AQ_F_1800590_20210423_ST_ProtRvw

„,STATE
ROY COOPER
Governor l O
DIONNE DELLI-GATTI
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
April 23,2021
Matt Cohn
Substance Inc.
3000 Frazier Drive
Claremont,North Carolina 28610
Subject: Substance Inc.,Claremont,Catawba County,North Carolina
Facility ID 1800590,Air Quality Permit No. 10649R00
VOC Destruction Efficiency Test Protocol for Adhesive Coating Line ES-1
Submitted by TRC Environmental
Proposed Test Date: April 28,2021, Tracking No.2021-146st
Dear Mr. Cohn:
The North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)
submitted by TRC Environmental. The proposed methods are acceptable to determine the volatile organic
compounds(VOC)from ES-1.Emissions Source ES-I is an adhesive coating application line with a
curing oven controlled by regenerative thermal oxidizer CD-1. 40 CFR 60 Subpart RR Standards of
Performance for Pressure Sensitive Tape and Label Surface Coating Operations applies and limits VOC
emissions to 0.20 kilograms per kilogram of coating solid or requires a 90%reduction of VOC emissions
on a monthly basis. 15A NCAC 2Q .0315 Synthetic Minor Facilities and 15A NCAC 2Q .0317
Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant Deterioration also apply.
TRC proposes EPA Method 25A for VOC emissions concurrently at the inlet and outlet of RTO CD-1.
Molecular weight of the gas stream at the inlet and outlet sampling locations will be assumed to be 29.0
and 30.0,respectively. For the verification of permanent total enclosure(PTE), TRC proposes EPA
Method 204. The proposed test methods are acceptable.
The PSF indicates that the total amount of solvent used during testing will be recorded and the CD-1
temperature will be"recorded manually every 15 minutes during each test run.”The temperature should
be monitored at the beginning and end of each run for a minimum of 5 temperature measurements for
each 60-minute sampling period. The proposed methods are acceptable to determine the CD-1 destruction
efficiency and to verify the enclosure meets the minimum requirements for PTE.
Approval of this sampling protocol does not exempt the tester from the minimum requirements of the
sampling method.Any deviations from the methods remain subject to approval by DAQ. If you have any
questions,please contact me at 919-707-8416 or [e-mail].
Sincerely,
Shannon Vogel,Env' onmental Engineer
Division of Air Quality,NCDEQ
cc: Ilya Alimov,TRC Bruce Ingle,Mooresville Regional Office IBEAM Documents 1800590
QE � North Carolina Department of Environmental Quality I Division of Air Quality
4 217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
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