NCAC 02Q.0308(a)] ti_Except as specified in Section 2.1 B0€.1<jzbelow,the Permittee shall operate the Thermal Oxidizer and 4Stage Formatted Highlight Scrubber System(ID Nos.NCD-QI and NCD-Q2)at all times when the HFPO Process,VEN Process,VIES Process,RSU Process,Liquid Waste Stabilization Process,MMF Process,IXM Resins Process,E-2 Process, TFE/CO:Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VIES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-D-1,NS-E,NS-F, NS-G-I,NS-K,NS-M,NS-N,NS-O,and NS-P)are operating- The Permittee shall develop,and sub»it to-Baf}€; pPrar m'-follow the approved a e 4ailzd-shutdown and malfunction plan for the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-f l AND NCD-4)21 that contains specific procedures for initiating the shutdown of process emission sources during periods of control device shutdown and malfunction,and a program of corrective action for malfunctioning processes,and control systems used to comply with the limits in Section 2.1 B;04.a,above.The Permittee shall keep a copy of the approve_dplan ____f_ Formatted Highlight onsite. ' i. To ensure that the control devices are well maintained to minimize malfunctions,the plan shall include a maintenance schedule for the Thermal Oxidizer and 4-Stage Scrubber System that is consistent with,butnot limited to the manufacturer's instructions and recommendations for routine and long-term maintenance,as specified in Section 2.1 BjI0-F.#gand B_1OI-.4hsabove. _ __ _ ___ Formatted:Highlight I An inspection schedule for each CMS installed on the Thermal Oxidizer and 4-Stage Scrubber Systemto ensure,at least once in each 24-hour period,that each CMS is properly functioning. Formatted:Highlight iii. At no time shall the emissions from the HFPO Process,VEN Process,VES Process,RSU Process,Liquid Waste Stabilization Process,MMF Process,IXM Resins Process,E-2 Process,TFEICO2 Separation Process, HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VIES Product Container Decontamination Process(]m Nos.NSA,NS-B,NS-C,NS-D-1,NS-E,NS-F,NS-G-1,NS-K,NS- M,NS-N,NS-O,and NS-P)be allowed to vent to the atmosphere without being controlled in the Thermal Oxidizer and 4-Stage Scrubber System(B)Nos.NCD-Q1 and NCD-Q2). RecordkeeoinQlRenortine[15A NCAC 02Q.0308(a)] bk_The Permittee shall record the following information monthly in a logbook(written or electronic format)thatshall be maintained on-site and made available to DAQ,upon request.The Permittee shall keep all records on file for a minimum of five years. i. Records ofthe continuous and 3-hour rolling average operating parameters specified in Section 2.1 B 10I-_#g Formatted:Highlight and B;01_ih ,fothe abover Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-g1 and NCD-__ Q2). - -- - -- - - -- - -- Formatted:Highlight ii. If the emission sources are not operating,a record of this fact along with the corresponding date and time. iii. Records of all inspections and maintenance conducted for the Thermal Oxidizer and 4-Stage Scrubber System (ID Nos.NCD Ql and NCD-Q2),as specified in Section 2.1 Bl0€.g€a above. - - __ Formatted:Highlight iv. Records associated with the site-specific monitoring plan specified in Section 2.1 B;0-l.f&,above. ----------'-—-- Formatted:Highlight sn L The Permittee shall retain all results of performance testing conducted in accordance with Section 2.1 Bj104_b em attd ---—__ Formatted:Highlight s,above,including development of the operating parameters,as specified in Section 2.1 Bjq.hzn and_ BJI01-.tlr,above,and the calculation ofthe Thermal Oxidizer and 4-Stage Scrubber System(D)Nos_NCD-Ql and_____ Formatted:Highlight NCD-Q2)control efficiency with respect to the controofl all PFAS,including GenX Compounds,emissions from - Formatted:Highlight the HFPO Process,VEN Process,VES Process,RSU Process,Liquid Waste Stabilization Process,MMF Process, IXM Resins Process,E-2 Process,TFE/CO2 Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VES Product Container Decontamination Process(ID Nos. NS-A,NS-% NSC,NS13-1,NSE,NS-F,NSG-1,NSK,NSM,NS-N,NS-O,and NSP). n-m_The Pemtittee shall submit a quarterly summary report,acceptable to the Regional Air Quality Supervisor,of monitoring and recordkeeping activities specified in Section 2.1 13_6}.€e through B 10}.rn_n,above,_postm_ar_ke_d_ ___ - Formatted:Highlight on or before January 30 of each calendar year for the preceding three-month period between October and December;April 30 of each calendar year for the preceding three-month period between January and March;July Formatted:Highlight 30 of each calendar year for the preceding three-month period between April and June;and October 30 of each calendaryear for the preceding three-month period between July and September.All instances of deviations from the requirements of this permit must be clearly identified. Permit No.n"2�T"Q 03735T49 Page 36 C. Polymer Processing Aid Process(ID No.AS-A)controlled by a wet scrubber(ID No.ACD-Al)in series with a Carbon Adsorber(ID No.ACD-A2) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Odors State-enforceable only 15A NCAC 02D.1806 See Section 2.2 B.5 Toxic Air Pollutants State-enforceable only 15A NCAC 02D.1100 Toxic air pollutant limits shall not be exceeded.See Sections 2.2 B.1 and 2.2 B.2 GenX Compounds' State-enforceable only 15A NCAC 02Q.0519 and See Section 2.2 D Consent Order STATE-ENFORCEABLE ONLY 1. 1SA NCAC 02D.1100:CONTROL OF TOXIC AIR POLLUTANTS a. Gaseous and mist emissions from the Polymer Processing Aid process area(ID No.AS-A)shall be controlled by a wet scrubber(ID No.ACD-Al).The Permittee shall ensure the proper performance of the scrubber by monitoring the following operational parameters: i. Liquid flow rate through the packed bed section(minimum of 30 gallons per minute averaged over a 3-hour period),and ii. Differential pressure across the packed bed section of the scrubber(maximum of12 inches of water pressure averaged over a 3-hour period),with a high differential pressure alarm. Recordkeeoine b. The Permittee shall record the results of inspections in a scrubber log(written or electronic records),which shall be kept on site and made available to Division of Air Quality personnel upon request.Any variance from the manufacturer's recommendations or the permit monitoring requirements,or the failure of the air pollution control equipment to operate in a normal and usual manner,shall be investigated with corrections made and dates of action recorded in the log book.The inspection and maintenance activities,as well as required monitoring for scrubbing liquid flow rates,and scrubber pressure drops,if appropriate,shall be recorded. s"Gea.X Compounds"means HFPO Diner Acid,also known as C3 Dimer Acid(CAS No.13252-13-6);HFPO Dimer Acid Fluoride,also(mown as C3 Direct Acid Fluoride(CAS No.2062-98-8);and HFPO Din ter Acid Ammonium Salt,also known as C3➢inter Acid Ammonium Salt(CAS No.620 3 7-8 0- 3). Permit No.03 73 5-T^ 03735T49 Page 37 D. Wastewater Treatment Area consisting of an extended aeration biological wastewater treatment facility (ID No.WTS-A)and two indirect steam-heated rotary sludge dryers(ID Nos.WTS-B and WTS-C) controlled by a wet scrubber with mist eliminator(ID No.WTCD-1) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Odors State-enforceable only 15A NCAC 02D.1806 Odorous emissions must be controlled STATE ENFORCEABLE ONLY 1. 15A NCAC 02D.1806:CONTROL AND PROHIBITION OF ODOROUS EMISSIONS a. The Permittee shall not operate the wastewater treatment area(ID Nos.WTS-A,WTS-B AND WTS-C)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. b. Odorous emissions from the wastewater treatment sludge dryers(ID Nos.WTS-B and WTS-C)shall be controlled by an impingement-type scrubber with caustic injection(ID No.WTCD-1). Mo nito rinrJRecordkeen int? c. To comply with the provisions of this Permit and ensure that maximum control efficiency of the scrubber(ID No. WTCD-1)is maintained,the Permittee shall perform periodic inspections and maintenance as recommended bythe scrubber manufacturer.As a minimum,the inspection and maintenance program shall include inspection of spray nozzles,packing material,chemical feed system(if so equipped),and the cleaning/calibration of all associated instrumentation. d. The Permittee shall record the results of inspections in a scrubber logbook(written or electronic format)that shallbe kept on site and made available to DAQ personnel upon request.Any variance from the manufacturer's recommendations or the permit monitoring requirements,or the failure of the air pollution control equipment to operate in a normal and usual manner,shall be investigated with corrections made and dates of actions taken recorded in the log book.The inspection and maintenance activities,as well as required monitoring for scrubbing liquid flow rates and scrubber pressure drops,if appropriate,shall be recorded. Permit No.n3?2�T1Qa 03735T49 Page 38 E. Natural gas/No.2 fuel oil-fired temporary boiler(less than 100.0 million Btu per hour maximum heat input,ID No.PS-Temp) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulations Particulate Matter 0.2426 pounds of particulate per million Btu 15A NCAC 02D.0503 Sulfur Dioxide 2.3 pounds SO2 per million Btu heat input 15A NCAC 02D.0516 Visible Emissions 20 percent opacity 15A NCAC 02D.0521(d) Sulfur Dioxide and Visible On site less than 180 days per consecutive twelve 15A NCAC 02Q.0317 Emissions month period and use of fuels emitting no more (15A NCAC 02D.0524[NSPS] than 0.06 pounds of sulfur dioxide per million Btu Avoidance) heat input. Sulfur Dioxide Less than 40 tons per consecutive 12-month period 15A NCAC 02Q.0317 (15A NCAC 02Q.0530[PSD] Avoidance) Sulfur Dioxide Boilers PS-A.PS-B.PS-C.and PS-Temp) 15A NCAC 02Q.0317 Less than 702.5 tons per consecutive 12-month (PSD Avoidance) period; See Section 2.2 A.1.of this permit. Hazardous Air Pollutants On site less than 180 days per consecutive twelve 15A NCAC 02Q.0317 month period. (15A NCAC 02D.11090111 [MACT]Avoidance) 1. 15A NCAC 02D.0503:PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter discharged into the atmosphere from the combustion of No.2 fuel oil in the temporary boiler(ID No.PS-Temp)shall not exceed 0.2426 pounds per million Btu heat input. Testing[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing she be performed in accordance General Condition JJ.If the results of this test are above the limit given in Section 2.1 E.La above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0503. Monitoring(Recordkeeping/Reporting[15A NCAC 02Q.0508(f)] c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of fuel oil in this source for this regulation. 2. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from the temporary boiler(ID No.PS-Temp)shall not exceed 2.3 pounds per trillion Btu heat input.Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining compliance with this standard. Testine[15A NCAC 02Q.0508(o] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 E.2.a above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0516. Monitoring/Recordkeeping/Recordkeeaing[15A NCAC 02Q.0508(f)] c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of natural gas or fuel oil in this source. 3. 15A NCAC 02D.0521:CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the temporary boiler(ID No.PS-Temp)shall not be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging periods may exceed 20 percent not more than Permit No.0372�_TT.!8 03735T49 Page 39 once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 87 percent opacity. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 E.3.a above,the Permittee shall be deemed in noncompliance with ISA NCAC 02D.0521. Monitoring/Recordkceoine/Reoortine[15A NCAC 02Q.0508(f)] c. No monitoring/recordkeepinglreporting is required for visible emissions from the firing of natural gas or fuel oilin this source. 4. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the temporary boiler(ID No.PS-Temp)shall discharge into the atmosphere less than 40 tons of sulfur dioxideper consecutive twelve-month period. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limits given in Section 2.1 E.4.a above,the Pemtittee shall be deemed in noncompliance with 15A NCAC 02D.0530. MonitorinQ/Recordkeeoine[15A NCAC 02Q.0508(f)] c. The Permittee shall keep monthly records of fuel usage in a log(written or in electronic format),as follows: i. The total quantity(in 1,000 gal)of fuel oil fired at the boiler;and, ii. The fuel oil supplier certification for any fuel oil fired at the boiler,including the sulfur content of the oil(in percent by weight). The Pemtittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the fuel usage and fuel oil sulfur content are not created and retained as required above. d. The Pemrittee shall calculate monthly and 12-month rolling SO,emissions from the temporary boiler within 30days after the end of each calendar month.Calculations shall be recorded in a logbook(written or electronic format), according to the following formulas: i. Calculate S02 emissions from the previous calendar month using the following equation: Eso=142�x S�x Q f 2 Where, Eso2 = SO,emissions(in lbs)during the previous calendar month, S = Sulfur content in the fuel oil(in percent by weight),and Qro, = Quantity of fuel oil fired at the temporary boiler during the previous calendar month(in 1,000 gal) ii. Sum the S02 emissions from the boiler for the previous 12-month period to determine the 12-monthrolling emission total. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in Section 2.1 E.4.a of this permit. Reoortine[15A NCAC 02Q.0508(f)] e. The Pemtittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality Supervisor,of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: i. The monthly SO,emissions from the boiler for the previous 17 months; ii. The total S02 emissions from the boiler for each 12-month period ending during the six month reportingperiod; and, iii. All instances of noncompliance from the requirements of this permit must be clearly identified. Pennit No.n"35T49T^° 03735T49 Page 40 c I5A NC-AG nin 0317: wino IS.NCE G^o^lo^:-ION 7-A n--- 11 no.r.A A Q 1 PH);!'ase by!`nse M A CT for R..:lo.•s R o.-aress venters NC An 02-D (ID No.PS Temp)sMll net Feenaimi on site fOF 1TIOfe tllafl 180 ceiiseetti-tva days.The Pefmiaee shall fetain FeeeFds owl;e-,Haber of enseoutive days the bode is alis„e. Permit No.91 ;i I°I° 03735T49 Page 41 F. Lime Silo(ID No.NS-RI)equipped with a pulse jet baghouse(ID No.NCD-RI) Lime Slaker(ID No.NS-R2)equipped with a Wet Particulate Scrubber(ID No.NCD-112) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulations Particulate matter E=4.10 x P 0•67 15A NCAC 02D.0515 where: E=allowable particulate emission rate in pounds per hour P=process weight rate in tons per hour Visible emissions 20 percent opacity 15A NCAC 02D.0521 1. 15A NCAC 02D.0515:PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions ofparticulate matter from the Lime Silo and Lime Slaker(ID Nos.NS-R1 and NS-112)shall notexceed an allowable emission rate as calculated by the following equation: E=4.10 x P°67 Where:E=allowable emission rate in pounds perhour P=process weight in tons per hour Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the results of this test are above the limit given in Section 2.1 F.l.a,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515. Monitorine/Recordkeenina[15A NCAC 02Q.0508(f)] c. Particulate matter emissions from the Lime Slaker(ID No.NS-112)shall be controlled by the Wet Particulate Scrubber(ID No.NCD-R2).The Permittee shall install,operate,and maintain a wet scrubbing liquid flowmeter on each-the scrubber.To ensure compliance and the effective operation of the scrubbers,the Permittee shall monitor and record,once per day,scrubbing liquid flow rate.The Permittee shall be allowed three(3)days of absent observations per semi-annual period.If the emission source(s)is not operating,a record of this fact along with the corresponding date and time shall substitute for the daily observation.To ensure quality,the flow rate meters shall be calibrated annually.The scrubber shall be operated to ensure the scrubbing liquid flow rate is greater than 0.84 gallons per minute.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the scrubber liquid flow rate is not maintained above the above prescribed limit or if these records are not maintained. d. If the scrubber liquid flow rate readings recorded as required,are observed to be below the minimum rate specified in Section 2.1 F.l.c,above,the Permittee shall inspect the scrubber(s)for malfunctions and clean or repair,as necessary.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the inspections, cleaning,and repairs are not performed. e. Particulate matter emissions from the Lime Silo(ID Nos.NS-RI)shall be controlled by the bagfilter(ID Nos.NSD- RI).To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer.In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks;and ii. an annual(for each 12-month period following the initial inspection)internal inspection of thebagfilter's structural integrity. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and bagfilters are not inspected and maintained. f. The results of inspection and maintenance activities in Section 2.1 F.l.c through 2.1 F.Le,above,shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative of DAQ upon request.The logbook shall record the following: i. the date and time of each recorded action Permit No.O3'"�735-TA 9 03735T49 Page 42 ii the results of each inspection; iii. the causes for any variance from the prescribed operating range for the scrubber(s);and iv. corrective actions taken. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these records are not maintained. Renortin2[15A NCAC 02Q.0508(f)] g. The Permittee shall submit the results of any maintenance performed on any control device within 30 days ofa written request by the DAQ. h. The Permittee shall submit a summary report of the monitoring and recordkeeping activities specified in Section 2.1 F.Lc through F.Lf,above,postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month periodbetween January and June.All instances of deviations from the requirements of this permit must be clearly identified. 2. 15A NCAC 02D.0521:CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the Lime Silo and Lime Slaker(ID Nos.NS-R1 and NS-R2)shall not be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average exceed 87 percent opacity. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in 2.1 F.2.a,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521. Monitorine[15A NCAC 02Q.0508(f)] c. To ensure compliance,once a week the Permittee shall observe the emission points of the Lime Silo and Lime Slaker(ID Nos.NS-R1 and NS-112)for any visible emissions above normal.The weekly observation must be made for each week of the calendar year period to ensure compliance with this requirement.Theme R ittee shall i. If visible emissions from the Lime Silo and Lime Slaker are observed to be above normal,the Pemtitteeshall either: (A)take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or (B) demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in Section 2.1 F.2.a,above. ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521 if. (A)the above-normal emissions are not corrected per c.i.(A)above; (B) the demonstration in c.i.(B)above cannot be made; (C) the weekly observations are not conducted per c above;or (D)"normal'is not established for the Lime Silo and Lime Slaker in the first 30 days following the beginning of operation per c above. Recordkeevina[15A NCAC 02Q.0508(f)] d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request.The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to beabove normal along with any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not maintained. Reaortin¢[15A NCAC 02Q.0508(1)] e. The Permittee shall submit a summary report of the monitoring activities specified in Section 2.1 F.2.c and d,above, postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June.All instances of deviations from the requirements of this permit must be clearly identified. Permit No.0373S rn o Q-735T49 Page 43 2.2-Multiple Emission Source(s)Specific Limitations and Conditions A. BOILERS: Three natural gas/No.2 fuel oil-fired boilers(ID Nos.PS-A,PS-B,and PS-C) Temporary boiler(ID No.PS-Temp),natural gas/No.2 fuel oil-fired(greater than 30.0 and less than 100.0 million Btu per hour maximum heat input). 1. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the affected boilers(ID Nos.PS-A,PS-B,PS-C,and PS-Temp)shall discharge into the atmosphere less than 702.5 tons of S02 per consecutive 12-month period. Testine[15A NCAC 02Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.If the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.2 A.La,above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530. MonitorineJRecordkeeaine[15A NCAC 02Q.0508(f)] c. The Permittee shall keep monthly records of fuel usage in a log(written or in electronic format),as follows: i. The total quantity(in million standard cubic feet)of natural gas fired at the affected boilers, ii. The total quantity(in 1,000 gal)of fuel oil fired at the affected boilers;and, iii. The fuel oil supplier certification for any fuel oil fired at the affected boilers,including the sulfur content ofthe oil(in percent by weight). The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the fuel usage and fuel oil sulfur contents are not created and retained as required above. d. The Permittee shall calculate monthly and 12-month rolling S02 emissions from the affected boilers within 30 days after the end of each calendar month.Calculations shall be recorded in a log(written or electronic format),according to the following formulas: i. Calculate SO,emissions from the previous calendar month using the following equation: Esoz=142 x Sfo2 x Qfo2+0.6 x Q,, Where, Eso2 = S02 emissions(in lb)during the previous calendar month; S r 2 = Sulfur content in the fuel oil(percent by weight); Qea2 = Quantity of fuel oil fired during the previous calendar month(1,000 gal); and, %g = Quantity of natural gas fired during the previous calendar month(million standard cubic feet). ii. Sum the S02 emissions from the affected boilers for the previous 12-month period to determine the 12- month rolling emission total. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations listed above are not retained or if the 12-month rolling emission totals are greater than the emission limitprovided in Section 2.2 A.l.a of this permit. Renortine[15A NCAC 02Q.0508(t)] e. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality Supervisor,of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December,and July 30 of each calendar year for the preceding six-month period between January and June.The report shall contain the following: i. The monthly S02 emissions from the two affected boilers for the previous 17 calendar months; H. The 12-month rolling SO,emissions for each 12-month period ending during the reporting period;and, iii. All instances of noncompliance from the requirements of this permit must be clearly identified. Permit No.03�T' 03735T49 Page 44 B. FACILITY-WIDE STATE-ENFORCEABLE 41yLY 1. 15A NCAC 02D.1100:TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS a. Pursuant to 15A NCAC 02D.1100 and in accordance with the approved application for an air toxic compliance demonstration,the following permit limit shall not be exceeded: Toxic Air Pollutant Facility-Wide Emission Limit Acetaldehyde 395 lb/hr Acetic Acid 54.1 lb/hr Acrolein L 17 lb/hr Acrylonitrile 240 lb/yr Ammonia 39.5 lb/hr Ammonium Chromate 0.54 lb/day Ammonium Dichromate 0.541b/day Aniline 14.6 lb/hr Arsenic and Inorganic Arsenic Compounds 0.371b/yr Aziridine 5.26 lb/day Benzene 1921b/yr Benzidine and Salts 0.02 lb/yr Benzo(a)pyrene 52.8lb/yr Benzyl Chloride 7.31 lb/yr Beryllium 6.56 lb/yr Beryllium Chloride 6.56 lb/yr Beryllium Fluoride 6.56 lb/yr Beryllium Nitrate 6.56 lb/yr Bis-Chloromethyl Ether 0.59 lb/yr Bromine 2.92 lb/hr 1,3-Butadiene 272 lb/yr Cadmium 8.81b/yr Cadmium Acetate 8.81b/yr Cadmium Bromide 8.8 lb/yr Calcium Chromate 0.13 lb/yr Carbon Disulfide 163 lb/day Carbon Tetrachloride 10,723 Ib/yr Chlorine 13.1 lb/hr,32.9 lb/day Chlorobenzene 1,929lb/day Chloroform 6,8821b/yr PeRTRt No.nz"o�735:P48 03735T49 Page 45 Toxic Air Pollutant Facility-Wide Emission Limit Chloroprene 51.1 lb/hr;386 lb/day Chromic Acid 0.54 lb/day Chromium(VI) 0.13 lb/yr Cresol 32.15 lb/hr p-Dichlorobenzene 965lb/hr Dichlorodifluoromethane 217,477 lb/day Dichlorofluoromethane 438 lb/day Di(2-ethylhexyle)phthalate 26.3 lb/day Dimethyl Sulfate 2.63 lb/day 1,4-Dioxane 491 lb/day Epichlorohydrin 132,832 lb/yr Ethyl Acetate 2,046 lb/hr Ethylenediamine 36.51b/hr,263 lb/day Ethylene Dibromide 640 lb/yr Ethylene Dichloride 6,081 lb/yr Ethylene Glycol Monoethyl Ether 27.8 lb/hr;105 lb/day Ethylene Oxide 43.2 lb/yr Ethyl Mercaptan 1.46 lb/hr Fluorides 3.651b/hr;14.03 lb/day Formaldehyde 2.191b/hr Hexachlorocyclopentadiene 0.15 lb/hr;0.53 lb/day Hexachlorodibenzo-p-dioxin 0.12 lb/yr n-Hexane 965 lb/day Hexane Isomers 5,2621b/hr Hydrazine 0.531b/day Hydrogen Chloride 10.2 lb/hr Hydrogen Cyanide 16.1 lb/hr;123 lb/day Hydrogen Sulfide 30.7lb/h Maleic Anhydride 1.46 lb/hr;10.5 lb/day Manganese&Compounds 27.2 lb/day Manganese Cyclopentadienyl Tricarbonyl 0.53 lb/day Manganese Tetroxide 5.44 lb/day Mercury,Alkyl 0.05 lb/day Mercury,Aryl&Inorganic 0.53 lb/hr Permit No.^"'ohm 8T,'8 03735T49 Page 46 Toxic Air Pollutant Facility-Wide Emission Limit Mercury,vapor 0.53 lb/hr Methyl Chloroform 3,581 lb/hr;10,523 lb/day Methylene Chloride 24.85 lb/hr;38,409 lb/yr Methyl Ethyl Ketone 1,2931b/hr;3,2451b/day Methyl Isobutyl Ketone 4381b/hr;2,245 lb/day Methyl Mercaptan 0.73 lb/hr Nickel Carbonyl 0.53 lb/day Nickel Metal 5.26 lb/day Nickel,Soluble Compounds as Nickel 5.26 lb/day Nickel Subsulfide 3.36 lb/yr Nitric Acid 14.6 lb/hr Nitrobenzene 7.31 lb/hr;52.6 lb/day n-Nitrosodimethlamine 80.0 lb/yr Pentachlorophenol 0.37 lb/hr;2.63 lb/day Perchloroethylene 304,073 lb/yr Phenol 13.9 lb/hr Phosgene 2.19lb/day Phosphine 1.90 lb/hr Polycholinated Biphenyls 133lb/yr Potassium Chromate 0.54 lb/day Potassium Dichromate 0.54 lb/day Sodium Chromate 0.54 lb/day Sodium Dichromate 0.54 lb/day Strontium Chromate 0.13 lb/yr Styrene 155 lb/hr Sulfuric Acid 1.46 lb/hr;10.5 lb/day Tetraclilorodibenzo-p-dioxin 0.00481b/yr 1,1,1,2-Tetrachloro-2,2-Difluoroethane 45,600 lb/day 1,1,2,2,-Tetrachloro-1,2-Difluoroethane 45.600lb/day 1,1,1,2-Tetrachloroethane 10,082 lb/yr Toluene 818lb/hr,4,122lb/day Toluene-2,4-diisocyanate 0.22 lb/hr;0.44 lb/day Tecchloroethylene 94,423 lb/yr Trichlorofluoromethane 8,185 lb/hr Permit No.037 5T-,t o° 03735T49 Page 47 Toxic Air Pollutant Facility-Wide Emission Limit 1,1,2-Trichloro-1,2,2-Trifluoroethane 13,885 lb/hr Vinyl Chloride 608lb/yr Vinylidene Chloride 105 lb/day Xylene 95016/hr;2,368 lb/day Zinc Chromate 0.13 lb/yr Recordkeeoine b. For compliance purposes,the Permittee shall maintain records of production rates,throughput,material usage, periods of excess emissions,failure of air pollution control equipment to operate in a normal and usual manner,and other process operational information,that allows for evaluation for compliance with the toxic air pollutant limits.These records shall be retained for a minimum of three years from the date of recording,and access to these records shall be provided to the Division of Air Quality staff upon request. Reoortin¢ c. For compliance purposes,within thirty(30)days after each calendar year gtiafte the following shall bereported to the Regional Supervisor,Division of Air Quality: i. Any and all exceedances of applicable toxic air pollutant emission limits during the previous calendaryear- OH . ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar yearryuauer-forall applicable toxic air pollutants that have a listed emission rate in pounds per hour. iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year ryuatteefor all applicable toxic air pollutants that have a listed emission rate in pounds per day. iv. The yearly emission rate for the 12-month period ending with the previous calendar year quartLF forall applicable toxic air pollutants that have a listed emission rate in pounds per year. STATE-ENFORCEABLE ONLY 2. 15A NCAC 02D.1100:TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS a. Pursuant to 15A NCAC 02D.1100 and in accordance with the approved application for an air toxiccompliance demonstration,the following permit limits shall not be exceeded: ------- -------------------------------- -- _-- I3ydrngeu.---- --_` -' Formatted:F.,,,10pt Fluoride Formatted Table Stack ID Emission Emission Limits No. Source Ib/hr Ib/dav -- - - ------------ Formatted:Font:10pt «` _ ,..a, oct t cnc r:,,.:a"'Aster c«.,t.a;- NIP-1r TTE rno cepafat:,.., ucnn °� FOrtnatted•Font:10 Pt Container « ,.'Decontamination ofeoe,,ei n,e � NS o N8 n i NS c Rio cat: t Formatted Table --- ---------- --------`----- -- -- Formatted:Font:10pt `--`--- - t- - --------- ------ Formatted:Font:lOpt allet by Wet c,...bbeF No.nun fuggitive d}}liSSi6k35 Carbon Adsorber(ID No.NCD-Hdr3)stack controlling VE-North Indoor Fugitive —` Formatted:Font:10 pt Emissions(ID No.NS-B-2y t Formatted Table Thermal Oxidizer and 4-Stage Caustic Scrubber System(I)Nos.NCD-Ql and NCD-Q2)stack controlling:HFPO,Vinyl Ethers North,Vinyl Ethers South,RSU, FPS Liquid Waste Stabilization,MMF,IXM Resins(except Fluorinator),E-2, 7.28 52.45 TFE/CO2 Separation,HFPO Product Container Decontamination,VEN Product Decontamination,and VES Product Container Decontamination Processes(ID Nos. NS-A,NS-B,NS-C,NS-D-I,NS-E,NS-F,NS-G-I,NS-K,NS-M,NS-N,NS-O, and NS-P Pennit No.03735-T^ 03735T49 Pampe 48 '-"'-,E-- PolytnefRrocessing Aid Stack-including-Carbon-Adsorber{ID-Ne.AC-D A2}- ---------- --- Formatted:Font:10 pt installed on Wet Scrubber(ID No.ACD-AI)and heating and ventilation building Formatted Table exhaust - -------- - groes---------- -- Formatted:Font:1Opt /A All sources not identified above_ ____ _ _ 2.7____19.4_ ___. Formatted:Font:10 pt Formatted Table Permit No.03735 ,!8 03735T49 Page49 Monitorine b. To ensure compliance with the limits in Section 2.2 13 2.a,above,the Permittee shall N"C-D Ildr 2)b5 meiiitat-ing the injection liquid flow tate(minimum 47,000 kilegmms pef War,awraged 4.i. AO&ensure the proper performance of the Thermal Oxidizer and 4-Stage Scrubber System(IDNos. NCD-Q1 and NCD-Q2)by complying with the requirements specified in Section 2.1 13_1Ok. ____Y_- Formatted:Highlight Recordkeeoine c. The Permittee shall: ii- -kl9S=record the results of inspections of the Thermal Oxidizer and 4-Stage Scrubber Formatted Indent:Leh: 1.4". No bullets or numbering System(IDNos.NCD-Q1 and NCD-Q2)as specified in Section 2.1 B.101;above ____ ii-i_Any variance from the manufacturer's recommendations or the permit monitoring requirements,or the Formatted:Highlight f failure of the air pollution control equipment to operate in a normal and usual manner,shall be investigated with corrections made and dates of action recorded in the log book.The inspection and maintenance activities,as well as required monitoring for scrubbing liquid flow rates,and scrubber pressure drops,if appropriate,shall be recorded. d. The Permittee shall maintain records of production rates,throughput,material usage,periods of excess emissions,failure of air pollution control equipment to operate in a normal and usual manner,and other process operational information,that allows for evaluation for compliance with the toxic air pollutant limits specified in Section 2.2 13.2.a,above.These records shall be retained for a minimum of three years from the date of recording,and access to these records shall be provided to the Division of Air Quality staff upon request. Reoortine e. For compliance purposes,within thirty(30)days after each calendar year quarter-the following shall bereported to the Regional Supervisor,Division of Air Quality: i. Any and all exceedances of applicable TAP emission limits during the previous calendar year gH*Aee. ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year-gw*IeF forall applicable toxic air pollutants that have a listed emission rate in pounds per hour. iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year-quaFterfor all applicable toxic air pollutants which have a listed emission rate in pounds per day. 3. 40 CFR Part 68"ACCIDENTAL RELEASE PREVENTION REQUIREMENTS:RISK MANAGEMENT PROGRAMS UNDER THE CLEAN AIR ACT,SECTION 112(r)" a. The Permittee is subject to Section 112(r)of the Clean Air Act and shall comply with all applicable requirements in accordance with 40 CFR Part 68. Recordkeeoine/Renortina[15A NCAC 02Q.0508(f)] b. The Permittee submitted a Risk Management Plan(RMP)to EPA pursuant to 40 CFR Part 68.150 on August 18,2014. c. The Permittee shall revise and update the RMP submitted under 40 CFR 68.150 by August 31,201q,and at - Commented[CR2]:Update this date based on the last ` least once every five years after that date or most recent update required by 40 CFR 68.190(b)(2)through(b)(7), submittal date of July 24,2019 f whichever is later. STATE-ENFORCEABLE ONLY 4. 15A NCAC 02D.0541:CONTROL OF EMISSIONS FROM ABRASIVE BLASTING a. The Permittee shall ensure that any abrasive blasting operation conducted outside a building or conducted indoors and vented to the atmosphere is performed in accordance with the requirements set forth in 15ANCAC 02D.0521,Control of Visible Emissions.Any visible emissions reading for abrasive blasting performed outside a building shall be taken at a spot approximately one meter above the point of abrasive blasting with a viewing distance of approximately five meters. Permit No.03 73 5T4T"8 03735T49 Page 50 b. All abrasive blasting operations shall be conducted within a building,except as provided below.The following abrasive blasting operations need not be conducted within a building: i. Abrasive blasting of an item that exceeds eight feet in any dimension;or, ii. Abrasive blasting of a surface situated at its permanent location or not further away from itspermanent location than is necessary to allow the surface to be blasted. c. Any abrasive blasting operation conducted outside a building,as provided in Section 2.2 B.3.b.i or ii,above, shall take appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being conducted.Appropriate measures include the following: i. Addition of a suppressant to the abrasive blasting material; ii. Wet abrasive blasting; iii. Hydro-blasting; iv. Vacuum blasting; v. Shrouded blasting;or vi. Shrouded hydro-blasting. STATE-ENFORCEABLE ONLY 5. 15A NCAC 02D.1806:CONTROL AND PROHIBITION OF ODOROUS EMISSIONS a. 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 causingor contributing to objectionable odors beyond the facility's boundary. Permit No.n'''e�, eT4 Q 03735T49 Page 51 C. PERMIT APPLICATION SUBMITTAL REQUIREMENT 1. 15A NCAC 02Q.0504:OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT_ Permittine[15A NCAC 02Q.0504(d)] a. As required under 15A NCAC 02Q.0501(bx2),the Pemrittee shall have one year from the date ofbeginning normal operation of the Thermal Oxidizer(ID No.NCD-Q1),the 4-Stage Caustic Scrubber(ID No.NCD-Q2),the Lime Silo(ID No.NS-RI),or the Lime Slaker(ID No.NS-R2),whichever is first,to file an amended application following the procedures of Section 15A NCAC 02Q.0504. ReoortinQ[15A NCAC 02Q.0508(f)] b. The Permittee shall notify the Regional Office,in writing,of the date of beginning normal operation ofthe Thermal Oxidizer(ID No.NCD-QI),the 4-Stage Caustic Scrubber(ID No.NCD-Q2),the Lime Silo(ID No.NS-R1),or the Lime Slaker(ID No.NS-R2),postmarked no later than 30 days after such date. Permit No.03735 rn oo 03735T49 Page 52 D. FACILUY-WIDE STATE-ENFORCEABLE ONLY 1, 15A NCAC 02Q.0519(a)(7)and CONSENT ORDER a. To carry out the purposes of N.C.G.S.§143 Article 21B and to ensure that air emissions do not contribute to groundwater violations,and pursuant to the Consent Order,'the Permittee shall reduce facility-wide annual emissions(including fugitive,maintenance,malfunction,or accidental emissions)of GenX Compounds7 to lessthan 23.027 pounds per year,which constitutes a 99 percent reduction from the 2017 Total Reported Emissions of 2,302.7 pounds per year.The Section 22 D.1 requirements shall survive termination of the Consent Order'and any part thereof The requirements in this section shall be included in all subsequent air quality permits for the Chemours Company—Fayetteville Works Facility unless the Director determines that the requirements in this section are no longer necessary to carry out the purposes of N.C.G.S.§143 Article 21B and any other applicable statutes and regulations.The Permittee shall comply with the following requirements: i. Permittee shall demonstrate compliance with the GenX Compounds emission limit of 23.027 pounds peryear by calculating annual emissions each calendar month for the previous 12 months. ii. The Permittee shall reduce emissions of GenX Compounds by 99.99 percent from the HFPO Process,Vinyl Ethers North Process,Vinyl Ethers South Process,RSU Process,FPS Liquid Waste Stabilization Process,NIN4F Process,IXM Resins Process(except Fluorinator),E-2 Process,TFE/CQ Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NSC,NS-D-1,NSE,NSF,NS-G-1,NS-R,NS-M,NSN, NS-O,and NS-P)by installing,operating,and maintaining a Thermal Oxidizer and 4-Stage Scrubber System (ID Nos.NCD-Q1 and NCD-Q2),as required in Section 2.1 B.11,above. iii. The Permittee shall install,operate,and maintain Carbon Adsorbers as specified in Section 2.2 D.Lb through g, below to reduce emissions of GenX Compounds from the following sources: (A)Carbon Adsorber(ID No.ACD-A2)installed to control emissions from the Polymer Processing Aid Process(ID No.AS-A); (B) Carbon Adsorber(ID No.NCD-Q3)installed to control VE-North Indoor Fugitives(ID No.NS-B-2); (C) Carbon Adsorber(ID No.NCD-Q4)installed to control VE-South Indoor Fugitives(ID No.NS-C-2);and (D)Carbon Adsorber(ID No.SCD-SW1)installed to control emissions from SemiworksPolymerization Operation,Semiworks Laboratory Hood,and VE Research Laboratory Hood and Chemical Storage Cabinet(ID Nos.SW-1,SW-2,and I-05-2,respectively). iv. The Permittee shall reduce emissions of GenX Compounds from process equipment by complying with the enhanced leak detection and repair program as specified in Section 2.2 D.Lh,below. v. The Permittee shall comply with the recordkeeping and reporting requirements specified in Section 2.2 D.l.i through in,below. Testine—Carbon Adsorbers[15A NCAC 02Q.0308(a)] b. The Permittee shall conduct performance tests for GenX Compounds emissions from each Carbon Adsorber(ID Nos.ACD-A2,NCD-Q3,NCD-Q4,and SCD-SW1)in accordance with General Condition JJ and in accordance with a testing protocol approved by DAQ at least 45 days prior to conducting the performance test.During each performance test,the Permittee shall collect production data and hours of operation.Two copies of the final air emission test report shall be submitted to the Director not later than 45 days after each performance test. c_ . _.. ,.r..,. ,, ,�,n The Pemdttee shall conduct an initial performance test on the Semiworks Carbon Adsorber(ID No.SCD-SWI)no later than 60 days after startup of normal operations of the adsorber system. _._...._.........._..._............._.....___.._... Formatted:Font:10 pt,Not Highlight Formatted-Indent:Left: 0.9",Hanging: 0.25",Right: "'Consent Order'means the Consent Order entered on February 25.2019,in State of North Carolina,ex rel.,Michael S.Regan,Secretary,North Carolina 0 No bullets or numbering,Tab stops:Not at 0.9"+ Department of Environmental Quality v.The Chemours Company FC,LLC,17 CVS 580(Bladen County). 0.91, "'GenX Compounds"means HFPO Dimer Acid,also knmvn as C3 Dimer Acid(CAS No.13252-13-6);HFPO Dimer Acid Fluoride,also known as C3 Dimer Acid Fluoride(CAS No.2062-98-8);and HFPO Dimer Acid Ammonium Salt,also knotm as C3 Dimer Acid Ammonium Salt(CAS No.62037-80- 3). Permit No.0"o�,;iT-4 03735T49 Page 53 I_The Permittee shall also conduct performance tests in order to develop carbon replacement schedules for each carbon adsorber(ID Nos.ACD-A2,NCD-03,NCD-44,and SCD-SN'l}.The replacement schedules shall be approved by DAQ and shall be based on hours of operation,production rate,or another approved parameter. Until a replacement schedule is submitted to and ao moved b)�rbon adsorber performance tests shall be conducted as follows: i. On a r uarterly basis for the PPA Process.1'E-Nortlr Indoor Fugitives.and VE-South Indoor Fugitives carbon adsorbers-ID Nos.ACD-A2,NCD-g3,and NCD-04t:and ii. On an annual basis for the Semiworks carbon adsorber,ID No.SCD-SW I Ee_Once the carbon replacement schedule has been approved,the Permittee shall conduct periodic performance tests within a 13-month time period 448F tile ' following the previous performance test. d-f. e—The Permittee shall conduct additional performance tests to reestablish the carbon replacement schedule no later than 90 days after permanent changes are made in production capacity,process feedstock type,or whenever there is a replacement,removal,or addition of an emission source or control device which has an impact significant enough to affect carbon lied rerforntance.:kftet the re iced retslaee»tenF-tlteinle s apprered-tlte Rean+ttee #aN rt +nx scl�eAc�.r. .. t—l3o«in�t+rrg yla., ,n --motees,arv: ,eladt+lcfe3rthepr>E�inefRfttes,i+}w lelProcesan,��cam_.. ;..r,� c,`:tvesCafFEn ldaarbers{ID-Nos.- lndoer€arf,:t ei Gaibeu Adsarlref(ID:7e. SC-B-SM'1-'mall annual basis. Inspections-Carbon Adsorbers[15A NCAC 02Q.0308(a)] i- Emissions of GenX Compounds from Polymer Processing Aid Process(ID No.AS-A),VE-North Indoor Fugitives (ID No.NS-B-2),VE-South Indoor Fugitives(ID No.NS-C-2),and Semiworks Polymerization Operation, Semiworks Laboratory Hood,and VE Research Laboratory Hood and Chemical Storage Cabinet(ID Nos.SW-1, SW-2,and 1-05-2,respectively)shall be controlled by Carbon Adsorbers(ID Nos.ACD-A2,NCD-Q3,NCD-Q4, and SCD-SWI,respectively).To ensure compliance,the Perittee shall perform annual inspections and maintenance as recommended by the manufacturer.In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum, the annual inspection and maintenance shall include the following: i. inspect and maintain the structural integrity of the carbon adsorber systems;and ii. inspect and maintain the structural integrity of duct work and piping leading to the carbon adsorber. Shutdown and Malfunction-Carbon Adsorbers r15A NCAC 02Q.0308(a)1 j-1t_Except as specified in Section 2.2 D.lg[,below,the Permittee shall: --__-_- _-- Formatted-Highlight i. Operate the Carbon Adsorber(ID No.ACD-A2)at all times when the Polymer Processing Aid Process is operating. ii. Operate the Carbon Adsorber(ID No.NCD-Q3)at all times when the VE-North Process is operating. iii. Operate the Carbon Adsorber(ID No.NCD-Q4)at all times when the VE-South Process is operating. iv. Operate the Carbon Adsorber(ID No.SCD-SWI)at all times when the Semiworks Process or VELaboratory Processes are operating. 4-._The Polymers Processing Aid Carbon Adsorber(ID No.ACD-A2)system shall be equipped with a differential pressure monitor on the primary blower and the scrubber blower.The VE-North Indoor Fugitives Carbon Adsorber (ID No.NCD-Q3)system shall be equipped with a differential pressure monitor on the blower and the tower.The VE-South Indoor Fugitives Carbon Adsorber(ID No.NCD-Q4)and Semiworks Carbon Adsorber(ID No.SCD- SWI)systems shall be equipped with a differential pressure monitor on the blower and an alarm on the exhaust blower to indicate whether the blower is running.Each monitor shall trigger an alarm in the control room when the differential pressure indicates improper operation of the carbon bed blower.The Pemtittee shall develop,andsubmit to DAQ for approval,a site-specific monitoring plan that addresses design,data collection,and quality assurance/quality control elements for operating each CMS installed on the carbon adsorbers.The monitoring plan shall,at a minimum,address the following: i. initial a: d aAt�' 1 'd segteent-Cealibrations ofthe CMS; Permit No.037Zvr 95T-1T`18 03735T49 Page 54 ii. Determination and adjustment of the calibration drift of the CMS; iii. Preventive maintenance of the CMS,including spare parts inventory; iv. Data recording,calculations,and reporting; v. Accuracy audit procedures,including sampling and analysis methods; vi. Program of corrective action for a malfunctioning CMS; vii. Ongoing operation and maintenance procedures;and viii.Ongoing data quality assurance procedures. heeamaintain a detailed shutdown and malfunction plan for the Polymer Processing Aid Process and VE-North Indoor Fugitive Carbon Adsorbers (ID Nos.ACD-A2 and NCD-Q3),that contains specific procedures for initiating the shutdown of process emission sources during periods of control device shutdown and malfunction,and a program of corrective action for malfunctioning processes and control systems used to comply with the limits in Section 2.2 D.l.a,above.No later than June 12,2020,the Permittee shall update,and submit to DAQ for approval,the detailed shutdown and Permit No.03735T48 03735T49 Page 55 malfunction plan to include the VE-South Indoor Fugitives and Semiworks Carbon Adsorbers(ID Nos.NCD-Q3 and SCD-SW 1).The Permittee shall keep a copy o£the approved plan onsite.At a minimum,the plan shall include: i. To ensure that the control devices are well maintained to minimize malfunctions,a maintenance schedulefor the carbon adsorbers that is consistent with,but not limited to the manufacturer's instructions and recommendations for routine and long-term maintenance,as specified in Section 2.2 D.1ik,above._ Formatted:Highlight ii. An inspection schedule for each CMS installed on the carbon adsorbers to ensure,at least once in each24-hour period,that each CMS is properly functioning. iii. A determination of the alarm set point for the differential pressure monitors installed on the carbonadsorber systems specified in Section 2.2 D.1 h_above. ____ _ -- Formatted:Highlight iv. At no time shall the emissions from the Polymer Processing Aid Process(ID No.AS-A),the VE-North Indoor Fugitives(ID No.NS-B-2),the VE-South Indoor Fugitives(ID No.NS-C-2),and Semiworks Polymerization Operation,Semiworks Laboratory Hood,and VE Research Laboratory Hood and Chemical Storage Cabinet(ID Nos.SW-1,SW-2,and I-05-2,respectively)be allowed to vent to the atmosphere without being controlled in the associated Carbon Adsorbers(I)Nos.ACD-A2,NCD-Q3,NCD-Q4,and SCD-SWI,respectively). Inspections and Monitoring-Enhanced Leak Detection and Repair Proeram[15A NCAC 02Q.0308(a)] fft,k.Ne lateF Vimi May 4 3._ -, .•",, I-' ._,.,.-...-.'-. The Permittee shall conduct inspections and monitor to detect leaks fromequipment identified in#bean approved enhanced leak detection and rmair program.The program shall address the following. i. Pressure testing for 30-minute intervals to detect a pressure drop rate up to 0.5 pounds per square inch(gauge) for those process lines with the potential to include 1 percent by weight of GenX Compounds,or greater. ii. Enhanced audial,visual,and olfactory(AVO)inspections,including,but not limited to: (A)expanding the equipment subject to the inspection process; (B) conducting daily AVO inspections of all outdoor equipment containing at least 1 percentby weight,or greater,GenX Compounds;and (C) completing a checklist of all equipment to be inspected along with information such as date and time of inspection,the names of personnel conducting the inspection,and detailed descriptions of the areas or equipment inspected. iii. Routine Method 211nstrument Monitoring for all outdoor equipment on process lines with the potential to contain at least 1 percent GenX Compounds. iv. Enhanced area monitoring,including but not limited to,increasing the number of area monitoring sampling locations,specifically those process streams with the potential to include 1 percent by weight of GenX Compounds and upgrading the monitoring system. v. Replacement or improvement program for valves and connectors,using leak detection and repair monitoringto initiate replacement with low emission technology.The program shall address the following: (A)the leak definition,not to exceed 500 ppm,as measured by instrument monitoring; (B) the criteria for replacement of manual valves and gaskets and automated valves,including: (1) the procedure for the normal means of repair for the first leak and,at a minimum,will include tightening of flanges,packing,or bonnets;and (2) once repaired,the program shall specify how the repaired equipment will be tested and how the Permittee will treat equipment that is still leaking. (C) how the Permittee will address equipment is found to be leaking above 500 ppm twice during a rolling 12- month period,including a requirement to replace these components with low-emission technology during the next shutdown,regardless of whether a first attempt at repair succeeds in repairing a second leak. vi. The maintenance and calibration of any instrumentation and equipment used to implement the enhanced leak detection and repair program in paragraphs i.through v.,above. Compliance Demonstration[15A NCAC 02Q.0308(a)] itl_The Permittee shall demonstrate initial compliance with the emission limitation specified in Section 2.2 D.La, above,by submitting a report to DAQ by February 28,2021.The report shall include the following information for the 12-month period beginning December 31,2019: i. Emissions of GenX Compounds,in pounds per year,shall be quantified for process vents,fugitive emissions, maintenance emissions and accidental emissions.Emissions shall be calculated based on test data,or established emission factors where test data are not available,hours of operation,and production data. ii. A summary of control device operating parameters throughout the year. e-m.After the initial compliance report specified in Section 2.2 D.l it above,the Pemuttee shall demonstrate ____ _-- Formatted:Highlight continuous compliance with the emission limitation specified in Section 2.2 D.La,above,by submitting quarterly reports Permit No.n"2� TT'' 03735T49 Page 56 summarizing the information specified in Section 2.2 D.111 above.The continuous compliance reports shall ________- Formatted:Highlight be submitted in accordance with the schedule specified in Section 2.2 D.1Inter below,and the first report shall___ ----.-- Formatted Highlight - :- - be postmarked on or before April 30,2021. g g Recordkeenina[15A NCAC 02Q.0308(a)] p-n_The Permittee shall record the following information monthly in a logbook(written or electronic format)thatshall be maintained on-site and made available to DAQ,upon request. i. Records of all production data and hours of operation collected during performance tests. ii. Records ofthe calculations,and all supporting documentation,of annual GenX Compound emissionsto demonstrate compliance with the emissions limitation specified in Section 2.2 D.La,above. iii. If the emission source is not operating,a record of this fact,along with the corresponding date and time. iv. Records of all inspections and maintenance conducted for the Carbon Adsorbers(ID Nos.ACD-A2,NCD-Q3, NCD-Q4,and SCD-SW1)as specified in Section 2.2 D.1_ft above.___________________________ --- Formatted:Highlight v. Records of all instances of process shutdowns,including those triggered by the pressure differential alarms associated with carbon adsorber systems. vi. Records of all inspections and calibrations of monitoring equipment as required in Section 2.2 D.1*h l and ______—_- Formatted:Highlight D.1 Iik above - - Formatted:Highlight to.The Permittee must keep each entry in the log and all required records on file for a minimum of five years.In addition to the records identified in Section 2.2 D.l,�n,above,the Perrrrittee shall also keep the following______-___-- Formatted:Highlight records. i. A copy of each test report and compliance report submitted to DAQ to comply with Section 2.2 D.1,including all documentation supporting any compliance report. ii. The most recent copy of the approved Carbon Adsorber shutdown and malfunction plan required in Section 2.2 D.l,d above.Records of instances where the differential pressure monitors or blower alarms_required in_______ --- Formatted:Highlight Section 2.2 D.1 41,_above,have resulted in process shutdowns. Enhanced- -- - -a__________________________---- Formatted:Highlight iii. The most recent copy of the approved Leak Detection and Repair Program required in Section 2.2 D.I.4k abov_e;including-the followinK____ _ __ _______ __-- Formatted:Highlight (A)Pressure testing records,including,but not limited to,the date of inspection,results of the inspection/pressure testing,repairs made to any equipment found to be leaking during pressure testing,and follow-up pressure testing to verify successful repair; (B) AVO inspection records,including the completed checklist specified in Section 2.2 D.lpk.ii_C,above,-_____ - Formatted:Highlight and inspection results including any leaks found and repair actions taken; (C) Method 21 and enhanced area monitoring results;and (D)Replacement program for valves and connectors logs of leakers and repair attempts. Reports[15A NCAC 02Q.0308(a)] r-p The Permittee shall submit a quarterly summary report,acceptable to the Regional Air Quality Supervisor,of monitoring and recordkeeping activities specified in Section 2.2 D.1,above,postmarked on or before January 30 of each calendar year for the preceding three-month period between October and December;April 30 of each calendar year for the preceding three-month period between January and March;July 30 of each calendar year for the preceding three-month period between April and June;and October 30 of each calendar year for the preceding three- month period between July and September.All instances of deviations from the requirements of this permit must be clearly identified. i. The summary report shall include the information recorded as required in Section 2.2 D.1<1ai and jo above.______ - Formatted•Highlight ii. The Permittee shall include in the summary report any excess emissions that have occurred during the reporting period.Excess emissions are defined as any calculated annual rolling average GenX Compound emissions rate, Formatted:Highlight calculated as required in Section 2.2 D.La,above,that exceeds the emission limit in Section 2.2 D.La,above. -L_The Pemittee shall have an ongoing duty to disclose to DAQ: i. any identified previously undisclosed PFAS and emissions rates for those PFAS,and it. any new process or production that may lead to the addition of any previously undisclosed PFAS in the Facility's air emissions.For any such PFAS,tare Permittee shall provide DAQ with any available analytical test methods and lab standards.The Permittee shall provide DAQ with all known test methods and lab standardsfor PFAS in air emissions at the facility by December 31,2018. Permit No.03735T48 03735T49 Page57 2.3 Permit Shield for Nonapplicable Requirements The Pemuttee is shielded from the following nonapplicable requirements[15A NCAC 02Q.0512(a)(1)(B)]. A. Temporary Boiler(ID No.PS-TEMP)—natural gas/No.2 fuel oil-fired boiler 1. The NSPS for Small Industrial-Commercial-Institutional Steam Generating units(40 CFR Part 60,Subpart Dc)and 15A NCAC 02D.0524 are not applicable to the natural gas/No.2 fuel oil-fired temporary boiler(ID No.PS-Temp) because the boiler is a temporary boiler,as defined in§60.41c,provided the following criteria are met: a. The boiler only fires natural gas and distillate oil; b. The potential SO,emissions are equal to or less than 0.060 lb/MIABtu; c. The boiler is designed to,and is capable of,being carried or moved from one location to another and isnot attached to a foundation;and d. The boiler remains at the location for 180 consecutive days or fewer(any temporary boiler that replaces a temporary boiler at a location and performs the same or similar function will be included incalculating the consecutive time period). 2. The National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and Process Heaters(40 CFR Part 63,Subpart DDDDD)and 15A NCAC 02D A I I I are not applicable to the natural gas/No.2 fuel oil-fired temporary boiler(ID No.PS-Temp)because the boiler is a temporary boiler,as defined in§63.7575,provided the criteria in Section 2.3 A.1 through A.4 are met. 3. The Permittee shall maintain the following records documenting that the natural gas/No.2 fuel oil-fired temporary boiler(ID No.PS-Temp)meets the criteria for a temporary boiler.These records shall be maintained in alogbook (written or electronic format)on-site and made available to an authorized representative upon request. a. the first,last and total number of days the boiler remains at the location; b. records of fuel usage in the boiler showing the type of fuel fired; c. records of fuel sulfur content of distillate oil fired in the boiler;and; d. the function of the boiler for each consecutive time period. 4. The Pemuttee shall submit a startup notification to the Fayetteville Regional Office within 15 days of startup of the temporary boiler(ID No.PS-Temp). Permit No."'"�T48 D3735T49 Page 58 SECTION 3-GENERAL CONDITIONS(version 5.3,08/21/2018) This section describes terms and conditions applicable to this Title V facility. A. General Provisions[NCGS 143-215 and 15A NCAC 02Q.0508(i)(16)] 1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 02D and02Q. 2. The terms,conditions,requirements,limitations,and restrictions set forth in this permit are binding and enforceable pursuant to NCGS 143-215.114A and 143-215.114B,including assessment of civil and/or criminal penalties.Any unauthorized deviation from the conditions ofthis permit may constitute grounds for revocation and/or enforcement action by the DAQ. 3. This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the facility which are not addressed in thispermit. 4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,animal or plant life,or property caused by the construction or operation ofthis permitted facility,or from penalties therefore,nor does it allow the Permittee to cause pollution in contravention of state laws or rules,unless specifically authorized by an order from the North Carolina Environmental Management Commission. 5. Except as identified as state-only requirements in this permit,all terms and conditions contained herein shall be enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal Clean Air Act. 6. Any stationary source ofair pollution shall notbe operated,maintained,or modified without the appropriate and valid permits issued by the DAQ,unless the source is exempted by rule.The DAQ may issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in violation ofany ofthe applicable requirements. A permitted installation may only be operated,maintained,constructed,expanded,or modified in a manner that is consistent with the terms of thispermit. B. Permit Availability[15A NCAC 02Q.0507(k)and.0508(i)(9)(B)] The Permittee shall have available at the facility a copy ofthis permit and shall retain for the duration of the permit term one complete copy of the application and any information submitted in support of the application package.The permit and application shall be made available to an authorized representative of Department of Environmental Quality upon request. C. Severability Clause[15A NCAC 02Q.0508(i)(2)] In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those held to be invalid,shall remain valid and must be complied with. D.Submissions[15A NCAC 02Q.0507(e)and 02Q.0508(i)(16)] Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,notifications,request for renewal,and any other information required by this permit shall be submitted to the appropriate Regional Office.Refer to the Regional Office address on the cover page of this permit.For continuous emissions monitoring systems(GEMS) reports,continuous opacity monitoring systems(COMS)reports,quality assurance(QA)/quality control(QC)reports,acid rain CEM certification reports,and NOx budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall be sentto: Supervisor,Stationary Source Compliance North Carolina Division of Air Quality 1641 Mail Service Center Raleigh,NC 27699-1641 All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit). E. Duty to Comply[15A NCAC 02Q.0508(i)(3)] The Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in this permit. Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a violation of the Federal Clean Air Act.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. Permit No.0373§T-,!Q"Q 03735T49 Page 59 F. Circumvention-STATE ENFORCEABLE ONLY The facility shall be properly operated and maintained at all times in a manner that will effect 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 pollution control device(s)and appurtenances. G. Permit Modifications 1. Administrative Permit Amendments[15A NCAC 02Q.0514] The Pennittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 02Q .0514. 2. Transfer in Ownership or Operation and Application Submittal Content[15A NCAC 02Q.0524 and 02Q.0505] The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 02Q.0524 and 02Q 0505. 3. Minor Permit Modifications[15A NCAC 02Q.0515] The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 02Q.0515. 4. Significant Permit Modifications[15A NCAC 02Q.0516] The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 02Q .0516. 5. Reopening for Cause[15A NCAC 02Q.0517] The Pemtittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q.0517. H. Changes Not Rea uirine Permit Modifications 1. ReportingRequrements Any of the following that would result in new or increased emissions from the emission source(s)listed in Section 1 must be reported to the Regional Supervisor,DAQ: a, changes in the information submitted inthe application; b. changes that modify equipment or processes;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 ofthe emission limitations specified herein. 2. Section 502(b)(10)Changes[15A NCAC 02Q.0523(a)] a "Section 502(b)(10)changes"means changes that contravene an express permit term or condition.Such changes do not include changes that would violate applicable requirements or contravene federally enforceable permit terms and conditions that are monitoring(including test methods),recordkeeping,reporting,or compliance certification requirements. b. The Permittee may make Section 502(b)(10)changes without having the permit revised if: i. the changes are not a modification under Title I of the Federal Clean Air Act; ii. the changes do not cause the allowable emissions under the permit to be exceeded; iii. the Permittee notifies the Director and EPA with written notification at least seven days before the change is made;and iv. the Permittee shall attach the notice to the relevant permit. c. The written notification shall include: i. a description of the change; ii. the date on which the change will occur; iii. any change in emissions;and iv. any permit term or condition that is no longer applicable as a result ofthe change. d. Section 502(b)(10)changes shall be made in the permit the next time that the permit is revised or renewed, whichever comes first. 3. OffPermit Changes[15A NCAC 02Q.0523(b)] The Permittee may make changes in the operation or emissions without revising the permit if. a. the change affects only insignificant activities and the activities remain insignificant after the change;or b. the change is not covered under any applicablerequirement. 4. Emissions Trading[15A NCAC 02Q.0523(c)] To the extent that emissions trading is allowed under 15A NCAC 02D,including subsequently adopted maximum achievable control technology standards,emissions trading shall be allowed without permit revision pursuant to 15A NCAC 02Q.0523(c). Permit No.937�T4 8 03735T49 Page 60 LA Renortine Reouirements for Excess Emissions and Permit Deviations[15A NCAC 02D.0535(f)and 02Q.0508(f)(2)] "Excess Emissions"-means ail emission rate that exceeds any applicable emission limitation or standard allowed by any nde in Sections.0500 .0900,.1200,or.1400 of Subchapter 02D;or by a pennit condition;or that exceeds an emission limit established in a permit issued under 15A NCAC 02Q.0700.(Note:Definitions of excess emissions under 02D.1110 and 02D.I I I I shall apply where defined by rule) "Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and conditions of this permit including those attributable to upset conditions as well as excess emissions as defined above lasting less than four hours. Excess Emissions 1. If a source is required to report excess emissions under NSPS(15A NCAC 02D.0524),NESHAPS(15A NCAC 02D .1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting ofexcess emissions,reporting shall be performed as prescribed therein. 2. Ifthe source is not subject to NSPS(15A NCAC 02D.0524),NESHAPS(15A NCAC 02D.1110 or.1111),or these rules do NOT define"excess emissions,"the Permittee shall report excess emissions in accordance with 15A NCAC 02D.0535 as follows: a. Pursuant to 15A NCAC 02D.0535,if excess emissions last for more than four hours resulting from a malfunction, a breakdown of processor control equipment,or any other abnormal condition,the owner or operator shall: i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m.Eastern Time ofthe Division's next business day ofbecoming aware ofthe occurrence and provide: • name and location ofthe facility; • nature and cause of the malfunction orbreakdown; • time when the malfunction or breakdown isfirst observed; • expected duration;and • estimated rate of emissions; ii. notify the Regional Supervisor or Director immediately when corrective measures have been accomplished; and iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC 02D .0535(f)(3). Permit Deviations 3. Pursuant to 15A NCAC 02Q.0508(t)(2),the Permittee shall report deviations from permit requirements(terms and conditions)as follows: a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered under 15A NCAC 02D.0535 quarterly.A written report to the Regional Supervisor shall include the probable cause of such deviation and any corrective actions or preventative actions taken.The responsible official shall certify all deviations from permit requirements. I.B Other Renuircracnits under 15A NCAC 02D.0535 The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D.0535,including 15A NCAC 02D.0535(c)as follows: 1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation ofthe appropriate rule unless the owner or operator ofthe sources demonstrates to the Director,that the excess emissions are a result of a malfunction.The Director shall consider,along with any other pertinent information,the criteria contained in 15A NCAC 02D.0535(c)(1)through(7). 2. 15A NCAC 02D.0535(g).Excess emissions during start-up and shut-down shall be considered a violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable. J. Emergency Provisions[40 CFR70.6(g)] The Permittee shall be subject to the following provisions with respect to emergencies: 1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control ofthe facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and that causes the facility to exceed a technology-based emission limitation under the permit,due to unavoidable increases in emissions attributable to the emergency.An emergency shall not include noncompliance to the extent caused by improperly designed equipment,lack ofpreventive maintenance,careless or improper operation,or operator error. Permit No.""�T^ 03 73 5T49 Page 61 2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based emission limitations if the conditions specified in 3.below are met. 3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or other relevant evidence that include information asfollows: a. an emergency occurred and the Permittee can identify the cause(s)ofthe emergency; b. the permitted facility was at the time being properly operated; c. during the period ofthe emergency the Permittee took all reasonable steps to minimize levels of emissions that exceeded the standards or other requirements in the permit;and d. the Permittee submitted notice ofthe emergency to the DAQ within two working days ofthe time when emission limitations were exceeded due to the emergency.This notice must contain a description ofthe emergency,steps taken to mitigate emissions,and corrective actions taken. 4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the burden of proof. 5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified elsewhere herein. K. Permit Renewal[I5A NCAC 02Q.0508(e)and 02Q.0513(b)] This 15A NCAC 02Q.0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q.0500 renewal application is submitted at least six months before the date of permit expiration.If the Permittee or applicant has complied with 15A NCAC 02Q.0512(b)(1),this 15A NCAC 02Q.0500 permit shall not expire until the renewal permit has been issued or denied.Permit expiration under 15A NCAC 02Q.0400 terminates the facility's right to operate unless a complete 15A NCAC 02Q.0400 renewal application is submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q.0400 requirements.In either of these events,all terms and conditions of these permits shall remain in effect until the renewal permits have been issued or denied. L. Need to Halt or Reduce Activih•Not a Defense[I5A NCAC 02Q.0508(i)(4)] It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions ofthis permit. M. Duli to Provide Information I submittal of information [I5A NCAC 02Q.0508(i)(9)] 1. The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director may request in writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to determine compliance with the permit. 2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are requested by the Director.For information claimed to be confidential,the Permittee may furnish such records directly to the EPA upon request along with a claim of confidentiality. N. Duty to Supplement[15A NCAC 02Q.0507(f)] The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the permit application,shall promptly submit such supplementary facts or corrected information to the DAQ The Permittee shall also provide additional information as necessary to address any requirement that becomes applicable to the facility after the date a complete permit application was submitted but prior to the release of the draft permit. O. Retention of Records[I5A NCAC 02Q.0508(f)and 02Q.0508(1)] The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five years from the date of the monitoring sample,measurement,report,or application.Supporting information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring information,and copies ofall reports required by the permit. These records shall be maintained in a forth suitable and readily available for expeditious inspection and review.Any records required by the conditions ofthis permit shall be kept on site and made available to DAQ personnel for inspection uponrequest. P. Compliance Certification[15A NCAC 02Q.0508(n)] The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsyth Street SW,Atlanta,GA 30303)postmarked on orbefore March 1 a compliance certification(for the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the permit,including emissions limitations,standards,or work practices.It shall be the responsibility of the current owner to submit a compliance certification for the entire year regardless ofwho owned the facility during the year.The compliance certification shall Permit No.05T^o 03735T49 Page 62 comply with additional requirements as maybe specified under Sections 114(a)(3)or 504(b)ofthe Federal Clean Air Act. The compliance certification shall specify: 1. the identification of each tent or condition ofthe permit that is the basis ofthe certification; 2, the compliance status(with the terms and conditions ofthe permit for the period covered by the certification); 3. whether compliance was continuous or intermittent;and 4. the method(s)used for determining the compliance status ofthe source during the certification period. Q. Certification by Resnonsible Official[15A NCAC 02Q.0520] A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or compliance certification required by this permit.All certifications shall state that based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate,and complete. R. Permit Shield for Apr+Hcable Reiluirements[15A NCAC 02Q.0512] 1. Compliance with the terms and conditions ofthis permit shall be deemed compliance with applicable requirements, where such applicable requirements are included and specifically identified in the permit as of the date of permit issuance. 2. A permit shield shall not alter or affect: a. the power ofthe Commission,Secretary ofthe Department,or Governor under NCGS 143-215.3(a)(I 2),or EPA under Section 303 of the Federal C1eanAir Act; b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective date ofthe permit or at the time of permit issuance; c. the applicable requirements under Title IV;or d. the ability ofthe Director or the EPA under Section 114 ofthe Federal Clean Air Act to obtain information to determine compliance ofthe facility with itspermit. 3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made under 15A NCAC 02Q.0523. 4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q.0515. S. Termination,Modification,and Revocation ofthe Permit[15A NCAC 02Q.0519] The Director may terminate,modify,or revoke and reissue this permit if 1. the information contained in the application or presented in support thereof is determined to be incorrect; 2. the conditions under which the permit or permit renewal was granted have changed; 3. violations of conditions contained in the permit have occurred, 4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or 5. the Director finds that termination,modification,or revocation and reissuance ofthe permit is necessary to carry out the purpose of NCGS Chapter 143,Article2lB. T. Insi®ifrcant Activities[15A NCAC 02Q.0503] Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from any applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement.The Permittee shall have available at the facility at all times and made available to an authorized representative upon request,documentation,including calculations,if necessary,to demonstrate that an emission source or activity is insignificant. U. Property Rights[15A NCAC 02Q.0508(i)(8)] This permit does not convey any property rights in either real or personal property or any exclusive privileges. V. Inspection and Entry[15A NCAC 02Q.0508(1)and NCGS 143-215.3(a)(2)] 1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow the DAQ, or an authorized representative,to performthe following: a. enterthe Pennittee's premises where the permitted facility is located or emissions-related activity is conducted,or where records are kept under the conditions ofthe permit; b. have access to and copy,at reasonable times,any records that are required to be kept under the conditions ofthe permit; c. inspect at reasonable times and usingreasonable safetypractices any source,equipment(including monitoring and air pollution control equipment),practices,or operations regulated or required under the permit;and d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of assuring compliance with the permit or applicable requirements at reasonable times. Permit No.03735T4 9 03735T49 Page 63 Nothing in this condition shall limit the ability ofthe EPA to inspect or enter the premises ofthe Permittee under Section 114 or other provisions ofthe Federal Clean Air Act. 2. No person shall refuse entry or access to any authorized representative ofthe DAQ who requests entry for purposes of inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or interfere with any such authorized 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. W. Annual Fee Payment[15A NCAC 02Q.0508(i)(10)] 1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q.0200. 2. Payment of fees may be by check or money order made payable to the N.C.Department of Environmental Quality. Annual permit fee payments shall refer to the permit number. 3. If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate action to terminate the permit under 15A NCAC 02Q.0519. X. Annual Emission Inventory Requirements[15A NCAC 02Q.0207] The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 02Q .0207(a)from each emission source within the facility dining the previous calendar year.The report shall be in or on such form as may be established by the Director.The accuracy ofthe report shall be certified by a responsible official of the facility- Y. Confidential Information[15A NCAC 02Q.0107 and 02Q.0508(i)(9)] Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q.0107,the Permittee may also submit a copy of all such information and claim directly to the EPA upon request.All requests for confidentiality must be in accordance with 15A NCAC 02Q.0107. Z. Construction and Operation Permits[15A NCAC 02Q.0100 and.0300] A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or emission source which is not exempted from having a permit prior to the beginning of construction or modification,in accordance with all applicable provisions of 15A NCAC 02Q.0100 and.0300. AA.Standard Application Form and Required Information[15A NCAC 02Q.0505 and.0507] The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 02Q .0505 and.0507. BB.Financial Responsibility and Compliance History[15A NCAC 02Q.0507(d)(3)] The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial compliance history. CC.Refri¢erantReguirements(Stratospheric Ozone and Climate Protection, [15A NCAC 02Q.0501(d)] 1. Ifthe Permittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment according to the workpractices,personnel certification requirements,and certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F. 2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the environment during the repair,servicing,maintenance,or disposal of any such device except as provided in 40 CFR Part 82 Subpart F. 3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166.Reports shall be submitted to the EPA or its designee asrequired. DD.Prevention of Accidental Releases-Section 112f rl[15A NCAC 02Q.0508(h)] If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r)ofthe Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part 68. EE.Prevention of Accidental Releases General Duly Clause-Section 112[r)(11—FEDERALLY-ENFORCEABLE ONLY Although a risk management plan may not be required,ifthe 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. Permit No.937�vT"48 03735T49 Page 64 FF.Title IV Allowances[15A NCAC 02Q.0508(i)(1)] This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not use allowances as a defense to noncompliance with any other applicable requirement.The Pemrittee's emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act. GG.Air Pollution Emergency Episode[15A NCAC 02D.0300] Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to operate in accordance with the Permittee's previously approved Emission Reduction Plan or,in the absence ofan approved plan,with the appropriate requirements specified in 15A NCAC 02D.0300. HH.Registration of Air Pollution Sources[15A NCAC 02D.0202] The Director of the DAQ may require the Permittee to register a source of air pollution.If the Pennittee is required to register a source of air pollution,this registration and required information will be in accordance with 15A NCAC 02D .0202(b). II. Ambient Air Quality Standards[15A NCAC 02D.0501(c)] In addition to any control or manner ofoperation necessary to meet emission standards specified in this permit,any source of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality standards in 15A NCAC 02D.0400 to be exceeded at any point beyond the premises on which the source is located.When controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of the ambient air quality standards or are required to create an offset,the permit shall contain a condition requiring these controls. JJ.General Emissions Testinz and Reporting Requirements[15A NCAC 02Q.0508(i)(16)] Emission compliance testing shall be by the procedures of Section.2600,except as may be otherwise required in Rules .0524,.0912,.1110,.1111,or.1415 of Subchapter 02D.If emissions testing is required by this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance,the Permittee shall perform such testing in accordance with 15A NCAC 02D.2600 and follow the procedures outlined below: 1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to theDirector prior to air pollution testing.Testing protocols are not required to be pre-approved by the Director prior to air pollution testing.The Director shall review air emission testing protocols for pre-approval prior to testing if requested by the owner or operator at least 45 days before conducting the test. 2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard shall notify the Director at least 15 days before beginning the test so that the Director may at his option observe thetest. 3. The owner or operator of the source shall arrange for controlling and measuring the production rates during the period of air testing.The owner or operator of the source shall ensure that the equipment or process being tested is operated at the production rate that best fulfills the purpose of the test.The individual conducting the emission test shall describe the procedures used to obtain accurate process data and include in the test report the average production rates determined during each testing period. 4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after sample collection unless otherwise specified in the specific conditions.The owner or operator may request an extension to submit the final test report.The Director shall approve an extension request if he finds that the extension request is a result of actions beyond the control of the owner or operator. a. The Director shall make the final determination regarding any testing procedure deviation and the validity of the compliance test.The Director may: i. Allow deviations from a method specified under a rule in this Section if the owner or operator of thesource being tested demonstrates to the satisfaction of the Director that the specified method is inappropriate for the source being tested. iL Prescribe alternate test procedures on an individual basis when he finds that the alternative methodis necessary to secure more reliable test data. iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test method is specified in this Section if the methods can be demonstrated to determine compliance of permittedemission sources or pollutants- b. The Director may authorize the Division of Air Quality to conduct independent tests of any source subject to a rule in this Subchapter to determine the compliance status of that source or to verify any test data submitted relating to that source.Any test conducted by the Division of Air Quality using the appropriate testing procedures described in Section 02D.2600 has precedence over all other tests. Permit No.n''"a� §—T 03735T49 Page 65 KK.Reopenina for Cause[15A NCAC 02Q.0517] 1. A permit shall be reopened and revised under the following circumstances: a. additional applicable requirements become applicable to a facility with remainingpermit term ofthree or more years; b. additional requirements(including excess emission requirements)become applicable to a source covered by Title IV; c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions ofthe permit;or d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the applicable requirements. 2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is promulgated.No reopening is required ifthe effective date ofthe requirement is after the expiration ofthe permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q.0513(c). 3. Except for the state-enforceable only portion ofthe permit,the procedures set out in 15A NCAC 02Q.0507_0521,or .0522 shall be followed to reissue the permit.If the State-enforceable only portion of the permit is reopened,the procedures in 15A NCAC 02Q.0300 shall be followed.The proceedings shall affect only those parts ofthe permit for which cause to reopen exists. 4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,except in cases of imminent threat to public health or safety the notification period may be less than 60 days. 5. Within 90 days,or 180 days if the EPA extends the response period,after receiving notification from the EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the EPA a proposed determination oftermination,modification,or revocation and reissuance,as appropriate. LL.Re ortin Requirements for Non-Orteratinig Ectuipment[15A NCAC 02Q.0508(i)(16)] The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from and placed into operation.When permitted equipment is not in operation,the requirements for testing,monitoring,and recordkeeping are suspended until operation resumes. MM.Fugitive Dust Control Re uirement[15A NCAC 02D.0540] As required by 15A NCAC 02D.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 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 Part 60,Appendix A),the owner or operator maybe required to submit a fugitive dust plan as described in 02D.0540(f). "Fugitive dust emissions"means particulate matter from process operations 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). NN.Specific Permit Modifications[15A NCAC 02Q.0501 and.0523] 1. For modifications made pursuant to 15A NCAC 02Q.0501(b)(2),the Permittee shall file a Title V Air Quality Permit Application for the air emission source(s)and associated air pollution control device(s)on or before 12 months after commencing operation. 2. For modifications made pursuant to 15A NCAC 02Q.0501(c)(2),the Permittee shall not begin operation ofthe air emission source(s)and associated air pollution control device(s)until a Title V Air Quality Permit Application is filed and a construction and operation permit following the procedures of Section.0500(except for Rule.0504 of this Section)is obtained. 3. For modifications made pursuant to 502(b)(10),in accordance with 15A NCAC 02Q.0523(a)(1)(C),the Permittee shall notify the Director and EPA(EPA-Air Planning Branch,61 Forsyth Street SW,Atlanta,GA 30303)in writing at least seven days before the change is made.The written notification shall include: a. a description ofthe change at the facility; b. the date on which the change will occur; c. any change in emissions;and d. any permit term or condition that is no longer applicable as a result of the change. In addition to this notification requirement,with the next significant modification or Air Quality Permit renewal,the Permittee shall submit a page"ES"ofthe application forms signed by the responsible official verifying thatthe Permit No.m-r�rn v 03735T49 Page 66 application for the 502(b)(10)changelmodification,is true,accurate,and complete.Further note that modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstruction requirements. 00.Third Part-Participation and EPA Review[15A NCAC 02Q.0521,.0522 and.0525(7)] For permits modifications subject to 45-day review by the federal Enviromnental Protection Agency (EPA), EPA's decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party petition, the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit.The time period available to submit a public petition pursuant to 15A NCAC 02Q.0518 begins at the end of the 45-day EPA review period. Permit No.03735-48 03735T49 Page 67 ATTACHMENT List of Acronyms :des n i.e...,a.:..e n..e_.,.:..g c,.,...,...:,. BACT Best Available GaFAi:E)1:Feehaa1an, Btu British thermal unit CAA Clean Air Act CAIR Clean n� F rn..erstate RH4e CEM Continuous Emission Monitor CFR Code of Federal Regulations DAQ Division of Air Quality DEQ Department of Environmental Quality EMC Environmental Management Commission EPA Environmental Protection Agency FR Federal Register GACT Generally Available Control Technology HAP Hazardous Air Pollutant MALT Maximum Achievable Control Technology NAA Non-Attainment Area NCAC North Carolina Administrative Code NCGS North Carolina General Statutes NESHAP National Emission Standards for Hazardous Air Pollutants NOx Nitrogen Oxides NSPS New Source Performance Standard OAH Office of Administrative Hearings PM Particulate Matter PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less PSD Prevention of Significant Deterioration PACT Reasonably Available Control Technology RNIP Risk Management Plan SIC Standard Industrial Classification SIP State Implementation Plan SOz Sulfur Dioxide tpy Tons Per Year VOC Volatile Organic Compound APPENDIX C CAM PLAN The business of sustainability ERM Compliance Assurance Monitoring Plan for the Lime Silo (ID No. NS-R1) Emissions Unit Description: Lime Silo—NS-R2 Control Device Description: Pulse Jet Baghouse—NCD-R1 Applicable Regulation: 15A NCAC 02D .0515 Regulated Pollutant: Particulate Matter Emission Limitation: E=4.10 x P 0.11 where: E=allowable particulate emission rate in pounds per hour P=process weight rate in tons per hour Indicator 1 Indicator 2 I. Indicator Operating Parameter: Visible Operating Parameter: Inspection and Emissions Maintenance Pr ram Measurement Approach Visible emissions from the baghouse Monthly visual inspection of the system will be monitored to evaluate for the ductwork and material collection unit for presence of visible emissions. If leaks and annual internal inspection of visible emissions are present, baghouse's structural integrity Chemours will determine visible emissions by conducting a Method 9 opacity reading for 12 minutes. II.Indicator Range Indicator Level: Any visible Indicator Level: An excursion is identified emissions will trigger a 12 minute as failure to conduct the monthly or Method 9 evaluation. Opacity annual inspections. readings greater than 20%opacity will be an excursion. QIP Threshold: Excursions below the indicator range for no more than 3 days during the semi-annual report period. III. Performance Criteria a. Data Representativeness Measurements will be taken at the Baghouses and associated ductwork will emission release point(exhaust of be inspected visually for signs of the baghouse). deterioration. b. QA/QC Practices and The certified observer will perform Maintenance, or other qualified personnel, Criteria any Method 9 evaluations, if will perform inspection and baghouse required. maintenance. c. Monitoring Frequency Data Collection Procedures: The Data Collection Procedures: Monthly visible emission observation will be visual inspection and annual internal conducted once per day when silo inspection. The results will be maintained loading is occurring. The results will in a logbook. be maintained in a logbook. Averaging Period: Not applicable. Averaging Period: Not applicable. The business of sustainability ER APPENDIX D EMISSION CALCULATIONS FOR I-RICE-05 The business of sustainability ER GAS&DIESEL INTERNAL COMBUSTION ENGINES EMISSIONS CALCULATOR REVISION S 6/2212015-OUTPUT SCREEN Instructions: Enter emission source I facility data on the"INPUT tab/screen.The air emission results and summary of input data are viewed/printed on the"OUTPUT"tablscreen. The different tabs are on the bottom of this screen. This spreadsheet is for your use only and should be used with caution.DENR does not guarantee the accuracy of the information contained. NCDEPIR This spreadsheet is subject to continual revision and updating. It is your responsibility to be aware of the most current information available. DENR is not responsible for errors or omissions that may be contained herein. SOURCE/FACILITY!USER INPUT SUMMARY FROM INPUT SCREEN COMPANY: The Chemours Company FC,LLC FACILITY ID NO.: 900009 PERMIT NUMBER: 03735T48 EMISSION SOURCE DESCRIPTION: 540 HP POWER OUTPUT,DIESEL INTERNAL COMBUSTION ENGINE FACILITY CITY: Fayetteville EMISSION SOURCE ID NO.: I-RICE-05 FACILITY COUNTY: Cumberland SPREADSHEET PREPARED BY: KME POLLUTANT CONTROL EFF ACTUAL THROUGHPUT 500 HRS OF OPERATION FUEL HEATING VALUE: 1400D0 BTU/GAL PM 0 REQUESTED ANNUAL LIMITATION 500 HRS OF OPERATION CALCULATIONS: 0.1381 mm BTU/GAL PM10 0 SULFUR CONTENT OF DIESEL FUEL(%) 1 01 PM2.5 0 METHOD USED TO COMPUTE ACTUAL GHG EMISSIONS: TIER 1: DEFAULT HIGH HEAT VALUE AND DEFAULT EF S02 0 CARBON CONTENT USED FOR GHGS(kg C/gal): CARBON CONTENT NOT USED FOR CALCULATION TIER CHOSEN NOX 0 CO 0 VOC 0 CRITERIAAIR POLLUTANT EMISSIONS INFORMATION ACTUAL EMISSIONS POTENTIALEMISSIONS EMISSION FACTOR IPFTER WNTR045ILMTS) (BEFORE CONTRpL$,LMT$) (AFnINCONTROLSA)MITS) b1hp-hr AIR POLLUTANT EMITTED Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yr uncontrolled PARTICULATE MATTER(PM? 1.19 0.30 1.19 5.20 1.19 0.30 2.20E-03 PARTICULATE MATTER<10 MICRONS(PM,o) 1.19 0.30 1.19 5.20 1.19 0.30 2.20E-03 PARTICULATE MATTER<2.5 MICRONS(PMZ.$) 1.19 0.30 1.19 5.20 1.19 0.30 2.20E-03 SULFUR DIOXIDE;SO2) 0.66 0.16 0.66 2.87 0.66 0.16 121E-03 NITROGEN OXIDES NOx 16.74 4.19 16.74 73.32 16.74 4.19 3.10E-02 CARBON MONOXIDE(COJ 3.61 0.90 3.61 15.80 3.61 0.90 6.68E-03 VOLATILE ORGANIC COMPOUNDS(VOC) 1 1.36 1 0.34 1.36 5.95 1.36 0.34 2.51 E-03 TOXIC/HAZARDOUS AIR POLLUTANT EMISSIONS INFORK477ON ACTUAL EMISSIONS POTENTIAL EMISSIONS EMISSION FACTOR CAS (NFTERCONTMO LIMITS) (BEFMECIXlTROLSIUMITS) (-MOONTRQS&IMITS) Ib/hp-hr TOXIC I HAZARDOUS AIR POLLUTANT NUMBER Ib/hr Ib/yr Ib/hr Ib/yr Iblhr Ib/yr Rantrmled Acetaldehyde H, 75070 2.90E-03 1.45E+00 2.9CE-03 2.54E+01 2.90E-03 1.45E+00 5.37E-06 Acrolein H,71 107028 3.50E-04 1.75E-01 3.50E-04 3.06E+00 3.50E-04 1.75E-01 6.48E-07 Arsenic unlisted compounds[H,T) ASC-Other 1.51E-05 7.56E-03 1.51E-05 1.32E-01 1.51E-05 7.56E-03 2.80E-08 Benzene(H,T) 71432 3.53E-03 1.76E+00 3.53E-03 3.09E+01 3.53E-03 1.76E+00 6.53E-06 Benno a) rene H,t 50328 7.11E-07 3.55E-04 7.11E-07 6.23E-03 7.11E-07 3.55E-04 1.32E-09 Beryllium metal unreacted H, 7440417 1.13E-05 5.67E-03 1.13E-05 9.93E-02 1.13E-05 5.67E-03 2.10E-08 1,3-Butadiens(H,T) 106990 1.48E-04 7.39E-02 1.48E-04 1.29E+00 1.48E-04 7.39E-02 2.74E-07 Cadmium metal elemental unreacted)(H, 7440439 1.13E-05 5.67E-03 1.13E-05 9.93E-02 1.13E-05 5.67E-03 2.10E-08 Chromic Acid(VI)(H,T) 7738945 1.13E-05 5.67E-03 1.13E-05 9.93E-02 1.13E-05 5.67E-03 2.10E-08 Fornaldehyde(H,T) 50000 4.46E-03 2.23E+00 4.46E-03 3.91E+01 4.46E-03 2.23E+00 8.26E-06 Lead unlisted compounds(H) PB60ther 3.40E-05 1.70E-02 3.40E-05 2.98E-01 3.40E-05 I 1.70E-02 6.30E-C8 Manganese unlisted compounds H, MNC-Other 2.27E-05 1.13E-02 2.27E-05 1.99E-01 2.27E-05 1.13E-02 4.20E-08 Mercury va or(H,T) 7439976 1.13E-05 5.67E-03 1.13E-05 9.93E-02 1.13E-05 5.67E-03 2.10E-08 Na thalene lH) 91203 3.21E-04 1.60E-01 321E-04 2.81E+00 3.21E-04 1.60E-01 5.94E-07 Nickel metal(H,T) 7440020 1.13E-05 5.67E-03 1.13E-05 9.93E-02 1.13E-05 5.67E-03 2.10E-08 Selenium compounds(H SEC 5.67E-05 2.84E-02 5.67E-05 4.97E-01 5.67E-05 2.84E-02 '..05E-07 Toluene(H,T, 108883 1.55E-03 7.73E-01 1.55E-03 1.35E+01 7.55E-03 7.73E-01 2.86E-06 X lene(H,T) 1330207 1.08E-03 5.39E-01 1.08E-03 9.44E+00 1.08E-03 5.39E-01 2.00E-06 Highest HAP(Formaldehyde) 50000 4.46E-03 2.23E+00 4.46E-03 3.91E+01 4.46E-03 2.23E+00 8.26E-06 Total HAPs 1.45E-02 7.26E+00 1.45E-02 127E+02 1.45E-02 7.26E+00 TOXIC AIR POLLUTANT EM/SS/0NS INFORMATION FOR PERMITTING PURPOSE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS I LIMITATIONS EMISSION FACTOR Ib/hp-hr TOXIC AIR POLLUTANT CAS Num. Ib/hr lb/day lb r uncontrolled Acetaldehyde H, 75070 2.90E-03 6.96E-02 1.45E+00 5.37E-06 Acrolein H, 107028 3.50E-04 8.39E-03 1.75E-01 6.46E-07 Arsenic unlisted compounds(H,Ty ASC-Other 1.51E-05 3.63E-04 7.56E-03 2.80E-08 Benzene(H, 71432 3.53E-03 8.46E-02 1.76E+00 6.53E-06 Senzol a)pyrene(H,T) 50328 7.11E-07 1.71E-05 3.55E-04 1.32E-09 Beryllium metal(unreacted)(H,T) 7440417 1.13E-05 2.72E-04 5.67E-03 2.10E-C8 1,3-Butadiene H,T 106990 1.48E-04 3.55E-03 7.39E-02 2.74E-07 Cadmium metal(elemental unreacted)(H, 7440439 1.13E-05 2.72E-04 5.67E-03 2.10E-08 soluble chromate compounds,as chromium tVII equivalent SOLCR6 1.13E-05 2.72E-04 5.67E-03 2.10E-08 Formaldehyde(H,T) 50000 4.46E-03 1.07E-01 2.23E+00 8.26E-06 Manganese unlisted compounds H,T) MNC-Other 2.27E-05 5.44E-04 1.13E-02 4.20E-08 Mercury vapor I H, 7439976 1.13E-05 2.72E-04 5.67E-03 2.10E-08 Nickel metal(H,T) 7440020 1.13E-05 2.72E-04 5.67E-03 2.10E-08 Toluene(H,T) 108883 1.55E-03 3.71E-02 7.73E-01 2.86E-06 X lene I H,. 1330207 1.08E-03 2.59E-02 5.39E-01 2.00E-06 GREENHOUSE GAS EMISSIONS INFORMATION(FOR EMISSIONS INVENTORY PURPOSES)-CONSISTENT WITH EPA GHG-POTENTIAL TO EMIT MANDATORYREPORT/NG RULE(MRR)METHOD NOT BASED ON EPA Ili METHOD DISTILLATE#2 ACTUAL EMISSIONS I POTENTIAL EMISSIONS-utilize max heat input - Capacity or horsepower and EPA MRR Emission Requested Emission Limitation-utilize Factors requested fuel limit and EPA MRR GREENHOUSE GAS EMITTED WILL NOT USE EPA MRR METHOD IF ONLY HOURS OF OPERATION ARE GIVEN Emission Factors metric tonstyr metric tons/r,CO2e short tonstyr short tons/r short tonstyr,CO2e short tons r short tons/r,CO2e CARBON DIOXIDE(COO no EPA method no EPA method no EPA method 2.699.58 2,699.58 154.09 154.09 METHANE(CH,) no EPA method no EPA method no EPA method 1.10E-01 2.74E+00 6.25E-03 1.56E-01 NITROUS OXIDE(N20) no EPA method no EPA method no EPA method 2.19E-02 6.53E+00 1.25E-03 3.73E-01 TOTAL no EPA method TOTAL 2,708.85 TOTAL 154.61 NOTE: CO2e means CO2 equivalent. NOTE: The DAQ Air Emissions Reporting Online(AERO)system requires short tons be reported. The EPA MRR requires metric tons be reported. NOTE: Do not use greenhouse gas emission estimates from this spreadsheet for PSD(Prevention of Significant Deterioration)purposes.