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HomeMy WebLinkAboutAQ_F_0600015_20181214_CMPL_Ext-Rqst a ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary MICHAEL ABRACZINSKAS Director December 14, 2018 Mr. Douglas Myers, Regional General Manager Sibelco North America P. 0. Box 588 Spruce Pine,North Carolina 28777-0588 Subject: Emissions Test Schedule Approval for Vibrating Screen(ID No. ES-VS-18) Sibelco North America- Schoolhouse Quartz Plant Spruce Pine,Avery County,North Carolina Facility ID No. 0600015, Air Permit No. 04000R22 Dear Mr. Myers: The North Carolina Division of Air Quality(DAQ)has reviewed your company's letter to Brendan Davey dated September 20,2018. In this letter,Jeffrey S. Ferguson of your company requests an extension to the federal New Source Performance Standards (NSPS) deadline for testing particulate and visible emissions from a permitted bagfilter(ID No. DC-02) at the Schoolhouse Quartz Plant. This bagfilter serves the screening and magnetic separation system building(Group 4; ID No. GR4),which houses several pieces of equipment including a vibrating screen(ID,No. ES-VS-18). Mr. Ferguson's letter indicates that ES-VS-18 had previously been tested in accordance with the requirements for new sources under 40 CFR 60, Subpart 000,Standards of Performance for Nonmetallic Mineral Processing Plants. Although,the original vibrating screen(ES-VS-I8)was tested in the early 2000's, it was later removed from the Group 4 building and was not within the building during the more recent testing programs on the associated bagfilter. On September 10, 2018, a like-for-like replacement of ES-VS-18 commenced operation within the Group 4 building in a different configuration from previous testing scenarios. If the vibrating screen was considered a new or reconstructed source per NSPS Subpart 000, a performance test would be required by March 9, 2019 (180 days after startup of the emission source). However,the federal rules are not clear as to whether or not a new performance test is required for the like-for-like replacement screen located within a building served by a bagfilter. Mr. Ferguson's letter also indicates that your company is planning to add two new screens (ID Nos. ES-VS-50 and ES-VS-51)within the Group 4 building in early 2019 that will definitely require performance testing under NSPS Subpart 000 requirements. Making the conservative assumption that the replacement vibrating screen(ES-VS-18)requires performance testing, your company is requesting a North Carolina Department of Environmental Quality I Division of Air Quality 217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641 919.707.8400 Sibelco North America December 14,2018 Page 2 of 2 60-day extension beyond the calculated NSPS test deadline for ES-VS-18 so that this replacement screen can be tested at the same time as the two new screens (ES-VS-50 and ES-VS-51). After consideration of your request, DAQ agrees that the NSPS testing requirements are unclear for the replacement vibrating screen(ID No. ES-VS-18). The DAQ also agrees that it makes sense to test ES-VS-18 at the same time as you test the new screens (ID Nos. ES-VS-50 and ES-VS-51) since they will be located in the same building served by the same control device. Since you expect to test the bagfilter(ID No. DC-02) serving the Group 4 building once ES-VS-50 and ES-VS-51 are installed and operational in early 2019,the DAQ grants Sibelco North America's request to delay any required performance testing on ES-VS-18 by up to 60 days. The final test results for the combined performance test on DC-02 should be submitted by May 8, 2019. The granting of this extension to the specific compliance test report due date does not relieve your company of the legal responsibility for compliance with any other applicable provisions of your air quality permit or with any other applicable federal, state, or local requirements. Also,remember that your company is required to provide DAQ with a copy of a testing protocol for any air emission testing program prior to conducting the testing, and if you would like to get pre-approval of the testing protocol, it should be submitted to DAQ at least 45 days prior to the test date. If you have any questions,please contact Gary Saunders, Stationary Source Compliance Branch Supervisor, or me at 919-707-8400. Respectfully, Stephen G. Hall Chief, Technical Services Section Division of Air Quality,NC DEQ cc: Jeffrey S. Ferguson, Sr. Environmental Engineer, Sibelco North America(via email) Brendan Davey, Asheville Regional Office Supervisor(ARO) Central Files (Avery County) IBEAM Documents -- 0600015 North Carolina Department of Environmental Quality I Division of Air Quality 217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641 %9.707.8400