AQ_F_1800419_20191114_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: 11/14/2019
F_ Facility Data Permit Data
Prysmian Cables and Systems USA,LLC Permit 07334/T28
2512 B Penny Road Issued 3/18/2019
Claremont,NC 28610 Expires 2/28/2024
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)TV-Minor,TV-
Renewal,TV-Minor
Contact Data
Facility Contact Authorized Contact Technical Contact
Program Applicability
Rick Miller Steve Linden Glenn Peterson SIP/Title V
Environmental Safety Plant Manager Fiber Plant Director MACT Part 63: Subpart ZZZZ
Manager [phone]
[phone]
Compliance Data
Comments:
Inspection Date 11/14/2019
Inspector's Name Karyn Kurek
Inspector's Signature: Operating Status Operating
-� Compliance Code Compliance-inspection
Action Code FCE
Date of Signature. _y I On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOc CO PM10 *HAP
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
2016 7.49 0.5200 207.33 . 25.31 1.49 7.47 1500.32'
*Hi hest HAP Emitted in ounds
Five Year Violation History:None
Date Letter Tvpe Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
02/06/2019 Compliance Method 7E ES-9, ES-9a

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Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 11/15/2019 _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 _IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date
11/01/2020
Directions: Take I-77 to 1-40 West. Take exit 135 and turn right/south into Claremont on North Oxford
Street. Turn right on Main Street/US 70 and after about 11/2 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)
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PRYSIVIIAN FIBER _
I 2512 Penny Rd k
Claremont,NC 28611D
Dan-823-578-3128 . - --j•�
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•/Iwww gooale com/maps/place/2512+Penny+Rd+Claremont.+NC+28610
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.

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Page 3
Safety Issues: None noted.
Lat/Long Coordinates: The"Maps of DAQ Regulated Facilities"is unavailable,however a review of
the facility's coordinates on"Maps of DAQ Regulated Facilities" last inspection indicated the facility's
latitude and longitude coordinates were,accurate.
Email Contacts: The facility contact information was reviewed with no changes needed.
1. General Information. The purpose of this 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.
2. 1 arrived at the facility on November 14,2019 at 10:36 AM. Dan Rappaport and Rick Miller,
accompanied me during the inspection.
3. 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 HistorX: 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, IDS)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. 2018-1.31 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.1.a.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

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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.
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.
4. 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.

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Emission Emission Source Description Control Control Device
Source Device Description
ID No. ID No.
ES-1, Chemical vapor deposition units 3WS . Wet scrubber(13,000
CAM -Cells 5, 6, and 7 acfm) consisting of a
variable throat venturi
scrubber(10 to 15 inches
water pressure drop)with
greater than 90 gallons per
ES-4-3WS Gas cabinets—Cells 5, 6, and 7 minute caustic solution
injection(pH 8 or higher
ES-14 Collapse furnaces- Cells 5, 6, as determined from source
and 7 testing)
ES-II Chemical Room
ES-18 SiC14 Storage Room
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
Or injection or higher as
determined by testing;
9,800 square feet of filter
area or greater)
1SCR Ammonia injected
catalytic 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 113S

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Emission Emission Source Description Control Control Device
Source Device Description
ID Wo., 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
Or hour lime injection or
higher as determined by
testing; 9,800 square feet
of filter area or greater)
Ammonia injected
2SCR catalytic NO.reduction
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
Chemical Vapor Deposition Units (ES-1) consisting of Cells 5 6, &7 with gas cabinets(ES-4-
3WS)Collapse Furnaces (ID No. ES-14) Chemical Room(ID No.ES-11) and SiC14 Bulk
Storage Room(ID No. ES-18)venting to Wet Scrubber(ID No. 3WS)
Observed. The chemical vapor deposition units(ES-1) controlled by a wet scrubber(3WS)were
started on August 23, 201.5. 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 PCVC
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 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.
Overcladdin Units nits(ES-9)consisting of: Cells 4 and four Cell 5 units venting to Hydrated Lime
In Dry Scrubber Fabric Filter System(ID No. IDS)venting to Selective Catalytic NOx
Reduction System(ID No. I SCR) '
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

Prysmian Cable and Systems USA, LLC
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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 NO,reduction system(1SCR)has never operated and should be
removed from the permit. The facility's permit lists it as an alternate control to the fabric filter
(IDS);the fabric filter is used to control these sources. This has been added to the yellowsheet.
Overcladding Units(ES-9a)consisting o£ Cells 6. 7, and remaining Cell 5 units venting to
Hydrated Lime Injection Dry Scrubber Fabric Filter System ID No. 2DS venting to Selective
Catalytic NOx Reduction System(ID No. 2SCR)
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 (213S). 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 (213S). 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 NO,reduction system(2SCR)has never operated and should be
removed from the pen-nit. The facility's permit lists it as an alternate control to the fabric filter
(IDS);the fabric filter is used to.control these sources..This has been added to the yellowsheet.
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
CAM deposition units- acfm) consisting of a
Cells 5, 6, and 7 variable throat venturi
scrubber(10 to 15 inches
water pressure drop)with
ES-18 SiC14 Storage Room greater than 90 gallons per
minute caustic solution
injection(pH 8 or higher
as determined from source
testing)
If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.The Permittee shall establish an inspection and maintenance schedule/checklist
based on manufacturer's recommendations.The permittee shall conduct internal
inspections of the wet scrubber system(3WS)at least quarterly. The inspection shall
include inspection of the:
- Spray nozzles
- Packing material
- Chemical feed system
- Cleaning and calibration of all associated instrumentation

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For wet scrubber ID No. 3 WS,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)
- pressure drop across scrubber(10 to 15 inches of H20)
The results of the monitoring shall be maintained in a logbook. The permittee shall
submit a summary report of the monitoring activities semi-annually.
Observed. The scrubber(3WS)started operating on August 23,2015. During the
inspection the following parameters were observed.
o recycle liquid— 110.7 gpm
o liquid make-up—6.0 gpm
o pH—8.5
o OP— 10.9 "water
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
October 4, 2019. The required semi-annual summary reports were received on January
25, 2019'and July 30, 2019. Compliance with this stipulation is indicated.
b. Overcladding Units(ES-9 and ES-9a)
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.
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. The most recent inspection occurred Oct. 4, 2019.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 25, 2019 and July
30,2019. Compliance with this stipulation is indicated.
The overcladding unit(ES-9a)was observed operating during this inspection.The permit
requires monthly visual inspections,however,the facility conducts weekly visible

Prysmian Cable and Systems USA, LLC
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Page 9
inspections for leaks in the ductwork and collection units. The most recent inspection
occurred Oct. 4,2019. 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 25, 2019 and July 30,2019. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
a.
Emission Emission Source Control Device Control Device Description
Source Description ID No.
ID No.
ES-1, Chemical vapor 3WS Wet scrubber(13,000 acfin)
CAM deposition units- consisting of a variable throat
Cells 5, 6, and 7 venturi scrubber(10 to 15 inches
water pressure drop)with greater
ES-4-3WS Gas cabinets— than 90 gallons per minute caustic
Cells 5, 6, and 7 solution injection(pH 8 or higher as
determined from source testing)
ES-14 Collapse furnaces-
Cells 5, 6, and 7
ES-11 Chemical Room
ES-18 SiC14 Storage
Room
ES-9 Over-cladding IDS- Fabric filter with hydrated lime
CAM Units—Cell 4 and injection(30 dry pounds per hour
four Cell 5 units lime injection or higher as
Or determined by testing; 9,800 square
feet of filter area or greater)
1 SCR
Ammonia injected catalytic NO,,
reduction system (ID No. 1 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 input)
installed on IDS

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Emission Emission Source Control Device Control Device Description
Source Description ID No.
ID.No.
ES-9a Over-cladding 2DS Fabric filter with hydrated lime
CAM Units-Cell 6, 7, injection(ID No. 2DS; 30 dry
and remaining Cell pounds per hour lime injection or
5 units Or higher as determined by testing;
9,800 square feet of filter area or
2SCR greater)
Ammonia injected catalytic NO,,
reduction 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
Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute period.
To assure compliance,once a week the permittee shall observe the emission points for the sources
listed below for any visible emissions above normal. The permittee shall submit a summary report
of the monitoring and recordkeeping activities semi-annually.
ES-1 —chemical vapor deposition units(ES-1)
ES-9—overcladding units(ES-9)
ES-9a—overcladding units(ES-9a)
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. The most recent
VE observation occurred Nov. 13,2019.No deviations were noted.The required semi-annual
summary reports were received on January 25, 2019 and July 30, 2019. Compliance with this
stipulation is indicated.
B.

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Page III
Emission Emission Source Control Control Device Description
Source Description` Device
ID No. ID No:r„
ES-9 Over-cladding 113S 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
Or filter area or greater)
1 SCR Ammonia injected catalytic NO.reduction
system(ID No. 1SCR 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 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)
2SCR Ammonia injected catalytic NO.reduction
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 213S
1. 15A NCAC 2D .0516: Sulfur Dioxide Emissions from Combustion Sources. Emissions
of sulfur dioxide from these source groups shall not exceed 2.3 lbs/mmBtu heat input. There
are no monitoring or reporting requirements. Compliance with this stipulation was
determined during the permit application process. Compliance with this stipulation is
indicated.
C.
Emission Emission Source Control, Control Device Description
Source Description Device
ID.No. ID No: ,
ES-Etch Etching 4WS Wet scrubber(3,254 acfin) 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
H 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

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Page 12
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 September 2019.The total through
September 2019 was 15.617 tons. Compliance with this stipulation is indicated.
Pollutant 127month
_�,,Rolling(tpy)
Chlorine 13.22
HCI 0.881
Hydrogen Fluoride 1.345
Acrylic Acid 0.037
Methanol 0.078
Glycol Ether Acrylate 0.001
Toluene 0.051
5. 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).
Two 8.76 million Btu per hour heat input natural gas-fired boilers (insignificant
sources)
Insignificant Sources (0.75 million Btu per hour hot water boilers, sludge dryer, ,
emergency fire pump, emergency generator, parts washer, two 0.129 million Btu per
hour boilers and air handling units)
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. 1SCR).
Testing Requirements
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)

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Page 13
i. NOx emissions from Over-cladding Units(Cells 4;ID No.ES-9)shall be tested prior to and after
the dry scrubber control (ID No. 1DS)to determine the dry scrubber control efficiency used in
demonstrating compliance with the PSD avoidance condition.
ii. Control efficiency of the dry scrubber system(lime injection and fabric filter)must be revalidated
annually and each time the type of filter material is changed unless the Pennittee assumes no
fabric filter control for the purposes of compliance demonstration until further DAQ approved
testing is conducted.
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%S stem
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. 1SCR)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 OD No. 1SCR)
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. 1SCRl to monitor emissions from the Over-cladding Units (ID No. ES-9)venting to
and from the selective catalytic NOx reduction system(ID No. 1SCR).
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
control efficiency, if applicable, 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:
i. NOx emission from CVD process hoods shall be determined by multiplying operating hours
for CVD units during the month by the pounds of NOx per unit-hour determined from source
testing. Calculations shall be performed using the highest of-the following values:
(A) 0.41 pounds of NOx per unit-hour; or, -
(B) Any higher emission rate demonstrated by a stack test. "

Prysmian Cable and Systems USA,LLC
November 14, 2019
Page 14
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,as provided in Section
2.2 A.1 c.
iii. Inclusion of Dry Scrubber Emissions Reductions
(A) Calculation of NOx emissions may include Dry Scrubber emissions reductions using the
control efficiency of the fabric filter measured during source testing for the type of filter
employed at the time of testing.
(B) The control efficiency for the dry scrubber determined by DAQ-approved testing is valid
if:
1. The NOx uncontrolled loading rate to the fabric filter,which occurred during the test
increases by no more than 25 percent,and
2. The lime injection rate is at or above the injection rate measured and recorded during
the performance 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.Le. shall be used
to reduce the amount of uncontrolled emissions calculated per 2.2.A.1.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.

Prysmian Cable and Systems USA,LLC
November 14, 2019
Page 15
Observed. Per Mr.Miller,the selective catalytic NOx reduction systems (1 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(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 September 2019,the hours of operation were 2567.8 hours,total NOx 6383.55
pounds and the 12-month rolling NOx was 30.4 tons. The required semi-annual summary reports
were received on January 25, 2019 and July 30, 2019.Compliance with this stipulation is
indicated.
w'Source` " Test`Re uirement " ,Date of testG::}
Cells 4&ES9 Uncontrolled over-cladding emission Most recent test performed Feb.
rates validation(by Mar 30 of ea year) 6, 2019 and approved by SSCB
2019
IDS Control efficiency annually AND each Most recent test performed Feb.
Dry Scrubber time filter material changed 6, 2019 and approved by SSCB
(lime injection Apr. 22, 2019
and fabric filter
1SCR 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. The facility is
considering having the SCR
control System(both ID.Nos.
1SCR and 2SCR)removed from
the ermit.
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.
The following rovides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulation7l

Prysmian Cable and Systems USA,LLC
November 14, 2019
Page 16
Nitrogen Oxides Total emissions of nitrogen oxides shall be less 15A NCAC 02Q .0317
than 250 tons per consecutive 12-month period. PSD Avoidance
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 (11)No.2DS),or
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 and after the dry
scrubber control (ID Nos.2DS) shall be tested and results submitted within 120 days from startup to
determine dry scrubber control efficiency to be used in demonstrating compliance with the PSD
avoidance condition. Control efficiency of the dry scrubber system (lime injection and fabric filter)
must be revalidated annually and each time the type of filter material is changed unless the Permittee
assumes no fabric filter control for the purposes of compliance demonstration until further DAQ
approved testing is conducted.
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.
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.

Prysmian Cable and Systems USA, LLC
November 14, 2019
Page 17
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.
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 should be removed from the permit. 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 facility is tracking the required ES-9a data,through the end of September 2019,the hours of
operation were 13099.6 hours,total NOx 32565.61 pounds and the 12-month rolling NOx was
198.4 tons. The testing requirements are outlined below. The required semi-annual summary
reports were received on January 25, 2019 and July 30,2019. Compliance with this stipulation is
indicated.
.� Date'of test
'Source ,Test Re uikemenf r Cells 5,6,and NOx uncontrolled emissions shall be tested Testing protocol was
7,ES-9a with and results submitted within 120 da. sy from approved by SSCB on Dec.
dry scrubber startup 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 Feb. 6,2019 and approved
dry scrubber must be revalidated annually. by SSCB Apr. 22, 2019
control(ID Nos.
2DS

Prysmian Cable and Systems USA,LLC
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Page 18
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. 1DS) 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)
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- 1hr
15A NCAC 02D.1100
C12: 0.9 milligrams/cubic meter- 1 hr and
0.0375 milligrams/cubic meter-24 hr
BF: 0.25 milligrams/cubic meter- lhr
0.03 milligrams/cubic meter-24 hr
NH3: 2.7 milligrams/cubic meter- lhr
1. STATE-ONLY REQUIREMENT
15A NC AC 2D .1100: Toxic Air Pollutant Emissions. The permittee shall comply with the
following toxic emission limits:
Affected Sources Pollutant Emission Limit
EP-1 I Wet Scrubber#1 (ID No.3.WS)"
Envirocare#1 Hydrogen Chloride 9.063 lb/hr .
Includes emission from:
Cells 5, 6,and 7 CVD(ID Nos:ES-1) Chlorine 5.582 lb/hr; and, 133.971b/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)
SiCla Storage Room No.ES-18
EP-21 combined stack for SCRs Ammonia 1.5841b/hr per SCR.

Prysmian Cable and Systems USA,LLC
November 14,2019
Page 19
Affected Sources Pollutant Emission Limit
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)
EP-18: dry scrubber(ID No. IDS) or
EP-21: SCR(ID No. 1SCR) ,
Cells 4, and some cell 5 OC units (ID No. Hydrogen Fluoride 2.67 lb/hr; and, 41.03 lb/day
ES-9
EP-19: dry scrubber#1 (ID No.2DS) or
EP-21: SCR(ID No.2SCR)
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)
Emissions from the CVD processes will be controlled by the scrubber(ID No.3WS).
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. 1DS and 2DS).
General
If emissions testing is required,the testing shall be performed in accordance with General Condition
JJ.
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. 1SCR 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 (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 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, Cl and

Prysmian Cable and Systems USA, LLC
November 14, 2019
Page 20
BF 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 due to
cost. The scrubber(ID No. 3WS)started operation on August 23,2015 and the required stack
tests(ES-1,ES-1 1, 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.
6. 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 the following
table. Pressure drop across the scrubber and water flow rate. 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 Jan. 16, 2019
(previously January 26,2017 and January 22,2018). The required semi-annual summary reports were
received on January 25,2019 and July 30, 2019. 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. 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. The observations noted during the inspection are identified in the table above. Annual
internal maintenance on fabric filter(2DS)was conducted on Sept. 13,2019(previously September 27,
2018.) The required semi-annual summary reports were received on January 25, 2019 and July 30,
2019. Compliance with this stipulation is indicated.

Prysmian Cable and Systems USA,LLC
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Page 21
7. Part I-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL CONDITIONS
A. Permit. Maintain a copy of the permit and application afthe facility.
Observed. The permit and application are at the facility. Permit 07334T28 was issued March 18,
2019 with an effective date of March 18, 2019 and an expiration date of February 28,2024.
Compliance with this stipulation is indicated.
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. Submitted on January 25, 2019. Compliance with this stipulation is indicated.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year.
Observed. Submitted on June 24, 2019. 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.
8. The Following Non-permitted/Insignificant Air Emission Sources and Control Devices were Observed as
Follows:
Emission Source ID ';,
No. Emission"Source Description `�
I-AHU Multiple roof top air handling units
Observed.These units were not observed during the inspection.

Prysmian Cable and Systems USA,LLC
November 14,2019
Page 22
-Emission'Source ID
- :
� Emission Source Description
I-boilerl,I-boiler2,I-
boiler3, Four natural gas-fired boilers(two 8.0 million Btu per hour and two
I-boiler4 8.76 million Btu per hour units)
MACT DDDDD
Observed.Boiler 1 was not operating, and Boiler 2 was observed in operation at the time of
inspection with no issues noted. The air permit identifies the maximum heat input of boiler 1 &
2.as 8.76 mmBtu/hr; however,the boiler plate indicates the maximum heat input is 8.3
mmBtu/hr, each.This has been added to the yellowsheet.
Boiler I-boiler3 was observed in operation at the time of inspection with no issues noted and I-
boiler4 was not in operation. The maximum heat input for the two boilers (ID Nos.I-boiler3
and I-boiler4) is 8.0 mmBut/hr, each. Energy assessments have been conducted on all four
boilers with the most recent occurring Nov. 7,2019.
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 were observed in operation at this time of inspection with no issues noted.
I-ES-5 Prep hoods
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 were
observed in operation with no issues noted.
I-ES-13, I-ES-13a, Three central vacuum systems
ES-13b
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.This process was not
in operation at the time of inspection.
I-SD-1 1 Waste water sludge dryer
Observed.The dryer was not in operation at the time of 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 operations were active during the
inspection with no issues noted.
I-Clean Machine cleaning stations with 10 eight-gallon capacity acetone baths

Prysmian Cable and Systems USA,LLC
November 14,2019
Page 23
Emission Source M
v'cNo:` Emission Source pescription
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 I 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. This activity was in operation during the inspection with no issues noted.
I-JEL I 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.
This activity was in operation during the inspection with no issues noted.
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). This activity was
in operation during the inspection with no issues noted.
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. The activity was in operation during the inspection with
no issues noted.
I-PL I 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. There are five ribbon lines in operation. This operation has been
removed from the facility and has been added to the yellowsheet.
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 were observed in operation during the inspection with
no issues noted.
I-WB-3 One hot water boiler(8.0 million Btu per hour)

Prysmian Cable and Systems USA,LLC
November 14, 2019
Page 24
Emission Source ID Emission Source Description
No.
MACT DDDDD
Observed.This unit was observed in operation during the inspection with no issues noted.The
facility conducted a recent energy assessment of this unit on Nov. 7, 2019.
I-SB
-SB DDDDD One steam boiler(2.1 million Btu per hour)
MACTObserved.This unit was observed in operation during the inspection with no issues noted.The
facility conducted a recent energy assessment of this unit on Nov. 7,2019.
I-WH-1 and I-WH-2 I 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 7 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
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 580.0 (previously 556.4 hours for a run time of 23.6 hours). Annual
maintenance was conducted on March 7,2019 (previously March 7,2018).
I-EmGen Diesel-fired emergency generator 150 HP
MACT ZZZZ
Observed.This unit is physically removed from the facility and should be removed from the
permit. This has been added to the yellowsheet.
I'-EmGen2 Diesel-fired emergency generator(1500kW)
NSPS HH
Observed.This generator is owned by Duke Power,the facility is leasing the unit through them
and does not have physical access to the unit. The unit is a certified engine and the certification
is below.David Hughes,permit engineer with RCO,has been notified of this issue.This should
be removed from the permit and has been added to the yellowsheet.

Prysmian Cable and Systems USA, LLC
November 14,2019
Page 25
Emission'Souree ID
No., ° 1 Emission Sour&Des`eription
�,ara..�.
:� r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF TRANSPORTATION
2018 MODEL YEAR AND AIR QUALITY
CERTIFICATE OF N AIR ACT
of e„o•.t`"� WITH THE CLEAN AIR ACT ANN ARBOR,]IIGHIGAN;810S
Cercitkate Issued To: Perldns Engines Co Ltd E8 ti,,Date; Issue Date:
(U.S.ManufactwerorinTorrec) 06f2tI_017 04'26::017
Cer Mcm,\umber.JP1,%M07.0PRT-004 Expiradcu Date: Revision Date:
JiyiarrJ unlsr,DDsion Director
1'J3—fir ompliauce irision NA
Model Year:2018 Mobile:St.d.-,Indi-wr:Stationary
3Ian.acturer Type:Ongiaai Eagiae Msnu5cturer Emissions Posner Catego T:215c=k,V 450
Engine Family:J1=07.0FN1 Fuel Type:Diesel,N--Stardisd Fuel
After Treatment Devices:No After Treatment Devices In:f:dled
No..fter Treatment Dnices:Elect o is Contro4 Engine Design.'.Ectvkafioa
Prusuaut to Section I i and Section 213 of the Clean AirAct(42 U.S.C.sections 7411 and 7547)and 40 CFR Part 60,and ss S nt to the tern and conditions prescribed in those prnvisioas,this certificate of
conformity is hereby issued With respect to she test eneiees schich hasebeeu found to conform to applicable regsaremears and utuch represent the fallowing engi-,by engine f—ily,mare fully d—ibed in
the doctmteoution required by 40 CFR Post 60 and ptcd ed in tL•e stored model year. „ '(d' i-
.I,•f
This certificate of confomtity carers only those nest compression-ignition engines which cocfcrm in aR material mspec s to the design specifications that applied to thou engines described in the
do<wnentation required by 40 CPR Part 60 and which are produced dining dw model y<n stated oa this certificate of the said manufacturer.as deimed in 40 CTRPart 60-
It is a term of this certificate tbat the mwiSachuer shall consent to all impectioi sde m'bed in 40 CFR'106S id mdwriud iri a wwrwt m cows order.Faille to conyly pith the regoiremaus of nosh a
wmrsil of covet ceder vny lead to revocaticn rA suspemim of this ttrtificate forieasons syeci6ed iat40 CFR Past 60.II is oho a ternt of this certificate that this certificate Hoyle r—ked cr suspen&d a
reudemdiroidabitJtioforotherreasaascpecifiedin40CFRPart 60.This certificate does not corer engines w1d,offered for code,or inaoduced,or de4ixsed for introduction,'iuto commerce in the U.S.prior to the eflectice date of the ceAucate.
I-EmGen3 Diesel-fired emergency generator(1500M)
NSPS IIII
Observed.This generator is owned by Duke Power,the facility is leasing the unit through them
and does not have physical access to the unit.. The unit is a certified engine and the certification
is below. David Hughes, permit engineer with RCO, has been notified of this issue. This should
be removed from the permit and has been added to the yellowsheet.

Prysmian Cable and Systems USA,LLC
November 14,2019
Page 26
Emission`Source ID
Emission,Source Description
•''ems '°• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TRANSPORTATION
2018 MODEL YEAR AND AIR QUALITY
CERTIFICATE OF CONFOR\IITY
1\'FIH THE CLEAN AIR ACT ANN ARBOR,MICHIGAN 48105
Certificate Issued To: PerLms Engines Co Ltd Wreck,Date: F*1
(US.NI-s1h,nnercrhtgtorter) 06t'_6i2017 Cerfifieate Nambrr.SPhM407.0PR7-004 Eapindon Date: tmL-r,Dlsision Due«or:;3ompliDhishon
31odel Year,2013 Mobile,Stationary Indicator:Stationary
.anufacttcer Type:Original Engine NlamsGcttaer Emissions Power Category:225emlA 450
Engine Family-IP=10PRtI Fuel Type:M.1,Non-Stac iardFuel
After Treatment Desica:No*erTreatmem Desices In^talled
Noo-after Treatment Drsi<es:Elecannie Coeval,Fs¢iee Iksi®Modification
F==t to Section III and Sectien'_13 of dw,0 an AirAct(42 U.S.C.sections 7411 and 7547)and 40 CFR Part 60,and subject to the temss and conditions pcese ibcd in those prosisices,thus certificate of
cmfmmiry is h ccbyissueduith ce•.peci to the test engine:ia'ch have been£mind to cmfarnt to applicable rega'vemnas and atich repsesem the falloscing engines,by engine faauty;mere fidlp described in
ihedocvmectatlonregstiredby40CFRPart60andpmdt.<diathesmtedmodelyear. __-4: 1'11
This certificate of con£ crovew and•those new c msioa-i nines Much&;jf sniia all materiZiQ; is to 1he dest fimioas that applied to tl—m de—bed in the
ormsry ) a°W gadion en_ �..t PK'. �� apph engines
docnm<ntation requ'ved by 40 CFRP.trt 60 and eluchare produced dining the rmdel year stated oa tlua caGiicate of the sn'dmmmfacncer,as LeSned is 40 CFRPut 60.
It is a terrnof dsis certificate that the nannfuheer shall co—ent m all iuipccrimis dren7ted in 40 CFR 106E aad authorized iu a 11—cat or court order.Failure to ccayly with the requuemxts of soh a
warram ar coon order may lead m revocation or suspension of ttsis eatif�cate forteasan:specified in a0 CFR'Part 60.It is alm term of this certifitate that this cestifirate auv be re-1led orsuspended or
rendered svid ab fnitio for other reasoas specified in 40 CFR Pan 60.
This mrtifc te does not toter engines sold,off red f—de,orintrodnred.or 4ec111'saed for invafiicrioq inio caamurce iaihe U.S.prior to the efrectivedate of the certificate.
r
'4µ'
9. Other Compliance Requirements and Issues:
None noted.
10. Compliance Assistance:
None.
11. Sumniga of Changes Needed to the Current Permit:
(I-EmGen)Diesel-fired emergency generator 150 HP,This unit is physically removed from the facility
and should be removed from the permit.
(I-EmGen2 &I-EmGen3)Diesel-fired emergency generator(1500M),This generator is owned by Duke
Power,the facility is leasing the unit through them and does not have physical access to the unit. The unit
is a certified engine and the certification is below. David Hughes,permit engineer with RCO, has been
notified of this issue. They should be removed from this permit and permitted through Duke Energy.
Selective catalytic NOx reduction system(1 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.

Prysmian Cable and Systems USA,LLC
November 14, 2019
Page 27
The air permit identifies the maximum heat input of I-boilerl &I-bioler2 as 8.76 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: Glass fibers strands are glued together, flattened and product code information is
applied in ink to the coating. There are five ribbon lines in operation. This operation has been removed
from the facility and should be removed from the permit.
12.Findings.
Based on my observations during this inspection, this facility appeared to be in compliance with the
applicable air quality regulations.
KAK:lhe
cc: MRO Files
hnps://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00419/INSPECT 20191114.doex