AQ_F_1800419_20210414_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Prysmian Cables and Systems USA,LLC
NC Facility ID 1800419
Inspection Report County/FIPS: Catawba/035
Date: 04/14/2021
Facility Data Permit Data
Prysmian Cables and Systems USA,LLC Permit 07334/T29
2512 B Penny Road Issued 12/16/2019
Claremont,NC 28610 Expires 11/30/2024
Lat: 35d 42.1680m Long: 8ld 9.2538m Class/Status Title V
SIC: 3229/Pressed And Blown Glass,Nec Permit Status Active
NAICS: 327212/Other Pressed and Blown Glass and Glassware Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Rick Miller Steve Linden Glenn Peterson MACT Part 63: Subpart DDDDD, Subpart ZZZZ
Environmental Safety Plant Manager Fiber Plant Director
Manager [phone]
[phone]
Compliance Data
Comments:
Inspection Date 04/14/2021
Inspector's Name Karyn Kurek
Inspector's Signature: xG� Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature:April 15,2021 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2019 10.25 0.6700 237.48 35.22 2.94 10.16 21474.84
2018 8.73 0.6500 242.81 32.43 2.61 8.73 23652.00
2017 7.38 0.5528 218.18 20.70 1.62 7.38 7884.00
*Highest HAP Emitted(inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
Date Test Results Test Method(s) Source(s)Tested
03/23/2021 Pending
03/05/2020 Compliance Method 7E ES-9, ES-9a

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Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 04/15/2021 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked IBEAM Complaint
_X_IBEAM Planning,Next Inspection Date 04/01/2022
Directions: Take I-77 to I-40 West. Take exit 135 and turn right/south into Claremont on North Oxford
Street. Turn right on Main Street/US 70 and after about '/z mile turn left onto Penny Drive. Turn on
Frazier Dr. Take first right; go to the back of the facility for entrance. The entrance is not where the
visitor parking is located, from the visitor parking area you must walk down a hill to the lower section of
the building. There are secure turn styles and you will need to call your contact upon arrival for access to
the facility.
Follow directions below on your arrival to the site please call Rick Miller(828)459 8668 or me(828-578-3128)
11�
i
Li
PRYSMIAN FIBER E
2512 Penny Rd
Claremont,NC 28610
Dan—828-578-3128
Directions to Prysmian's Claremont Fiber Plant(we have multiple facilities onsite)Will meet at ENTRANCE
We are exit 135 off Rt 40 and Penny Rd from Rt 70
https://www.google.com/ma ps/place/2512+Penny+Rd,+Claremont,+NC+28610

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Page 3
Safety Equipment: Safety glasses and safety shoes are required. A lab coat is required in some areas and
will be provided by the facility. A hard hat may be required if entering construction areas.
Safety Issues: None noted.
Lat/Long Coordinates: A review of the facility's coordinates on DAQ's"Facilities Regulated by Air
Quality"website indicates the facility latitude and longitude coordinates are not listed; however,the
location appears to be accurate.No changes to the latitude and longitude coordinates of this facility in
IBEAM are needed.
Email Contacts: The facility contact information was reviewed with no changes needed.
Covid-19 Information
The facility is allowing both on-site and virtual inspections to be conducted. For the on-site inspections,
the facility requires the inspector to complete a health questionnaire,wear a face covering and maintain
the required social distancing of 6 feet. The facility currently has face covering, social distancing and
hand washing precautions in place for all employees and visitors. I conducted a virtual MS TEAMS
inspection of the permitted sources,a records request via email and drove by the facility to inspect for
odors and visible emissions.
On Monday,April 5,2021,I emailed Mr. Steve Linden,Plant Manager,to coordinate a virtual inspection
via MS TEAMS, an associated records request and informed the facility I would be performing a visual
inspection of the sources from my vehicle after completion of the virtual portion of the inspection. The
requested records were received via email April 9,2021 from Mr.Miller. The MS TEAMS meeting was
conducted Wednesday,April 14,20201 at 10:30 AM with the drive-by source inspection completed April
14,2021 at 1:52 PM.
Before conducting the drive-by source inspection,I completed the NC Employee Screening for
Employees Reporting Onsite form on the oshr.nc.gov web site. Based on my responses to the questions in
this form,I was able to proceed with this portion of the inspection.
1. General Information. The purpose of this MS TEAMS meeting and site visit was to conduct a full
compliance evaluation. This facility manufactures glass fibers and fiber optic cable. This facility
operates the fiber optic cable plant with four shifts,24 hours per day, seven days per week, 51 weeks
per year, and employs about 520 people.

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rysmian Cable and Systems USA,LLC
April 14,2021
Page
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2. File Review.
A. Contacts: The facility contact information was reviewed with no changes needed.
B. Files: The following files were reviewed prior to the inspection: previous inspection reports;
correspondence since the last inspection; semiannual, and annual reports; complaints; stack test
results, annual emissions inventories, etc.
C. Compliance HistM: A Notice of Deficiency was issued on September 10,2015 for late
submission of a stack test report. A stack test was conducted on April 15,2015 and the report
was to be submitted 30 days after the stack test. However,the report was not received until
September 8,2015.
D. Operating Conditions established by Stack Testing:
The permittee was required to conduct an annual stack test for the over-cladding unit(ID No. ES-
9, 1DS)per Section 2.2.C.l.c.iii of the previous air permit 07334T27 to determine NOx
emissions. The permittee conducted a stack test(Tracking No. 2018-131 ST)on April 3,2018.
The stack test report was received on April 27,2018 and approved on July 25,2018.
The permittee was required to conduct an annual stack test for the over-cladding unit(ID No. ES-
9a,2DS)per Section 2.2.C.1.c.iii of the previous air permit 07334T27 to determine NOx
emissions. The permittee conducted a stack test(Tracking No. 2018-012ST)on February 6,
2018. The stack test report was received on April 27, 2018 and approved on July 25,2018.
The permittee was required to conduct a one-time PM test on the chemical vapor deposition units
(ES-1) and the SiCL4 storage room(ES-18)venting to the scrubber system(3WS)within 180
days of commencement of operations in Section 2.1.A.La.i.A under permit 07334T27. The
facility conducted this required test on February 17,2016,the test results were reviewed and
approved by SSCB on November 10,2016.
In addition,the permittee was required to conduct a one-time HCI, Cl,HF stack test on the
chemical vapor deposition units(ES-1), gas cabinets(ES-4), collapse furnaces (ES 14),chemical
room(ES-11) and the SiCL4 storage room(ES-18)venting to the scrubber system(3WS)within
180 days of commencement of operations. The scrubber(3WS) started operation on August 23,
2015 and the required stack tests(ES-1,ES-11,ES-14,ES-18,ES-4-3WS)were completed on
February 17, 2016(within 180 days). The stack test(ID No. 2016-029ST)report was reviewed
and approved by the SSCB on November 10,2016. Again, stack testing(ID No. 2017-045ST)
was conducted on February 14,2017 and results approved on November 30,2017.
E. Records Required by Title V: During this inspection all records required by the Title V permit
were reviewed.
F. NSPS/NESHAP Review:
A letter was mailed by DAQ to the facility regarding MACT Subpart 6S for Glass Manufacturing.
In a letter received June 10,2008,the Permittee stated the facility is not subject to NESHAP
Subpart 6S since they do not have continuous furnace operations for glass manufacturing.
The facility is not subject to NESHAP Subpart 5H—Miscellaneous Coating Operation because
the facility is an area source for HAPs. NESHAP Subpart 5H only applies to major HAP sources.

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The facility is not subject to NESHAP Subpart 6H—Paint Stripping and Miscellaneous Surface
Coating Operations at Area Sources because the facility does not coat any metal or plastic parts
with paint or inks containing the targeted HAPs.
The facility is not subject to NESHAP Subpart 6J—for Boilers at Area Sources because the
facility's boilers only combust natural gas.
The facility is subject to NESHAP Subpart 4Z. The facility has an existing emergency generator
(ID No. I-EmGen)that is used to have a controlled shut-down if power to the facility is lost. The
facility also has a diesel fire pump(ID No. I-FP). Both generators are considered existing since
they commenced construction in 1985 and 1992.
The facility is not subject to NESHAP 6C since the facility has no gasoline storage tanks.
3. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission
sources and/or control devices listed in Section 2 Paragraph 2.1- Emission Source(s) and
Control Devices(s) Specific Limitations and Conditions were observed during this inspection:
A.
Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
ES-1, Chemical vapor deposition units 3WS Wet scrubber(13,000 acfin)
-Cells 5, 6,and 7 consisting of a variable throat
venturi scrubber(10 to 15
inches water pressure drop)
with greater than 90 gallons
per minute caustic solution
ES-4-3WS Gas cabinets—Cells 5,6, and 7 injection(pH 8 or higher as
determined from source
ES-14 Collapse furnaces -Cells 5, 6, testing)
and 7 Or
ES-11 Chemical Room Wet scrubber(a.k.a. Xerxes;
2WS 11,000 acfm) consisting of a
ES-18 SiC14 Storage Room packed bed countercurrent
scrubber(greater than 120
gal/min caustic solution
injection pH 8 or higher)
installed on a venturi scrubber
(greater than 70 gal/min
caustic solution injection pH
8 or higher)

Prysmian Cable and Systems USA,LLC
April 14,2021
Page
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Chemical Room
SiC14 Storage Room
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Page 9
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2WS (not used/not functional)
3WS
Observed. The chemical vapor deposition units(ES-1)controlled by a wet scrubber(3WS)were
started on August 23,2015. The chemical vapor deposition units (ES-1)use an electromagnetic field
to heat plasma around a glass tube as various chemicals are added to the inner diameter of the glass
tube. The Permittee refers to this process as PCVD. The permittee has two PCVD machines and both
were in operation during the inspection. One unit is located in cell 5 and the second unit is located in
cell 6. The permittee stores bulk SiC14 in the building(ES-18) and emissions are controlled by the wet
scrubber(3WS). Note that the chemical, SiC14, is piped from the SiC14 storage room to the chemical

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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
vapor deposition units(ES-1). As a result, any emissions being vented directly from the SiC14 storage
room to the scrubber(3WS) are the result of any malfunctions or leaks in the storage room and minor
amounts during tank changes. No issues were observed at the time of inspection.
ES-Etch Etching Operations 4WS Wet scrubber(3,254 acfm)
consisting of a packed
scrubber(2.5 to 5.0 inches
water pressure drop)with
greater than 264 gallons per
minute of alkaline solution
injection(pH 10.5)
Observed.This operation was observed not working,the control device 4Ws has not operated since
June 2019.
ES-9 Over-cladding Units—Cell 4 1DS Fabric filter with hydrated
CAM and four Cell 5 units lime injection(30 dry pounds
per hour lime injection or
Or higher as determined by
testing; 9,800 square feet of
filter area or greater)
Ammonia injected catalytic
1 SCR NO,,reduction system(ID
No. 1 SCR space velocity
11,214 hr-')with natural gas-
fired flue gas re-heater(10
million Btu per hour heat
input) and natural gas-fired
ammonia injector dilution air
heater(one million Btu per
hour heat input) installed on
MS

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Page 11
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ES-9

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Prysmian(1808619)MS Teams Vi�wlingiecEon — 0
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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
5Y15TV1 FAN NO. I BAG HOUSE . . - BACHOUSE
INLET FAN NO. 2 &#DOM RAGIDAE BAGIGWE
BAG40USE MIST FEED
SYSTEM
0%
Observed. Overcladding unit(ES-9)was observed in operation with no visible emissions noted at the
time of inspection. The emissions are controlled by the hydrated lime injection dry scrubber fabric
filter system(IDS). The overcladding process consists of silica glass being added to the outside of a
glass rod to increase the diameter on a lathe. An air plasma plume is used to provide heat to the
process. Hydrogen fluoride is produced in the overcladding process and the emissions are controlled
by the hydrated lime injection dry scrubber fabric filter system(IDS). To control HF, lime is fed from
supersacks that are located in the lime feed building and injected into the dry scrubber fabric filter
system. The lime collected at the fabric filter is drained into empty supersacks. Silica particulate from
the process is so fine that without the lime the bags would clog. Selective catalytic NOx reduction
system(I SCR)has never operated,and the facility has no plans to use it but were advised to keep it on
the permit.

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April 14,2021
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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
ES-9a Over-cladding Units-Cell 6, 7, 2DS Fabric filter with hydrated
CAM and remaining Cell 5 units lime injection(ID No. 2DS;
30 dry pounds per hour lime
Or injection or higher as
determined by testing; 9,800
square feet of filter area or
greater)
Ammonia injected catalytic
2SCR NO.reduction system(ID
No. 2SCR; space velocity
11,214 hr-')with natural gas-
fired flue gas re-heater(10
million Btu per hour heat
input) and natural gas-fired
ammonia injector dilution air
heater(one million Btu per
hour heat input)installed on
2DS

Prysmian Cable and Systems USA, LLC
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Page 15
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Page 16
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ES9a

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Page 17
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2DS
Lime Feed, D5
mom':..
Observed. Overcladding unit(ES-9a)was observed in operation with no visible emissions noted at
the time of inpsection. The emissions are controlled by the hydrated lime injection dry scrubber fabric
filter system(2DS). The overcladding process consists of silica glass being added to the outside of a
glass rod to increase the diameter on a lathe. An air plasma plume is used to provide heat to the
process. Hydrogen fluoride is produced in the overcladding process and the emissions are controlled
by the hydrated lime injection dry scrubber fabric filter system(2DS). To control HF,lime is fed from
supersacks that are located in the lime feed building and injected into the dry scrubber fabric filter
system. The lime collected at the fabric filter is drained into empty supersacks. Silica particulate from

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Page 18
Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
the process is so fine that without the lime the bags would clog. Selective catalytic NOx reduction
system(2SCR)has never operated,and the facility has no plans to use it but were advised to keep it on
the permit.
ES-boilerl One natural gas-fired boiler(8.0 N/A N/A
MACT million Btu per hour)
DDDDD
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- F 5
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Observed. This source was previously listed under the insignificant sources;this was moved to a
permitted source with the issuance of T29. The unit was observed in operation,no issues were noted
at the time of inspection.

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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
ES-boiler2 One natural gas-fired boiler(8.0 N/A N/A
MACT million Btu per hour)
DDDDD
Y
ix
Observed. This source was previously listed under the insignificant sources;this was moved to a
permitted source with the issuance of T29. This unit was in operation,no issues were noted at the time
of inspection.
ES-boiler3 One natural gas-fired boiler N/A N/A
MACT (8.76 million Btu per hour)
DDDDD

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April 14, 2021
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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
�1+1
d
y.
Observed. This source was previously listed under the insignificant sources; this was moved to a
permitted source with the issuance of T29. This unit was not in operation,no issues were noted at the
time of inspection.
ES-boiler4 One natural gas-fired boiler N/A N/A
MACT (8.76 million Btu per hour)
DDDDD

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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
Observed. This source was previously listed under the insignificant sources;this was moved to a
permitted source with the issuance of T29. This unit was in operation with no issues were noted at the
time of inspection.
ES-WB-3 One hot water boiler(8.0 million N/A N/A
MACT Btu per hour)
DDDDD

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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
a
Observed. This source was previously listed under the insignificant sources;this was moved to a
permitted source with the issuance of T29. This unit was in operation,no issues were noted at the time
of inspection.
ES-SB One steam boiler(2.1 million N/A N/A
MACT Btu per hour)
DDDDD

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Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
AL
1 .
TI�A
STEAM
Bryan Steam LLC — Since 1916
Observed. This source was previously listed under the insignificant sources; this was moved to a
permitted source with the issuance of T29. This unit was not in operation,no issues were noted at the
time of inspection.

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Page 24
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
a.
Emission Emission Source Control Control Device
Source Description Device Description
ID No. ID No.
ES-1, Chemical vapor 3WS Wet scrubber(13,000
deposition units- acfin)consisting of a
Cells 5, 6, and 7 variable throat venturi
scrubber(10 to 15 inches
ES-18 water pressure drop)with
SiC14 Storage Room greater than 90 gallons per
minute caustic solution
injection(pH 8 or higher
as determined from source
Or testing)
2WS Wet scrubber(a.k.a.
Xerxes; 11,000 acfm)
consisting of a packed bed
countercurrent scrubber
(greater than 120 gal/min
caustic solution injection
pH 8 or higher)installed
on a venturi scrubber
(greater than 70 gal/min
caustic solution injection
pH 8 or higher)
Emissions of particulate matter from this source(ID No.ES-1)shall not exceed an allowable emission
rate as calculated by the following equation:
E=4.10 X pO.67
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Observed.This was determined in compliance during the most recent permit review process for
T29,Dec. 16,2019. Compliance is indicated.
Testing If emissions testing is required,the testing shall be perfonned in accordance with General
Condition JJ.
Monitoring Particulate matter emissions from the chemical vapor deposition units(ID No.ES-1)
shall be controlled by the wet scrubber system(ID No. 3WS or 2WS). The Permittee shall establish
an inspection and maintenance schedule/checklist based on manufacturer's recommendations.The

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 25
permittee shall conduct internal inspections of the wet scrubber systems(3WS and 2WS)at least
quarterly. The inspection shall include inspection of the:
- Spray nozzles
- Packing material
- Chemical feed system
- Cleaning and calibration of all associated instrumentation
For wet scrubber ID No. 3WS,the permittee shall monitor the following parameters each shift:
- Recycle liquid flow rates(>90 gpm),
- Liquid make up flow rates (> 1 gpm),
- pH of recirculation tank scrubbing solution(pH of 8 or higher as determined from source
testing)and,
- pressure drop across scrubber(10 to 15 inches of H2O),
For wet scrubber ID No. 2WS,the permittee shall monitor the following parameters each shift:
- Recycle liquid flow rates(> 120 gpm for the packed bed scrubber portion AND>70 gpm
for the venturi scrubber portion),
- Liquid make up flow rates (4- 14 gpm each scrubber portion),
- pH of recirculation tank scrubbing solution(pH of 8 or higher)and,
- pressure drop across scrubber(0.5—4.0 inches of H2O for the packed bed scrubber portion
and 8- 14 inches of water for the venturi scrubber portion),
The results of the monitoring shall be maintained in a logbook. The permittee shall
submit a summary report of the monitoring activities semi-annually.
a
3WS

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Page 26
e
3WS readings
do
3WS liquid makeup
Observed. Scrubber 2WS is not functional and not in use. The scrubber(3WS) started operating
on August 23,2015. During the inspection the following parameters were observed for 3WS.
o recycle liquid— 102.9 gpm
o liquid make-up—5.0 gpm
o pH—8.6
o OP— 11.2 "water

Prysmian Cable and Systems USA,LLC
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Page 27
The logbook was reviewed,and all observations were made.No deviations were noted. The SiC14
storage room(ES-18)is used to store SiC14 in bulk but the room is currently under construction
and is not operational. Currently, SiCL4 is being stored in smaller quantities (canisters)in the
chemical room(ES-11). The permittee performs quarterly internal inspections of the scrubber.
The most recent inspection was conducted on March 18,2021. The required semi-annual
summary reports were received on January 29,2021 and July 30,2020. Compliance with this
stipulation is indicated.
b. Overcladding Units(ES-9 and ES-9a)
Testing If emissions testing is required,the testing shall be performed in accordance with
General Condition JJ.
Monitoring,Recordkeeping, and Reporting:
The Permittee shall ensure the proper performance of the lime injection/fabric filter system(ID
Nos. IDS and 2DS)by monitoring and recording the following operating parameters at least once
per shift:
(A)Lime injection rate(minimum 30 dry pounds per hour)and
(B) Pressure drop across the fabric filter(0.1 to 9 inches of water).
The above records shall be maintained in a logbook.
The Permittee shall perform, at a minimum, monthly visual inspections of the ductwork and
material collection unit for leaks; and an annual (for each 12 month period following the initial
inspection) internal inspection of the bagfilter's structural integrity. The results of inspection and
maintenance shall be maintained in a logbook. The permittee shall submit a summary report of
the monitoring and recordkeeping activities semi-annually.
Lime Feed # 1 DS
IDS Lime Feed Reading

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Page 28
Lime Feed
IC
7 �wi
i
2DS Lime Feed Reading
2DS Control Reading
Observed. Overcladding unit(ES-9)was observed operating during the inspection. The unit
was started,and source tested on April 3,2018. The permit requires monthly visual
inspections,however,the facility conducts weekly visible inspections for leaks in the
ductwork and collection units. Weekly visual inspection records were reviewed and no issues
noted. Logs were reviewed and once per shift the bagfilter delta P and lime injected rate are
recorded. The required semi-annual summary reports were received on January 29, 2021 and
July 30,2020. Compliance with this stipulation is indicated.

Prysmian Cable and Systems USA,LLC
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Page 29
The overcladding unit(ES-9a)was observed operating during this inspection. The permit
requires monthly visual inspections,however,the facility conducts weekly visible inspections
for leaks in the ductwork and collection units. Weekly visual inspection records were
reviewed and no issues noted. Logs were reviewed and once per shift the bagfilter delta P and
lime injected rate are recorded. The required semi-annual summary reports were received on
January 29,2021 and July 30, 2020.Compliance with this stipulation is indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
a. Chemical Vapor Deposition Units(ID No.ES-1) and Over-cladding Units(ID No.ES-9&
ES 9a)
Monitoring Visible emissions shall not be more than 20 percent opacity when averaged over a six-
minute period.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
The Permittee shall observe the emissions points to reestablish normal within 30 days-of the
operation of each additional CVD lathe.
To assure compliance,once a week(each week of the calendar year period)the permittee shall
observe the emission points for the sources listed below for any visible emissions above normal. 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 permittee shall submit a summary report of the monitoring and recordkeeping activities semi-
annually.
Observed. The chemical vapor deposition units(ES-1)and the overcladding units(ES-9a and
ES-9)were in operation during the inspection with no visible emissions. The permittee conducts
daily visible emission observations for these sources and records the findings. No deviations
were noted. The required semi-annual summary reports were received on January 29,2021 and
July 30,2020. Compliance with this stipulation is indicated.

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Page 30
B.
Emission Emission Source Control Control Device Description
Source Description Device
ID No. ID No.
ES-9 Over-cladding IDS Fabric filter with hydrated lime injection(30
CAM Units—Cell 4 and dry pounds per hour lime injection or higher
four Cell 5 units as determined by testing; 9,800 square feet of
filter area or greater)
Or
Ammonia injected catalytic NO,,reduction
I SCR system(ID No. I SCR space velocity 11,214
hr 1)with natural gas-fired flue gas re-heater
(10 million Btu per hour heat input) and
natural gas-fired ammonia injector dilution
air heater(one million Btu per hour heat
in ut)installed on IDS
ES-9a Over-cladding 2DS Fabric filter with hydrated lime injection
CAM Units -Cell 6, 7, (ID No. 2DS; 30 dry pounds per hour lime
and remaining injection or higher as determined by testing;
Cell 5 units Or 9,800 square feet of filter area or greater)
Ammonia injected catalytic NO,,reduction
2SCR system(ID No. 2SCR; space velocity 11,214
hr 1)with natural gas-fired flue gas re-heater
(10 million Btu per hour heat input) and
natural gas-fired ammonia injector dilution
air heater(one million Btu per hour heat
input)installed on 2DS
1. 15A NCAC 2D .0516: Sulfur Dioxide Emissions from Combustion Sources. Emissions of sulfur
dioxide from these source groups shall not exceed 2.3 lbshrmBtu heat input. There are no monitoring
or reporting requirements.
Observed. Compliance with this stipulation was determined during the permit renewal process.
Compliance with this stipulation is indicated.

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C.
Emission Emission Source Control Control Device Description
Source Description Device
ID No. I ID No.
ES-Etch Etching 4WS Wet scrubber(3,254 acfrn)consisting of a
Operations packed scrubber(2.5 to 5.0 inches water
pressure drop)with greater than 264 gallons
per minute of alkaline solution injection
(pH 10.5)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable
Pollutant Regulation
Toxic Air C12,HCI,HF,NH3 15A NCAC 02D
Pollutants See Section 2.2 C.Multiple Emissions Sources .1100
Observed.The facility is tracking TAPs on a monthly basis and a 12-month rolling basis to ensure
compliance. The below table illustrates TAPS data through February 2021. The total through
February 2021 was 1.429 tons. Compliance with this stipulation is indicated.
Pollutant 12-month
Rolling(tpy)
Chlorine 1.21
HCl 0.081
Hydrogen Fluoride 0.128
Acrylic Acid 0.003
Methanol 0.003
Glycol Ether Acrylate 0.000
Toluene 0.004
D.
Emission Emission Source Control Control Device Description
Source Description Device
ID No. ID No.
ES-boilerl One natural gas- N/A N/A
MACT fired boiler(8.0
DDDDD million Btu per
hour)
ES-boiler2 One natural gas- N/A N/A
MALT fired boiler(8.0
DDDDD million Btu per
hour)

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Emission Emission Source Control Control Device Description
Source Description Device
ID No. ID No.
ES-boiler3 One natural gas- N/A N/A
MACT fired boiler(8.76
DDDDD million Btu per
hour)
ES-boiler4 One natural gas- N/A N/A
MALT fired boiler(8.76
DDDDD million Btu per
hour)
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT EXCHANGERS
Emissions of particulate matter from the combustion of natural gas discharged from these sources(ID
Nos.ES-boilerl through ES-boiler4)into the atmosphere shall not exceed 0.40 pounds per million Btu
heat input.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Conditions JJ.
Monitoring,Recordkeeping,and Reporting Requirements No monitoring,recordkeeping,or
reporting is required.
Observed.Compliance was determined during the permit renewal process.Compliance with this
stipulation is indicated.
2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from these boilers(ID Nos. ES-boilerl through ES-boiler4) shall not
exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfixr in
fuels,wastes,ores, and other substances shall be included when determining compliance with this
standard.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping,and Reporting Requirements No monitoring,recordkeeping,or
reporting is required for sulfur dioxide emissions from the firing of natural gas in these sources(ID
Nos.ES-boilerl through ES-boiler4).
Observed.Compliance was determined during the permit renewal process. Compliance with this
stipulation is indicated.
3. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these boilers(ID Nos.ES-boilerl through ES-boiler4) 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.

Prysmian Cable and Systems USA,LLC
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Page 33
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping,and Reporting No monitoring,recordkeeping,or reporting is
required for visible emissions from the firing of natural gas in these sources(ID Nos. ES-boilerl
through ES-boiler4).
Observed.No visible emissions were observed at the time of inspection. Compliance with this
stipulation is indicated.
4. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
For these sources (ID Nos. ES-boilerl through ES-boiler4) (existing sources(s) designed to burn
gas I fuels with a heat input capacity greater than or equal to 5 million Btu per hour and less than
10 million Btu per hour),the Permittee shall comply with all applicable provisions,including the
monitoring,recordkeeping, and reporting contained in Environmental Management Commission
Standard 15A NCAC 02D .1111 "Maximum Achievable Control Technology" (MACT) 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."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.
The Permittee shall complete the initial tune up and the one-time energy assessment no later than
March 18,2022. (i.e, March 18, 2019 plus three years)
The Permittee shall submit a Notification of Compliance Status to the DAQ. The notification must
be signed by a responsible official and submitted by May 17, 2022.
Work Practice Standards
The Permittee shall conduct a tune-up every two years while burning the type of fuel(or fuels in
case of units that routinely burn a mixture)that provided the majority of the heat input to the
boiler or process heater over the 12 months prior to the tune-up,as specified below.
• As applicable,inspect the burner, and clean or replace any components of the burner as
necessary(the Permittee may perform the burn inspection any time prior to the tune-up or
delay the burner inspection until the next scheduled unit shutdown.
• 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;
• Inspect the system controlling the air-to-fuel ratio,as applicable, and ensure that it is
correctly calibrated and functioning properly(you may delay the inspection until the next
scheduled unit shutdown);
• Optimize total emissions of carbon monoxide. This optimization should be consistent with
the manufacturer's specifications,if available, and with any NOx requirement to which the
unit is subject; and
• 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

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 34
and after the adjustments are made). Measurements may be taken using a portable CO
analyzer.
Each biennial tune-up shall be conducted no more than 25 months after the previous tune-up. If
the unit is not operating on the required date for a tune-up,the tune-up must be conducted within
30 calendar days of startup.
Energy Assessment Requirements
The Permittee shall have a one-time energy assessment performed by a qualified energy assessor.
Recordkeeping Requirements The Permittee shall keep a copy of each notification and report
submitted to comply with this subpart,including all documentation supporting any Initial
Notification or Notification of Compliance Status, or compliance report that has been submitted.
Maintain on-site and submit, if requested by the Administrator, an annual report containing the
information in paragraphs(A)through(C)below:
(A)the concentrations of carbon monoxide in the effluent stream in parts per million by
volume, and oxygen in volume percent,measured at high fire or typical operating load,
before and after the tune-up of the source;
(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 annual adjustment,but
only if the unit was physically and legally capable of using more than one type of fuel
during that period. Units sharing a fuel meter may estimate the fuel use by each unit.
Reporting Requirements The Permittee shall submit compliance reports to the DAQ on a 2-year
basis. The first report shall cover the period beginning on the March 18,2022 and ending on
December 31,2023. Subsequent 2-year reports shall cover the periods from January 1 to
December 31. The Permittee shall submit the compliance reports postmarked on or before
January 30 for the preceding reporting period. The compliance report must also be submitted
electronically via the Compliance and Emissions Data Reporting Interface(CEDRI). CEDRI can
be accessed through the EPA's Central Data Exchange(CDX) (https:Hcdx.epa.gov/).)
Observed.These sources were moved from the insignificant list to the permitted source list with
the issuance of T29. The first energy assessments are due March 18,2022. The Notification of
Compliance Status is due May 17, 2022. Tune-ups are due every 2 years. Tune ups were
performed for Boilers 1,2,3 &4 on Nov. 5,2020. Reporting is due March 18,2022. Compliance
with this stipulation is indicated.
E. One natural gas-fired hot water boiler(ID No. ES-WB-3)
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT
EXCHANGERS
Emissions of particulate matter from the combustion of natural gas discharged from this source(ID
No.ES-WB-3)into the atmosphere shall not exceed 0.40 pounds per million Btu heat input.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Conditions JJ.
Monitoring,Recordkeeping,and Reporting Requirements No monitoring,recordkeeping,or
reporting is required for particulate emissions from the firing of natural gas in this source(ID No.
ES-WB-3).

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 35
Observed.Compliance was determined during the permit renewal process. Compliance with this
stipulation is indicated.
2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from boiler(ID No.ES-WB-3)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.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping, and Reporting Requirements No monitoring,recordkeeping,
or reporting is required for sulfur dioxide emissions from the firing of natural gas in this source(ID
No.ES-WB-3).
Observed.Compliance was determined during the permit renewal process. Compliance with this
stipulation is indicated.
3. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from this boiler(ID No.ES-WB-3) 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.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping,and Reporting No monitoring,recordkeeping,or reporting is
required for visible emissions from the firing of natural gas in this source(ID Nos. ES-WB-3).
Observed.This unit was in operation,no visible emissions were observed at the time of inspection.
Compliance with this stipulation is indicated.
4. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
For this source(ID Nos. ES-WB-3) (i.e., new source, units designed to burn gas 1 fuels with a
heat input capacity equal to or greater than SMMBtu/hr and less than 10 MMBtu/hr, with no
autotrim),the Permittee shall comply with all applicable provisions,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."
Compliance Date The Permittee shall comply with the applicable requirements upon startup of
this source.

Prysmian Cable and Systems USA,LLC
April 14, 2021
Page 36
Notifications The Permittee shall submit an Initial Notification to the DAQ not later than 15 days
after the actual date of startup of the affected source. The Permittee shall submit a Notification of
Compliance Status to the DAQ within 60 days of startup and signed by a responsible official.
Work Practice Standards The Permittee shall conduct a tune-up every 2 years while burning the
type of fuel(or fuels in case of units that routinely burn a mixture)that provided the majority of
the heat input to the boiler or process heater over the 12 months prior to the tune-up, as specified
below:
• as applicable,inspect the burner, and clean or replace any components of the burner as
necessary. The Permittee may perform the burner inspection any time prior to the tune-up or
delay the burner inspection until the next scheduled unit shutdown.
• 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;
• inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly(the Permittee may delay the inspection until the next
scheduled unit shutdown).
• optimize total emissions of CO. This optimization should be consistent with the
manufacturer's specifications, if available, and with any NOX requirement to which the unit
is subject.
• measure the concentrations in the effluent stream of CO in parts per million,by volume, and
oxygenin 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.
Each 2-year tune-up shall be conducted no more than 25 months after the previous tune-up. The
initial tune-up shall be conducted no later than 25 months after the initial startup of the source. If
the unit is not operating on the required date for a tune-up,the tune-up must be conducted within
30 calendar days of startup.
Recordkeeping Requirements The Permittee shall keep a copy of each notification and report
submitted to comply with this subpart,including all documentation supporting any Initial
Notification or Notification of Compliance Status or compliance report that has been submitted,
maintain on-site and submit, if requested by the Administrator,a report containing the information
in paragraphs below:
• the concentrations of CO in the effluent stream in parts per million by volume, and oxygen in
volume percent,measured at high fire or typical operating load,before and after the tune-up of
the boiler or process heater;
• a description of any corrective actions taken as a part of the tune-up; and
• the type and amount of fuel used over the 12 months prior to the tune-up,but only if the unit
was physically and legally capable of using more than one type of fuel during that period.
Units sharing a fuel meter may estimate the fuel use by each unit.
Reporting Requirements The Permittee shall submit compliance reports to the DAQ on a 2-year
basis. The first report shall cover the period beginning on the compliance date specified in Section
2.1 E.4.d(i.e., start-up)of the permit and ending on the earliest December 31st less than two years
from the compliance date. Subsequent 2-year reports shall cover the periods from January 1 to
December 31. The Permittee shall submit the compliance reports postmarked on or before January
30. The compliance report must also be submitted electronically via the Compliance and

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 37
Emissions Data Reporting Interface(CEDRI). CEDRI can be accessed through the EPA's Central
Data Exchange(CDX) (https:Hcdx.epa.gov/).)
Observed.This source is an existing source that was moved from the insignificant list to the
permitted source list with the issuance of T29. Tune-ups are due every 2 years. A tune up was
performed on Nov. 4, 2020. Reporting is due March 18,2022. Compliance with this stipulation is
indicated.
F. One natural gas-fired steam boiler(ID No.ES-SB)
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT
EXCHANGERS
Emissions of particulate matter from the combustion of natural gas discharged from this source(ID
No. ES-SB)into the atmosphere shall not exceed 0.40 pounds per million Btu heat input.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Conditions JJ.
Monitoring,Recordkeeping,and Reporting Requirements No monitoring,recordkeeping,or
reporting is required for particulate emissions from the firing of natural gas in this source(ID No.ES-
SB).
Observed.Compliance was determined during the permit renewal process.Compliance with this
stipulation is indicated.
2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from boiler(ID No. ES-SB)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.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping,and Reporting Requirements No monitoring,recordkeeping,or
reporting is required for sulfur dioxide emissions from the firing of natural gas in this source(ID No.
ES-SB).
Observed.Compliance was determined during the permit renewal process. Compliance with this
stipulation is indicated.
3. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from this boiler(ID No. ES-SB)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.
Testing If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring,Recordkeeping,and Reporting No monitoring,recordkeeping,or reporting is required
for visible emissions from the firing of natural gas in this source(ID Nos. ES-SB).

Prysmian Cable and Systems USA,LLC
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Page 38
Observed.This unit was not in operation,therefore,no visible emissions were observed at the time of
inspection. Compliance with this stipulation is indicated.
4. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
For this steam boiler(ID Nos. ES-SB) (i.e., new source, units designed to burn gas I fuels with a
heat input capacity less than 5MMBtu/hr, with no autotrim),the Permittee shall comply with all
applicable provisions,including the monitoring,recordkeeping, and reporting contained in
Environmental Management Commission Standard 15A NCAC 02D .I I I I "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."
The Permittee shall submit an Initial Notification to the DAQ not later than 15 days after the actual
date of startup of the affected source. The Permittee shall submit an initial Notification of
Compliance Status to the DAQ within 60 days of startup and signed by a responsible official.
Work Practice Standards The Permittee shall conduct a tune-up every 5 years while burning the
type of fuel(or fuels in case of units that routinely burn a mixture)that provided the majority of
the heat input to the boiler or process heater over the 12 months prior to the tune-up, as specified
below:
• as applicable, inspect the burner, and clean or replace any components of the burner as
necessary. The Permittee may perform the burner inspection any time prior to the tune-up or
delay the burner inspection until the next scheduled or unscheduled shutdown but the burner
must be inspected at least once every 72 months.
• 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;
• inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly(you may delay the inspection until the next scheduled unit
shutdown).
• optimize total emissions of CO. This optimization should be consistent with the manufacturer's
specifications, if available,and with any NOX requirement to which the unit is subject.
• measure the concentrations in the effluent stream of CO 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.
Each 5-year tune-up shall be conducted no more than 61 months after the previous tune-up. The
initial tune-up shall be conducted no later than 61 months after the initial startup of the source. If
the unit is not operating on the required date for a tune-up,the tune-up must be conducted within
30 calendar days of startup.
Recordkeeping Requirements The Permittee shall keep a copy of each notification and report
submitted to comply with this subpart,including all documentation supporting any Initial
Notification or Notification of Compliance Status or compliance report that has been submitted,
maintain on-site and submit, if requested by the Administrator,a report containing the information
in paragraphs below:

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 39
• the concentrations of CO in the effluent stream in parts per million by volume, and oxygen in
volume percent,measured at high fire or typical operating load,before and after the tune-up
of the boiler or process heater;
• a description of any corrective actions taken as a part of the tune-up; and
• the type and amount of fuel used over the 12 months prior to the tune-up,but only if the unit
was physically and legally capable of using more than one type of fuel during that period.
Units sharing a fuel meter may estimate the fuel use by each unit.
Reporting The Permittee shall submit compliance reports to the DAQ on a 5-year basis. The first
report shall cover the period beginning on the compliance date specified in Section 2.1 FAA(i.e.,
start-up) and ending on the earliest December 3Pt within five years from the compliance date.
Subsequent 5-year reports shall cover the periods from January 1 to December 31. The Permittee
shall submit the compliance reports postmarked on or before January 30. The compliance report
must also be submitted electronically via the Compliance and Emissions Data Reporting Interface
(CEDRI). CEDRI can be accessed through the EPA's Central Data Exchange(CDX)
(https://cdx.epa.govo.)
Observed.This source is an existing source that was moved from the insignificant list to the
permitted source list with the issuance of T29. Tune-ups are due every 2 years. Previous energy
assessment was Nov. 7,2019. Reporting is due March 18,2022. Compliance with this stipulation
is indicated.
4. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources and/or
control devices listed in Section 2 Paragraph 2.2-Multiple Emission Source(s) Specific Limitations and
Conditions were observed during this inspection:
A. Over-cladding Units (ID No.ES-9, excluding cell 5 units).
Insignificant Sources
Two natural gas-fired hot water boilers (ID Nos.I-WB-1 and I-WB-2);
One waste water sludge dryer(ID No.I-SD-1);
One diesel-fired fire pump (ID No. I-FP);
One parts washer(ID No.I-PW); and
Multiple roof top air handling units (ID No.I-AHU)
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 02D. 0530: PREVENTION
OF SIGNIFICANT DETERIORATION
Total emissions of nitrogen oxides from equipment in Cells 1,2, 3,and 4 and two boilers shall be
less than 250 tons per consecutive 12-month period.
To ensure compliance with the above emissions limits, nitrogen oxides from Over-cladding Units
contained in Cells 4(ID No. ES-9,excluding cell 5 units) shall be controlled by:
i. A fabric filter with hydrated lime injection(ID No. IDS),or
ii. A fabric filter with hydrated lime injection(ID No. IDS)in series with a selective catalytic
NOx reduction system(ID No. 1 SCR).
Testing Requirements

Prysmian Cable and Systems USA,LLC
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Page 40
Over-cladding Units
i. Uncontrolled NOx emissions from individual small and large torch Over-cladding Units (Cells
4;ID No.ES-9)shall be tested to determine emission rates in pounds of NOx per unit-hour to be
used in demonstrating compliance with the PSD avoidance condition.
ii. Uncontrolled over-cladding emission rates must be revalidated annually by May 30 of each
calendar year.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if uncontrolled NOx
emissions from these sources are not tested and validated as provided above.
Dry Scrubber System(Lime Injection and Fabric Filter)
i. NOx emissions from Over-cladding Units(Cells 4; ID No.ES-9) shall be tested prior to the dry
scrubber control (ID No. IDS) to determine the dry scrubber uncontrolled NOx rate used in
demonstrating compliance with the PSD avoidance condition.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if NOx emissions from
these sources are not tested and validated as provided above.
SCR System
i. NOx emissions from Over-cladding Units(Cells 4;ID No.ES-9)shall be tested prior to and after
the SCR control (ID No. 1 SCR)to validate the data generated by the continuous NO and NO2
emission analyzers. The control efficiency calculated from the test and the analyzers at the time
of the test shall be within 5%to validate the analyzers.
ii. Initial validation test results for SCR control efficiency must be submitted to the Regional
Supervisor,DAQ,within 120 days(or alternate date approved by DAQ)of SCR(ID No. 1 SCR)
startup.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if NOx emissions from
these sources are not tested as provided above.
General
Emissions testing is required. The testing shall be performed in accordance with General Condition
JJ found in Section 3.
Monitoring and Recordkeeping Requirements
Continuous NO and NO2 emission analyzers shall be installed upstream and downstream of the SCR
(ID No. 1 SCR) to monitor emissions from the Over-cladding Units (ID No. ES-9) venting to and
from the selective catalytic NOx reduction system(ID No. 1 SCR).
i.Analyzers shall be calibrated daily.
ii. Measurements of NO and NO2 shall be recorded after calibration at the inlet and outlet
monitors.
iii.NO and NO2 concentrations at the inlet shall be summed and NO and NO2 concentrations
at the outlet shall be summed for the determination of a daily control efficiency.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if NOx emissions are
not monitored as provided above.
Calculation of monthly NOx emissions shall be made at the end of each month. Facility-wide NOx
emissions shall be determined by adding emissions from the insignificant sources using AP-42
emission factors,and the Over-cladding Units in Cells 4(ID No.ES 9)including dry scrubber NOx
emission rate,and the SCR control efficiency for periods when the SCR system was used. Calculation
of NOx emissions using test data from(ID No.ES 9)shall be performed as follows:

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 41
i. NOx emissions from Over-cladding Units in Cells 4 (ID No. ES-9) shall be determined by
multiplying operating hours for each over-cladding unit group type by the pounds of NOx
per unit-hour determined from source testing. The number of operating hours for small and
large torch groups shall be a separate record. Emissions of NOx shall be calculated using the
uncontrolled emission rate demonstrated in the most recent stack test(B) Any higher
emission rate demonstrated by a stack test.
ii. NOx emissions from Over-cladding Units in Cells 4 (ID No. ES-9) shall be determined by
multiplying operating hours for each over-cladding unit group type by the pounds of NOx
per unit-hour determined from source testing. The number of operating hours for small and
large torch groups shall be a separate record. Emissions of NOx shall be calculated using the
uncontrolled emission rate demonstrated in the most recent stack test.
Inclusion of SCR Emissions Reductions
(A) Calculation of NOx emissions may include SCR emissions reductions during SCR operating
periods. The daily control efficiency determined in accordance with 2.2A.I.e. shall be used
to reduce the amount of uncontrolled emissions calculated per 2.2.A.l.c.ii on a daily basis.
1. If a daily measurement is not available during a period that the SCR is operational, the
last available measurement shall be used in place of the missing data provided that the
missing data does not exceed more than 25%of the data for any one-month period.
2. If a daily measurement is not available during a period that the SCR is operational, and
the missing data exceeds more than 25%of the data for any one-month period,no control
efficiency shall be assumed for that day.
3. Inspection and Maintenance Requirements-To comply with the provisions of this permit
and ensure that emissions do not exceed the regulatory limits, the Permittee shall
establish an inspection and maintenance(I&M)schedule/checklist for the SCR based on
manufacturer's recommendations. As a minimum, the I&M program will include an
annual inspection of the burners,catalyst,the catalyst housing,and associated ducting to
ensure structural integrity.
Operating hours for the SCR, Over-cladding Units, SCR control efficiency calculations, NOx
emission calculations, inspection/calibration/maintenance of the NOx analyzers, inspection and
maintenance of the SCR, and the total monthly amount of NOx emissions must be recorded in an
emissions log. The Permittee shall make the log available to officials of the DAQ upon request.
The emissions log must be kept on file for a minimum of five years. The Permittee shall be deemed
in noncompliance with 15A NCAC 02D .0530 if records are not maintained.
Reporting Requirements
Submit a semiannual 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. Monthly NOx emissions for each of the previous 17 calendar months; and,
ii. 12-month rolling NOx emissions for each consecutive 12-month period ending in the
previous six months.
Observed.Per Mr.Miller,the selective catalytic NOx reduction systems(I SCR and 2SCR)have
never operated and the facility has no plans to use them. The facility's permit lists it as an
alternate control to the fabric filter(IDS);the fabric filter is used to control these sources.
The testing requirements are outlined below. The facility is tracking the required ES-9 data,
through the end of March 2021,the hours of operation were 4,570 hours,total NOx 13,927.7
pounds and the 12-month rolling NOx was 78.62 tons. The required semi-annual summary

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 42
reports were received on January 29,2021 and July 30,2020.Compliance with this stipulation is
indicated.
Source Test Requirement Date of test
Cells 4 & ES9 Uncontrolled over-cladding emission Most recent test performed March
rates validation(by Mar 30 of each 6,2020 approved by SSCB
year) October 20,2020 and March 23,
2021 with SSCB approval still
pending.
IDS Control efficiency annually AND each Most recent test performed March
Dry Scrubber time filter material changed 6,2020 approved by SSCB
(lime injection October 20,2020 and March 23,
and fabric filter) 2021 with SSCB approval still
pending.
ISCR Initial validation test for SCR control Per the facility,the SCR control
SCR control efficiency within 120 days of startup system has never operated,and is
system for ES-9 (one-time test) not physically connected.
Previous testing was conducted
for uncontrolled NOx emissions,
initially the intent was believed to
be to determine if the dry
scrubber had NOx control
efficiency;however, data was
inconsistent with showing a NOx
control, so the facility uses the
uncontrolled NOx testing value in
their reporting. IBEAM
documents shows the test
protocol went to SSCB 12/22/17,
the test protocol approved by
SSCB on Feb. 2,2018,test
conducted Apr. 3,2018,test
results approved by SSCB July
25, 2018.
B. Cells 5, 6, and 7 Equipment consisting of-
Over-cladding Units (ID No.ES-9a and cell 5 units in ES-9).
Two 8.0 million Btu per hour heat input natural gas-fired boilers;
Two 10.0 million Btu per hour SCR flue gas re-heaters; and,
Two 1.0 million Btu per hour SCR ammonia injector dilution air heaters.
1. 15A NCAC 2Q .0317: Avoidance of 2D.0530 Prevention of Significant Deterioration.
The nitrogen oxides emissions increase due to equipment operation shall be less than 250 tons per
consecutive 12-month period.
To ensure compliance with the above emissions limits, nitrogen oxides from Over-cladding Units
contained in Cells 5, 6,and 7 shall be controlled by:
i. A fabric filter with hydrated lime injection(ID No.2DS),or

Prysmian Cable and Systems USA,LLC
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Page 43
ii. A fabric filter with hydrated lime injection(ID No.2DS)in series with a selective catalytic NOx
reduction system(ID No.2SCR).
Testing Requirements
New Technology Over-cladding Units
NOx uncontrolled emissions from individual new technology torch Over-cladding Units (Cells 5, 6,
and 7,ES-9a)shall be tested and results submitted within 120 days from startup to determine emission
rates in pounds of NOx per unit-hour to be used in demonstrating compliance with the PSD avoidance
condition.Uncontrolled over-cladding emission rates must be revalidated annually.
Dry Scrubber System(Lime Injection and Fabric Filter)
NOx emissions from Over-cladding Units (Cells 5, 6, 7; ID No. ES-9a) prior to the dry scrubber
control(ID Nos.2DS)shall be tested and results submitted within 120 days from startup to determine
dry scrubber control emission rate to be used in demonstrating compliance with the PSD avoidance
condition.
SCR System
NOx emissions from Over-cladding Units (Cells 5, 6, 7; ID No. ES-9a) shall be tested prior to and
after the SCR controls(ID Nos.2SCR)to validate the data generated by the continuous NO and NO2
emission analyzers. The control efficiency calculated from the test and the analyzers at the time of
the test shall be within 5%to validate the analyzers. Initial validation test results for SCR control
efficiency must be submitted to the Regional Supervisor,within 120 days(or alternate date approved
by DAQ)of SCR(ID Nos. 2SCR)startup.
General
Emissions testing is required. The testing shall be performed in accordance with General Condition
JJ found in Section 3 of the permit.
Monitoring and Recordkeeping Requirements
Continuous NO and NO2 emission analyzers shall be installed upstream and downstream of each
SCR(ID Nos. 2SCR)to monitor emissions from the Over-cladding Units(ID No.ES-9a)venting to
and from each selective catalytic NOx reduction system(ID Nos. 2SCR).
i. Analyzers shall be calibrated daily.
ii. Measurements of NO and NO2 shall be recorded after calibration at the inlet and outlet
monitors.
iii. NO and NO2 concentrations at the inlet shall be summed and NO and NO2 concentrations
at the outlet shall be summed for the determination of a daily control efficiency.
Calculation of monthly NOx emissions shall be made at the end of each month. Calculation of NOx
emissions may include SCR emissions reductions during SCR operating periods.
To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory
limits,the Permittee shall establish an inspection and maintenance(I&M) schedule/checklist for the
SCRs based on manufacturer's recommendations. As a minimum,the I&M program will include an
annual inspection of the burners, catalyst, the catalyst housing, and associated ducting to ensure
structural integrity.
Operating hours for the SCR, Over-cladding Units, SCR control efficiency calculations, NOx
emission calculations, inspection/calibration/maintenance of the NOx analyzers, inspection and
maintenance of the SCRs, and the total monthly amount of NOx emissions must be recorded in an
emissions log.

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Page 44
Reporting Requirements
Submit a semiannual 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. Monthly NOx emissions for each of the previous 17 calendar months; and,
ii. 12-month rolling NOx emissions for each consecutive 12-month period ending in the
previous six months.
Observed.Per Mr.Miller,the selective catalytic NOx reduction systems(I SCR and 2SCR)have
never operated and the facility does not plan to use them. The facility's permit lists it as an
alternate control to the fabric filter(1DS); the fabric filter is used to control these sources.
The facility is tracking the required data,through the end of March 2021,the hours of operation
were 13,336.0 hours,total NOx 33,153.3 pounds and the 12-month rolling NOx was 179.85 tons.
The testing requirements are outlined below. The required semi-annual summary reports were
received on January 29,2021 and July 30,2020. Compliance with this stipulation is indicated.
Source Test Requirement Date of test
Cells 5,6,and NOx uncontrolled emissions shall be tested Testing protocol was
7,ES-9a with and results submitted within 120 days from approved by SSCB on Dec.
dry scrubber st�to determine emission rates in 3,2007,testing was
control(ID Nos. pounds of NOx per unit-hour to be used in performed Dec. 20,2007 and
2DS) demonstrating compliance with the PSD again June 2,2008,the June
avoidance condition and to determine dry 2,2008 testing was reviewed
scrubber control efficiency. (one-time test) and approved by SSCB on
Jan. 21,2009
Cells 5,6,and NOx uncontrolled over-cladding emission Most recent test performed
7,ES-9a with rates and dry scrubber control efficiency March 6,2020 approved by
dry scrubber must be revalidated annually. SSCB October 20,2020 and
control(ID Nos. March 23,2021 with SSCB
2DS) approval still pending.
C. Chemical Vapor Deposition Units (ID No. ES-1),
Gas Cabinets (ID No.ES-4), and Collapse Furnaces (ID No. ES-14) consisting of:
Cells 5, 6, and 7 with Wet Scrubber(ID No.3WS); and,
Over-cladding Units (ID No.ES-9) consisting of:
Cells 4, and some cell 5 units venting to Hydrated Lime Injection Dry Scrubber Fabric
Filter System (ID No. IDS) that vents to a Selective Catalytic NOx Reduction System
(ID No. 1SCR).
Over-cladding Units (ID No.ES-9a) consisting of:
Cells 6,7,and remaining cell 5 units venting to Hydrated Lime Injection Dry Scrubber
Fabric Filter System (ID No. 2DS) that vents to a Selective Catalytic NOx Reduction
System(ID No.2SCR); and,
Chemical Room(ID No.ES-11)with Wet Scrubber System(ID No.3WS); and,
SiC14 Storage Room (ID No. 18)with Wet Scrubber System (ID No.3WS).
Etching Operations(ID No.ES-Etch)equipped with a Wet Scrubber System(ID No.4WS)

Prysmian Cable and Systems USA,LLC
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The following provides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulation
STATE-ONLY REQUIREMENT
Emissions of HCI, C12,HF,and NH3 must be emitted
at or below the emission rates tabulated in the next
table in order to comply with the following
acceptable ambient levels.
Toxic Air Pollutants HCl: 0.7 milligrams/cubic meter- lhr
15A NCAC 02D .1100
C12: 0.9 milligrams/cubic meter- 1 hr and
0.0375 milligrams/cubic meter-24 hr
HF: 0.25 milligrams/cubic meter- 1 hr
0.03 milligrams/cubic meter-24 hr
NH3: 2.7 milligrams/cubic meter- Ihr
1. STATE-ONLY REQUIREMENT
15A NCAC 2D .1100: Toxic Air Pollutant Emissions. The permittee shall comply with the
following toxic emission limits:
Affected Sources Pollutant Emission Limit
EP-11: Wet Scrubber#1 (ID No.3WS)
Envirocare#1 Hydrogen Chloride 9.063 lb/hr
Includes emission from:
Cells 5, 6,and 7 CVD (ID Nos.ES-1) Chlorine 5.5821b/hr; and, 133.97 lb/day
Cells 5, 6, and 7 GC (ID No.ES-4),
Cells 5, 6 and 7 CF(ID No.ES-14)
Chemical Room(ID No.ES-11)
SiC14 Storage Room(ID No.ES-18)
EP-21 combined stack for SCRs Ammonia 1.584 lb/hr per SCR
EP-11: Wet Scrubber#1 (ID No.3WS)
Envirocare#1
Includes emission from:
Cells 5, 6, and 7 CVD (ID Nos.ES-1)
Cells 5, 6,and 7 GC (ID No.ES-4),
Cells 5, 6 and 7 CF(ID No.ES-14)
Chemical Room(ID No.ES-11)
SiC14 Storage Room(ID No.ES-18) Hydrogen Fluoride 2.67 lb/hr; and, 41.03 lb/day
EP-18: dry scrubber(ID No. IDS) or
EP-21: SCR(ID No. 1SCR)
Cells 4, and some cell 5 OC units(ID No.
ES-9
EP-19: dry scrubber#1 (ID No.2DS) or
EP-21: SCR(ID No. 2SCR)

Prysmian Cable and Systems USA,LLC
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Page 46
Affected Sources Pollutant Emission Limit
Cells 6, 7, and remaining cell 5 OC units
(ID No.ES-9a)
EP-4WS: Wet Scrubber(ID No.4WS)
Includes emission from:
Etching operations(ID No.ES-Etch)
The Permittee has submitted a toxic air polluntant dispersion modeling analysis (March 21, 2018) for the
facility's toxic air pollutant emissions as listed in the above table. The modeling was reviewed and approved
by the AQAB on(April 10,2018). Placement of the emission sources, configuration of the emission points,
and operation of the sources shall be in accordance with the submitted dispersion modeling analysis and
should reflect any changes from the original analysis submittal as outlined in the AQAB review memo.
Emissions from the CVD processes will be controlled by the scrubber(ID No. 3WS or 2WS).
Emissions from the Over-cladding Units (ID Nos. ES-9 and ES-9a) shall be controlled by two fabric filters
each with hydrated lime injection(ID Nos. IDS and 2DS).
General
If emissions testing is required,the testing shall be performed in accordance with General Condition JJ of
the permit.
Monitoring,Recordkeeping and Reporting
Monitoring, recordkeeping, and reporting pertain to inspection and maintenance of control devices and
parametric monitoring to ensure control efficiencies. Continuous emission analyzers for ammonia
emissions from the selective catalytic NOx reduction systems (ID Nos. ISCR and 2SCR) shall be
inspected and maintained in accordance with the manufacturer's recommendations. As a minimum, the
instruments shall be calibrated daily. Records of calibrations,inspections,and maintenance shall be kept
in a logbook and maintained on site. Records shall be made available to the DAQ personnel upon request.
All required records on file for a minimum of two years.
Observed. Overcladding units(ES-9a and ES-9)were in operation and the emissions were being
controlled by the fabric filter with hydrated lime injection(2DS & IDS). Per Mr. Miller,the selective
catalytic NOx reduction systems (1SCR and 2SCR)have never operated and the facility does not plan
to use them. The facility's permit lists it as an alternate control to the fabric filter(IDS);the fabric
filter is used to control these sources. The chemical vapor deposition units (ES-1),gas cabinets(ES-
4), collapse furnaces(ES-14)and the chemical room(ES-11)were in operation and venting emissions
to the wet scrubber(3WS). The remaining sources are not in operation. The permittee provided
electronic records of production and amounts of HCI,CI and HF emitted. Ammonia is not being
emitted by the facility as the selective catalytic reduction systems which uses ammonia have not been
operated nor are anticipated to be operated. The scrubber(ID No. 3WS) started operation on August
23,2015 and the required stack tests(ES-1,ES-11, ES-14, ES-18,ES-4-3WS)were completed on
February 17,2016(within 180 days). The stack test(ID No. 2016-029ST)report was reviewed and
approved by the SSCB on November 10, 2016. Again, stack testing(ID No. 2017-045ST)was
conducted on February 14,2017 and results approved on November 30,2017. Compliance with this
stipulation is indicated.

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5. Part I-AIR QUALITY TITLE V OPERATION PERMIT. 2.3- Compliance Assurance Monitoring
(CAM; 40 CFR Part 64)
A. One Fabric Filter with Hydrated Lime Injection (ID No. IDS)
1. 15A NCAC 02D .0614: Continuous Assurance Monitoring for fabric filter with hydrated lime
injection(ID No. IDS)
The Permittee shall ensure that PM emitted from the Over-cladding Units(ID No. ES-9)is controlled by
a fabric filter(ID No. IDS)by monitoring the Pressure drop across the fabric filter,and the Lime injection
rate.No testing is required. The key elements of the monitoring approach are presented in a table within
the current permit.Pressure drop across the scrubber and water flow rate. An excursion is defined as an
hourly average differential pressure (DP) less than 0.1 inches of water pressure drop or more than 9
inches of water pressure drop. An excursion is defined as an injection rate reading less than 30 pounds
per hour. The permittee must maintain monthly records of the above operating parameters and submit
a semi-annual report.
Observed. Records reviewed indicated that all monitoring is being conducted with no issues noted at
the time of inspection. Annual maintenance on fabric filter (IDS) was conducted on Dec. 4, 2020
(previously Jan. 16, 2019 and January 22, 2018). The required semi-annual summary reports were
received on January 29,2021 and July 30, 2020. Compliance with this stipulation is indicated.
B. One Fabric Filter With Hydrated Lime Injection (ID No. 2DS)
1. 15A NCAC 02D .0614: Continuous Assurance Monitoring for fabric filter with hydrated lime
injection(ID No.2DS)
The Permittee shall ensure that PM emitted from the Over-cladding Units (ID No. ES-9a) is controlled
by a fabric filter (ID No. 2DS) by monitoring the pressure drop across the fabric filter, and the lime
injection rate. No testing is required. The key elements of the monitoring approach are Pressure drop
across the scrubber and water flow rate.An excursion is defined as an hourly average differential pressure
(DP) less than 0.1 inches of water pressure drop or more than 9 inches of water pressure drop. An
excursion is defined as an injection rate reading less than 30 pounds per hour.The Permittee must maintain
all measurements of operating parameters on a monthly basis. The Permittee shall submit a summary
report of all monitoring 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.
Observed. Records reviewed indicated that all monitoring is being conducted with no issues noted at
the time of inspection. Annual internal maintenance on fabric filter(213S) was conducted on Dec. 4,
2020(previously Sept. 13,2019 and Sept. 27,2018.) The required semi-annual summary reports were
received on January 29,2021 and July 30, 2020. Compliance with this stipulation is indicated.
6. Part I-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL CONDITIONS
A. Permit. Maintain a copy of the permit and application at the facility.
Observed. The permit and application are at the facility. Permit 07334T29 was issued December 16,
2019 with an effective date of December 16,2019 and an expiration date of November 30,2024.
Compliance with this stipulation is indicated.

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Page 48
B. Submissions. Except as otherwise specified,two copies of all documents,reports,test data,
monitoring data are required to be submitted to MRO.
Observed. The permittee submits two copies. Compliance with this stipulation is indicated.
C. Circumvention. Operate and maintain the facility at all times in a manner that will affect an overall
reduction in air pollution.
Observed. The facility modifies control operations to meet permit requirements. Compliance with
this stipulation is indicated.
D. Excess Emissions. Report excess emissions and permit deviations as required.
Observed. No deviations have been reported since last inspection. Compliance with this stipulation
is indicated.
E. Retention of Records. 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.
Observed. Records are being maintained. Compliance with this stipulation is indicated.
F. Compliance Certification. By March 1 submit a compliance certification(for the preceding
calendar year).
Observed. Received on Feb. 22,2021. Compliance with this stipulation is indicated.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year.
Observed. The 2020 emission inventory is not due until June 30,2021. The previous emission
inventory report for 2019 was received June 26,2020. Compliance with this stipulation is indicated.
H. Refrigerant Requirements(Stratospheric Ozone and Climate Protection). The facility must dispose
of refrigerants properly.
Observed. The facility has standard air conditioners with R123. Trane representatives service the
refrigerant. Compliance with this stipulation is indicated.
I. Section 112(r).
Observed. This facility does not appear to be subject to the requirements of the Chemical Accident
Release Prevention Program, Section 112(r) of the Clean Air Act. Quantities of hydrogen are kept
below 10,000 pounds. Compliance with this stipulation is indicated.
7. The Following Non-permitted/Insignificant Air Emission Sources and Control Devices were Observed as
Follows:
Emission Source ID Emission Source Description
No. or
I-AHU Multiple roof top air handling units
Observed.These units were not observed during the inspection.
I-ES-15 Collapse process hoods
Observed.The collapse process hoods are used on a few of the older sources and there are also
units known as collapse process lathes which uses a plasma process with the same emissions.
These units were not observed during the inspection.
I-ES-S Prep hoods

Prysmian Cable and Systems USA,LLC
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Page 49
Emission Source ID Emission Source Description
No,
Observed. Glass rods are leveled and handles are placed on the rods. A single natural gas fired
flame is used to heat the rods and add the handles. There are six prep hoods. These units were
not observed during the inspection.
I-ES-13,I-ES-13a, Three central vacuum systems
ES-13b

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 50
Emission Source ID Emission Source Description
Observed.There are only two central vacuum systems and they are used to clean grain from
the over cladding cabinets and fiber strands around the draw towers. The vacuum systems were
in operation during the inspection with no visible emissions.
I-ES-10 Glass saw hoods
Observed.The saw cuts glass rods to meet specific product requirements. These units were not
observed during the inspection.
I-SD-1 Waste water sludge dryer
Observed.This unit was not observed during the inspection. The dryer is natural gas fired and
has a maximum heat input rating of 0.41 mmBtu/hr.
I-ES-7 Draw towers
Observed. Glass rods are placed in the draw tower and heated to produce fiber strands. The
fiber strands go through a series of quality control checks on the draw tower and is also
coated/painted as it goes through the draw tower. The facility has numerous draw towers
(confidential info)in different business units. These units were not observed during the
inspection.
I-Clean Machine cleaning stations with 10 eight-gallon capacity acetone baths
Observed.The cleaning stations are used to clean the dies that manage and paint the fiber
strands in the draw tower. This operation uses charcoal filter traps to retain the volatile acetone.
This activity was not observed.
I-BEL Sixteen Buffering extruder lines
Observed.The glass fibers are twisted and then a plastic coating is applied. The twisting
allows the fibers to bend without breaking. The plastic is extruded onto the fibers then cooled
in chilled water. These units were not observed during the inspection.
I-JEL Eleven Jacketing extruder lines
Observed.After the fibers have been processed through the buffering extruder lines,the
jacketing extruder lines place additional layers of protection around the fibers after coating the
fiber with a plastic coating. The plastic is extruded onto the fibers then cooled in chilled water.
These units were not observed during the inspection.
I-JM Jacket Melters
Observed.Bulk compound is melted(jacket melters) at each jacket line and then the melted
compound goes through the extruders(jacketing extruders—ID No. I-JEL). These units were
not observed during the inspection.
I-FH Eight flame heaters for the jacket extruder lines(0.044 million Btu per
hour each)
Observed.A flame is used to heat the plastic coating around the glass fibers then a product
code is applied with ink to the coating. These units were not observed during the inspection.
I-PL Sixteen printing lines
Observed.Ink is applied to the outer finish of the fiber cable. The process uses a non-VOC ink
that is dried with UV light. The activity was not observed.
I-RL Six ribbon lines
Observed. Glass fibers strands are glued together, flattened and product code information is
applied in ink to the coating. This operation has been removed from the facility and has been
added to the yellowsheet.

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 51
Emission Source ID Emission Source Description
No.
I-FBW Fluidized bed washer
Observed.Parts are placed in a cylinder where sand and water are heated(electric) and injected
to clean the metal parts. A small cyclone is used to capture any particulates. This was not
observed.
I-PW Parts washer
Observed.The parts washers are small washers located near the ribbon line. These units were
not observed during the inspection.
I-Draw Clean Cleaning stations
Observed.These units were not observed during the inspection.
I-WB-1, I-WB-2 Two hot water boilers(0.75 million Btu per hour each)
Observed.These Fulton hot water boilers are labelled as 750 M Btu/hr each. They are
seasonally used for comfort heat. These units were not observed during the inspection.
I-WH-I and I-WH-2 Two domestic water heaters (0.75 million Btu per hour each)
Observed.These large domestic style hot water heaters were not observed. They are rated at
75,100 Btu/hr.
I-ANNEAL Annealing Furnace
Observed.The furnace is used to clean the irradiator tubes used on the draw towers. The
annealing furnace is electric and was not observed during this inspection.
I-CORRAL One natural gas-fired corral lathe(0.10 million Btu per hour)
Observed. Glass rods are leveled on the corral lathe. Multiple natural gas fired flames are used
to heat the rods while it is rotated. The facility no longer uses this equipment.
I-M-1 and I-M-2 Two natural gas-fired munters(2.4 million Btu per hour each)
Observed.These units were not observed during the inspection.
I-FP Diesel-fired fire pump 105 HP
MACT ZZZZ

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 52
Emission Source ID Emission Source Description
No.
is
20
MP
()o
0 Home
Observed.The fire pump is subject to NESHAP Subpart 4Z as an existing engine. The
engine's serial number is 4474811. The permittee conducts annual maintenance on the engine
since the fire pump has never operated more than 500 hours per year. The hour meter reading
during the inspection was 605.3 (previously 580.0 hours). Annual maintenance was conducted
on Dec. 7,2020(previously March 7,2019).
I-CT-601 Fiber Plant 2 cell Cooling Tower
I-CT-701 Fiber Plant 3 cell Cooling Tower
I-CT-702 Fiber Plant 3 cell Cooling Tower
I-CT-801 Fiber Plant 3 cell Cooling Tower
I-CT-1 Cable Plant Cooling Tower

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 53
Emission Source ID Emission Source Description
No.
e
L
� E k
Observed.These cooling towers were added to permit T29. This units were observed with no
issues noted.
8. Other Compliance Requirements and Issues:
None noted.
9. Compliance Assistance:
None.
10. Summary of Changes Needed to the Current Permit:
Selective catalytic NOx reduction system(I SCR and 2SCR)have never operated and should be removed
from the permit. The facility's permit lists it as an alternate control to the fabric filter(1DS); the fabric
filter is used to control these sources.
The air permit identifies the maximum heat input of I-boilerI &I-bioler2 as 8.0 mmBtu/hr; however,the
boiler plate indicates the maximum heat input is 8.3 mmBtu/hr, each and should be corrected on the
permit.
(I-RL) Six ribbon lines. This operation has been removed from the facility and should be removed from
the permit.

Prysmian Cable and Systems USA,LLC
April 14,2021
Page 54
11. Findings.
Based on my observations during this inspection, this facility appeared to be in compliance with the
applicable air quality regulations.
KAK:
cc: MRO Files
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00419/INSPECT 20210414.docx