AQ_F_1900030_20200213_CMPL_InspRpt (4)

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NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Arclin USA,LLC
NC Facility ID 1900030
Inspection Report County/FIPS: Chatham/037
Date: 02/14/2020
Facility Data Permit Data
Arclin USA,LLC Permit 04162/R21
790 Corinth Road Issued 7/29/2014
Moncure,NC 27559 Expires 6/30/2022
Lat: 35d 36.2420m Long: 79d 2.8780m Class/Status Synthetic Minor
SIC: 2821 /Plastics Materials And Resins Permit Status Active
NAILS: 325211 /Plastics Material and Resin Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/112r
Bowman Harvey Brian Reddy Bowman Harvey
NSPS: Subpart III, Subpart Kb,Subpart VV
HSE Coordinator Plant Manager HSE Coordinator
[phone] [phone] [phone]
Compliance Data
Comments: In Compliance. 2D.0958 can be removed during next
mod/renewal. Inspection Date 02/13/2020
Inspector's Name Matthew Mahler
Inspector's Signature: lkldt/tl `'�� � Operating Status Operating
1 Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: '%j `j / On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2010 0.0300 --- 0.4500 1.43 18.38 0.0100 2358.90
2005 0.1400 0.0100 1.80 2.65 26.42 0.0300 3607.79
*Hi hest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I) DIRECTIONS TO FACILITY: Arclin USA, Inc. is located on 790 Corinth Road in Moncure, NC, in Chatham County.
From RRO, take 1-440 W(US-1 S)towards Sanford. Take the Old US-1 exit via Exit 84. Turn right onto Old US-1. After
approximately 5 miles,turn left onto Corinth Rd. Facility is approx.0.5 mi.on the right.Pull up to the intercom and someone
will open the gate.

(In FACILITY DESCRIPTION: Arclin manufactures three different groups of resins: urea formaldehyde resin for particle
board,phenol formaldehyde resin for water resistant wood products, and melamine formaldehyde resin for auto paints. The
facility has two plants that manufacture formaldehyde:MF-1 and MF-2. In MF-1 methanol is combined with water and a silver
catalyst to create formaldehyde.MF-2 is a dry process in which methanol reacts with a molybdenum oxide catalyst to create
formaldehyde. The facility operates six separate batch kettles, in which formaldehyde is combined with other ingredients to
make batch-specific resins.The process operates 365 days/year and 24 hrs/day.The facility employs approximately 50 people.
Safety notes:This is a large outdoor facility.Inspectors are required to wear a hard hat,safety glasses,gloves,and safety shoes.
A high visibility safety vest is not required but is also a good idea as facility vehicle and truck traffic can be heavy at times.
Inspectors may experience exposure to high pressure steam and hazardous chemicals/substances used to produce resins.
(III) INSPECTION SUMMARY: On February 13,2020,I(Matt Mahler)visited Arclin for an air quality compliance inspection.
There I met with Mr.Bowman Harvey,HSE Coordinator and Facility Contact. Mr.Brandon Eason,Operations Manager,also
assisted with retrieving data for the records review. Mr.Brian Reddy also assisted with clarification of the bagfilter ID numbers
and bagfilter records review.
Mr.Harvey and I reviewed the current permit and required paperwork. The recordkeeping appeared up to date,except for the
missing 2019 bagfilter, the incomplete LDAR recordkeeping related to two leaks in 2019, and missing tank capacity and
dimensions for ES-M-94 (213 .0524 NSPS Subpart Kb). The 2019 bagfilter records and the ES-M-94 records were later
provided by email by Mr. Harvey on February 16, 2020. The missing LDAR recordkeeping was provided by email on
February 18,2020 by Mr.Harvey. After the permit and records review,Mr.Harvey and I toured the facility and the emission
sources were verified onsite and appeared to be in working order.MF-1 and MF-2 was in operation. At the time of inspection,
the facility was not unloading urea. No trucks were parked in the truck loading bays at the time of the inspection.
During the 2017 tour,a 250-gallon Fire System Diesel Fuel Tank and a diesel fire pump engine,were observed and should be
added to the exempt list during the next permit renewal. The 255 hp engine was manufactured by Cummins Engine Co.in June
1970. The engine is serviced yearly by C.Atlantic in Greensboro,NC and the annual engine maintenance was last conducted
on January 22,2019. The 2017 hour-meter reading was noted as 598.46 hours and the January 22,2019 hours-meter reading
was noted as 610 hours. The following information was also noted: SBM No. 33055; Engine # 744187; and Model #
NT-280-IF.
Overall,the facility appeared well run and maintained from an air quality standpoint.
(IV) PERMITTED EMISSION SOURCES: Arclin has several permitted sources onsite; following is a summary of sources by
type and inspection observations. See permit for the full list.
• Methanol-Formaldehyde Conversion Plant No.1(MF-1)
Source includes: formaldehyde absorption system (ES-A-1) controlled by a regenerative thermal oxidizer (CD-1)
(hereafter"RTO"). Observed running.
• Methanol-Formaldehyde Conversion Plant No.2(MF-2)
Setwees inelude two abser-bef eelumns (ES A 2 and 3), eantrelled by a thermal oxidizer (CD 2) (hereafter-"TO").
Observed running.
• Resin Kettles
Six resin kettles(ES-K series),controlled by the RTO. All were verified onsite.
• Loading and Unloading Operations
Sources include both truck and railcar loading/unloading areas and two railcar cleaning operations;all but the urea
unloading pit are controlled by the RTO. Loading/unloading of urea was observed.
• Miscellaneous Sources
Source includes fugitive emissions from MF-2 Plant(ES-FUG);none were observed.
• Solid Raw Material Storage
The permitted equipment list includes four urea weigh tanks (ES-WT series) that sit atop the Resin Kettles; a
melamine storage silo (ES-MS-6); and one salt bin(ES-SB-1). According to an email received from Mr. Reedy on
March 4, 2019, ES-SB-1 and ES-WT-3 have never been installed and the associated bagfilters are not in service.
ES-WT-4 is no longer in service. According to an email received from Mr.Bowman on February 16,2020,ES-WT-4
was taken out of service in June 2011. The retrofit of ES-WT-4 to service as ES-MS-6 was completed on July 30,

2011. With the retrofit,bagfilter CD-1311-6 was used to control the new ES-MS-6(former ES-WT-4). All sources are
controlled by bagfilters(CD-BH series).
• Storage Tanks
Sources include 60 permitted tanks(ES-M series),of which 13 are controlled by the RTO and 37 are subject to NSPS.
Four tanks(ES-M-70,71,77 and 95)are listed as"future tanks." All(except ES-M-10)were observed onsite.
(V) PERMIT SPECIFIC CONDITIONS:
A.1 The Permittee shall comply with Title 15A NCAC, Subchapter 2D.0202,2D .0515,2D .0521,2D.0524(40 CFR 60, Subpart
III,Subpart Kb,and Subpart VV),2D.0535,2D.0540,2D.0611,2D.0948,2D.0949,2D.0958,2D.1100,2D.1806,2Q.0315
and 2Q.0317(Avoidance).
Appeared to be in compliance—see below.
A.2 PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the
expiration date of this permit, shall request permit renewal and submit the air pollution emission inventory report for the 2021
calendar year.
Appeared to be in compliance—I discussed with Mr.Harvey the renewal and emissions inventory due date of April 1,
2022.
A.3 PARTICULATE CONTROL REQUIREMENT—As required by 15A NCAC 2D .0515 particulate matter emissions shall not
exceed allowable emission rates.
Appeared to be in compliance — this condition demonstrates that particulate emissions are a factor of the
process throughput and were determined in permit review.
A.4 VISIBLE EMISSIONS (VE) CONTROL REQUIREMENT—As required by 15A NCAC 2D .0521 VE from the emission
sources shall not be more than 20 percent opacity when averaged over a six-minute period.
Appears to be in compliance—no VE was observed during the inspection.
A.5 15A NCAC 213 .0524 "NEW SOURCE PERFORMANCE STANDARDS (NSPS)" -For ID No.MF-2 consisting of ID Nos.
ES-A-2 and ES-A-3 the Permittee shall comply with all applicable provisions in 15A NCAC 2D .0524,NSPS, Subpart III
[Standards of Performance for Volatile Organic Compound (VOC) Emissions from the Synthetic Organic Chemical
Manufacturing Industry(SOCMI)Air Oxidation Unit Processes],and including Subpart A"General Provisions".
a. NSPS Emissions Limitations- As required by 15A NCAC 2D .0524 and 40 CFR Part 60.612, the following permit
limits shall not be exceeded:
i. The thermal oxidizer(ID No.CD-2)installed on the formaldehyde absorbers(ID nos.ES-A-2 and ES-A-3)shall
reduce emissions of total organic compounds or TOC (minus methane and ethane)by 98 weight percent or to a
TOC (minus methane and ethane) concentration of 20 ppmv on a dry basis corrected to 3 percent oxygen,
whichever is less stringent.
Appears to be in compliance—the TO was observed and appeared to be running properly.
b. NSPS Monitoring of Emissions and Operations-As required by 15A NCAC 2D .0524 and 40 CFR Part 60.613,the
following requirements shall be met:
i. The Permittee shall install,calibrate,maintain,and operate:
A. A temperature monitoring device equipped with a continuous recorder and having an accuracy of±
1%of the temperature being monitored expressed in°C,or±0.5°C,whichever is greater.
B. A flow indicator that provides a record of vent stream flow to the incinerator>—1/hr for each affected
facility.The flow indicator shall be installed in the vent stream from each affected facility at a point
closest to the inlet of the incinerator and before being joined with any other vent stream.
Appeared to be in compliance—active run time temperature trends and vent stream flow trends were observed on a
facility laptop via the Parcview electronic monitoring program. The operations manager also pulled up historic data on
a remote screen in the conference room.
c. NSPS Reporting and Record keeping Requirements-As required by 15A NCAC 2D .0524 and 40 CFR Part 60.615,
the following requirements shall be met:
i. The Permittee shall keep records of during each performance test,and include the following data in the report
of the initial performance test required under 40 CFR Part 60.8.

A. The average temperature of the firebox measured at least every 15 min.and averaged over the same
time period of the performance testing.
B. The percent reduction of total organic compounds minus methane and ethane(TOC)determined as
specified in 40 CFR Part 60.614(b)achieved by the incinerator,or the concentration of TOC(ppmv,
by compound)determined as specified in 40 CFR Part 60.614(b)at the outlet of the control device
on a dry basis corrected to 3%oxygen.
Appeared to be in compliance- the most recent performance test was conducted on November 22, 2004. Test results
were incorporated into the facility's permit application and were deemed in compliance by DAQ Stationary Source
Compliance Branch in a memo dated May 5, 2005. Results include TOC reduction of 98.87% with the following
emission rates:
Pollutant Pounds/hour Tons/year
Formaldehyde 0.07 0.29
Methane, other VOCs 0.35 1.53
Methyl Formate 0.33 1.44
Total VOCs 0.74 3.26
From the November 22,2004 stack test report,the average temperature measured at the stack was 1290 IF as provided
by Mr.Harvey's records(this was not provided in the permit application).
ii. The Permittee shall keep continuous records of the equipment operating parameters specified to be monitored
under 40 CFR Part 60.613(a) [i.e., temperature and vent stream flow] as well as records of periods of
operation during which the parameter boundaries established during the most recent performance test are
exceeded. For the incinerator, the periods of operation during which the parameter boundaries established
during the most recent performance test are exceeded are defined as follows:
A. All 3-hour periods of operation during which the average combustion temperature is more than
28°C(507)below the average combustion temperature during the most recent performance test at
which compliance with 40 CFR Part 60.612(a)was determined.
Appeared to be in compliance—Mr.Harvey stated that there are interlocks that prevent the system from operating if
the average combustion temperature is 28°C (50°F) below the 1290OF from the 2004 performance test. The facility
keeps continuous records of temperature and vent stream flow in the historian of their control system. Brandon Eason,
operations manager pulled up historic data for review.
iii. The Permittee shall keep up-to-date,readily accessible records of all periods when the vent stream is diverted
from the control device or has no flow rate.
Appeared to be in compliance— I reviewed the facility's Thermal Oxidizer Outage Log sheets, which document the
periods when vent stream flow is diverted from the TO.
iv. The Permittee shall submit to the Regional Supervisor, DAQ, semiannual reports of the following
information as specified in 40 CFR Part 60.6150):
A. Exceedances of monitoring parameters recorded above in paragraph c.ii above,and in 40 CFR Part
60.615(c).
B. All periods recorded above in paragraph c.iii above,and in 40 CFR Part 60. 615(d),when the vent
stream is diverted from the control device or has no flow rate.
Appeared to be in compliance-the most recent semi-annual report,received on January 27,2020,states: "There were
no 3-hourperiods of operation when average combustion temperature was more than 28'C below the average combustion
temperature recorded during the last performance test [i.e. 1290 IF]." The semi-annual reports also include completed
Thermal Oxidizer Outage Log forms.
A.6 15A NCAC 2D.0524"NEW SOURCE PERFORMANCE STANDARDS"-For ID No.MF-2,the Permittee shall comply with
all applicable provisions in 15A NCAC 2D .0524,NSPS, Subpart VV,"Standards of Performance for Equipment Leaks in the
Synthetic Organic Chemicals Manufacturing Industry,"and including Subpart A"General Provisions".
a. STANDARDS - The Permittee shall comply with the requirements of the leak standards in 60.482-1 through
60.482-10 as applicable for all equipment in the affected facility.

b. RECORDKEEPING REQUIREMENTS - The Permittee shall comply with the recordkeeping requirements in
60.486(a)through(h).
i. Affected facilities applying for exemptions from this subpart per 60.480(d) must comply with the
recordkeeping requirements in 60.486(i).
ii. All records shall be kept in a log in a readily accessible location.
c. REPORTING REQUIREMENTS - The Permittee shall submit semiannual reports to the Air Quality Regional
Supervisor,Division of Air Quality.
i. All semiannual reports shall include a summary of the recordkeeping requirements detailed in 60.486.
ii. If electing to comply with the provisions in 60.483-1 and 60.483-2 the Permittee shall notify the Regional
Supervisor,Division of Air Quality of the alternative standard selected 90 days before implementing either of
the provisions.
Appears to be in compliance-the facility conducts Leak Detection and Repair(LDAR)inspections on pumps monthly
and on valves quarterly, following their preventative maintenance program which uses electronically scheduled and
recorded work orders. I reviewed LDAR log reports, the monthly inspection on pumps and the last quarterly
inspection on valves. The pumps and valves at Arclin are in light liquid service. They have no equipment in gas/vapor
and light liquid service. For VOC detection, they employ the MultiRAE 3000 Portable Handheld VOC monitor.
According to the standards in 60.482-1 through 60.482—10,a reading on the monitor of 10,000 ppm or higher indicates
a leak. Mr.Harvey indicated that if he obtains a reading>0 on the MultiRAE or if there is a visible leak,maintenance is
called to inspect and repair as needed. We discussed the timing in the standard that states that once a leak is detected,
repairs should be initiated within 5 days and completed within 15 calendar days. Mr. Harvey indicated that he has
never obtained a reading of 10,000 ppm or greater that constitutes a leak according to the standard. Records reviewed
indicated that there were two visible leaks logged on July 22, 2019 and October 22, 2019. Mr. Harvey did not have
complete records of these two leaks available for review. The missing records are required by 40CFR60.486(c) and
include information regarding the repair of the pump leak. Mr.Harvey provided the missing LDAR recordkeeping by
email on February 18, 2020 and indicated that a completed work order repaired the leak logged in July 2019. The
October 2019 leak was a carryover error in the log. As a result,Mr. Harvey stated that the facility will improve their
tracking system by using clean LDAR check sheets to record our monitoring results, instead of type-overs.
Additionally,any identified leaks will have a Work Order number documented on the inspection log sheet.
A.7 15A NCAC 2D.0524"NEW SOURCE PERFORMANCE STANDARDS"-For storage tanks listed in the table(see the Permit
under this condition),the Permittee shall comply with all applicable provisions in 15A NCAC 2D .0524,NSPS, Subpart Kb,
"Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for
which Construction, Reconstruction, or Modification Commenced After July 23, 1984," and including Subpart A "General
Provisions."
Recordkeeping Requirements-Per 40 CFR 60.116b(a)and(b),the Permittee shall keep records showing the dimension of each
storage vessel and an analysis showing the capacity of each storage vessel readily accessible for the life of the source.
Appears to be in compliance — Mr. Harvey showed me a spreadsheet listing all relevant tanks, their ID numbers,
dimensions,and capacities in gallons. ID No.ES-M-99 has been removed from the site. Mr.Harvey provided missing
tank capacity and dimensions for ES-M-94 by email on February 16,2020.
A.8 NOTIFICATION REQUIREMENT—As required by 15A NCAC 2D .0535 the Permittee of a source of excess emissions that
last>4 hr and results from a malfunction,a breakdown of process or control equipment or any other abnormal condition shall
be required to give notification to the Director or his designee.
Appears to be in compliance—From December 11-17,2018,the facility had one period of operating in excess of four
hours without the RTO operating due to a malfunction. The malfunction was from a flame detection failure. Mr.
Bowman Harvey contacted the RRO by email on December 11, 2018 to notify the office of this occurrence. A letter
from the facility was received on February 4, 2019 (postmarked January 30, 2019) describing that the facility had
operated MF-1 unit during the outage according to Scenario A allowed by Stipulation 14,2D.1100 Control of Toxic Air
Pollutants.
A.9 FUGITIVE DUST CONTROL REQUIREMENT—As required by 15A NCAC 2D.0540 the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property
boundary.
Appears to be in compliance — no dust was observed during the inspection; no dust complaints are on file at RRO
against Arclin.

A.10 FABRIC FIUTER REQUIREMENTS-As required by 15A NCAC 2D .0611,particulate matter emissions shall be controlled
as described in the permitted equipment list.
a. Inspection and Maintenance (I&M) Requirements - To comply with the provisions of this permit and ensure that
emissions do not exceed the regulatory limits,the Permittee shall perform,at a minimum,an annual internal inspection
of each bagfilter system and periodic 1&M as recommended by the equipment manufacturer.
b. Recordkeeping Requirements-The results of all inspections and any variance from manufacturer's recommendations
shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance
activities shall be recorded in the logbook. The logbook shall be kept on-site and made available to DAQ personnel
upon request.
Appears to be in compliance—The facility's bagfilter maintenance logs,which record monthly internal inspections and
maintenance performed, were not available for review during the inspection. Mr. Harvey provided 2019 bagfilter
records to the RRO by email on February 16, 2020. In a voicemail on March 1, 2019, Mr. Brian Reddy, Plant
Manager/Authorized Contact indicated that ES-SB-1 (CD-BH-7) and ES-WT-3 (CD-BH-3) are not in service. From
the 2018 inspection report,Mr.Baker had electronic records dating back to 1998.
A.11 VOC EMISSIONS FROM TRANSFER OPERATIONS—As required by 15A NCAC 2D.0948,the Permittee shall not load in
any one day>20,000 gallons of VOC with a vapor pressure of>1.5 lbhn'under actual conditions into any tank-truck,trailer or
railroad tank car from any loading operation unless the loading operation uses submerged loading through boom loaders that
extend down into the compartment being loaded or by other methods that are at least as efficient based on source testing or
engineering calculations
Appears to be in compliance — Mr. Harvey informed me that because of the equipment restrictions, they are not
capable of exceeding the limit of 20,000 gallons. Additionally, the previous inspector stated that no open loading is
conducted; all loading is closed,with vapors trapped to prevent emissions.
A.12 STORAGE OF MISCELLANEOUS VOLATILE ORGANIC COMPOUNDS — As required by 15A NCAC 2D .0949 the
Permittee shall not place,store,or hold in any stationary tank,reservoir,or other container with a capacity>50,000 gallons,any
liquid VOC that has a vapor pressure of>— 1.5 lb/in'-under storage conditions unless certain conditions are met.
Appears to be in compliance-the facility's 500,000-gallon methanol storage tank(ES-M-34)has a floating pontoon type
roof and was inspected in mid-December 2009.The facility has four(4)75,000-gallon formaldehyde storage tanks with
the vapors being controlled by the regenerative thermal oxidizer(CD-1).
A.13 WORK PRACTICES REQUIREMENTS FOR SOURCES OF VOC—As required by 15A NCAC 2D.0958(c),for all sources
at facilities that use VOC or emit VOC as a product of chemical reactions;the Permittee shall adhere to the following required
work practices(see permit for list).
Appears to be in compliance—evidence of good housekeeping was observed during the inspection. Mr.Harvey stated
that the work practices are followed.
Permit note: This stipulation can be removed from the air permit during the next modification renewal since the
regulation has been repealed for attainment areas.
A.14 TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT-Pursuant to 15A NCAC 2D
.1100,and in accordance with the approved application for an air toxic compliance demonstration,the following permit limits
shall not be exceeded(see permit for list).
a. Operations Restrictions - the following operating restrictions (scenarios) shall apply during control device(s)
maintenance downtime(see permit for table).
b. Recordkeeping Requirements-During periods of control device(s)maintenance downtime,the Permittee shall record:
i. the flow rates to the RTO and TO hourly;
ii. the number of process kettles producing urea-formaldehyde resin operating in the vacuum strip step;
Records shall be recorded in a log book, which shall be kept on-site and made available to DAQ personnel upon
request.
Appears to be in compliance-the facility operates under Scenario C or Scenario D(i.e.,both RTO and TO are running
and one resin kettle is in operation during vacuum step). Kettle K-5 and K-6 were in operation. The recordkeeping
requirement,Stipulation 14.b.,is tied to the operating scenarios A,B,and E during which the process is operated while
a control device(s) is down. Mr. Harvey explained that when the process is shutdown, control devices are not in
operation. The facility doesn't operate in Scenario A,B,or E,therefore,the facility does not maintain recordkeeping of
flow rates and the number of process kettles.

A.15 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A NCAC 2D .1806, the Permittee shall
prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary.
Appears to be in compliance-no odors were detected; no odor complaints are on file against the facility.
A.16 LIMITATION TO AVOID 15A NCAC 2Q.0501 -Pursuant to 15A NCAC 2Q.0315"Synthetic Minor Facilities,"to avoid the
applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee,
facility-wide air pollutant emissions shall be less than the amounts tabulated below per consecutive 12-month period.
Volatile Organic Compounds(VOCs) 100 tons
Carbon Monoxide 100 tons
Formaldehyde and Methanol 10 tons each
Sum of all Hazardous Air Pollutants(HAPs) 25 tons total
a. Operations Restrictions-the following restrictions shall apply:
i. Carbon monoxide, formaldehyde, methanol, total VOC and total HAP emissions shall be controlled by the
RTO and TO as described in the equipment list with downtime allowances as described below.
Appears to be in compliance—both the RTO and TO were observed running properly.
b. Recordkeeping Requirements-The Permittee shall record monthly and total annually the following:
i. the facility-wide carbon monoxide,formaldehyde,methanol,total VOC and total HAP emissions.
The Permittee shall keep each record on file for a minimum of three years.
Appears to be in compliance — I reviewed facility's monthly and total annual emission records, which appeared
complete and up to date. Data for 2019 is in the following table:
Pollutant January 2019-December 2019
VOC 4.51 tons
CO 62.67 tons
Formaldehyde 0.87 tons
Methanol 3.71 tons
Total HAPs 5.51 tons
c. Reporting Requirements-Within 30 days after each calendar year,the Permittee shall submit the following to DAQ:
i. monthly carbon monoxide,formaldehyde,methanol,total VOC and total HAP emissions for the previous 12
months;and
ii. total carbon monoxide, formaldehyde, methanol, total VOC and total HAP emissions for the previous 12
months.
Appears to be in compliance — copies of submitted reports are kept onsite. The most recent report submitted was
received on January 27,2020 and includes monthly and 12-month rolling total emissions for 2019. Total emissions for
2019 are as follows:
Pollutant CY 2019
VOC 4.51 tons
CO 62.67 tons
Formaldehyde 0.87 tons
Methanol 3.71 tons
Total HAPs 5.51 tons

d. RTO and TO Requirements-Carbon monoxide,formaldehyde,methanol,total VOC and total HAP emissions shall be
controlled by the RTO (ID No. CD-1) and TO (ID No. CD-2) as described in the equipment list with downtime
allowances as described in paragraph(d)(v)below.
i. I&M Requirements- the Permittee shall perform periodic I&M as recommended by the manufacturer and
perform an annual internal inspection of the primary heat exchanger and associated inlet/outlet valves to
ensure structural integrity.
Appears to be in compliance—facility personnel told me that they do I&M checks on the RTO and TO every Monday,
Wednesday and Friday. Arclin maintenance also does an internal inspection every 6 months, which is in a greater
frequency than the required annual. The most recent internal inspection/maintenance was completed on February 26,
2019 and May 17, 2019 for CD-1 and CD-2,respectively. Additionally,Durr contractors conducts extensive internal
maintenance every other year. Durr's last RTO maintenance was completed December 7, 2018 and last TO
maintenance was completed on February 11,2019.
ii. Recordkeeping Requirements - The results of all inspections and any variance from manufacturer's
recommendations shall be investigated with corrections made and dates of actions recorded in a logbook.
Records of all maintenance and monitoring activities shall be recorded in the logbook.The logbook shall be
kept on-site and made available to DAQ personnel upon request.
Appears to be in compliance — I reviewed the RTO and TO I&M electronic logs, which appeared complete and
up-to-date.
iii. RTO Monitoring_Requirements - The Permittee shall ensure the proper performance of the RTO by
monitoring the following operational parameters:
A. The Permittee shall record the maximum temperature measured inside the unit but in the second half
of the oxidizer (away from the flame zone) monthly. The allowable range is between 1,400 and
1,700'F.
B. The Permittee shall record the gas flowrate to the RTO daily.The maximum allowable flowrate is
11,800 standard cubic feet per minute (scfm), except during periods of thermal oxidizer
maintcnance doWnwhe.
Appears to be in compliance—I reviewed daily data for the RTO from February 2019—January 2020. All recorded
temperatures were within the allowable range. All recorded flowrates reviewed were below the maximum 11,800 scfm.
iv. TO Monitoring Requirements-The Permittee shall ensure the proper performance of the TO by monitoring
the following operational parameters:
A. The Permittee shall record the maximum temperature measured inside the unit but in the second half
of the oxidizer(away from the flame zone)monthly.The minimum temperature is 1,280°F.
B. The Permittee shall record the gas flowrate to the TO daily. The maximum allowable flowrate is
11,414 scfm,except during periods of maintenance downtime.
Appears to be in eomplianee 1 reAewed daft data for the TO from February 2019 january 2020. All Feco-r-ded
temperatures were within the allowable range. All recorded flowrates reviewed were below the maximum 11,414 scfm.
v. RTO and TO Downtime Allowance - emission sources controlled by the RTO or TO may operate
uncontrolled according to the conditions listed below. This provision is limited only to satisfying
maintenance requirements of the RTO and/or TO.
A. Control Device Downtime Recordkeeping Requirements -The Permittee shall keep records of the
dates and number of hours for each maintenance downtime of the RTO and/or the TO. Included
with these records shall be calculations for emissions resulting from each RTO and/or TO downtime
and 12-month facility-wide totals for the Synthetic Minor pollutants (carbon monoxide,
formaldehyde,methanol,total VOCs and total HAPs).
B. Control Device Downtime Reporting Requirements-The Permittee shall provide a written report to
DAQ within 7 days of conclusion of each control device maintenance downtime. This report shall
contain a summary of all RTO and/or TO maintenance downtime over the previous twelve-month
period and calculations showing facility-wide emissions of all Synthetic Minor pollutants over the
previous 12-month period.

Appears to be in compliance— I reviewed the facility's Thermal Oxidizer Outage Log forms,which appear complete
and up-to-date. Copies of these logs are submitted to DAQ semi-annually. Every entry on the data log does not require
a notice `within seven days of conclusion of each control device maintenance downtime' - according to the facility
contacts, there are electrical `blips' with the TO and RTO that are recorded on the outage log, but do not constitute
control device maintenance,downtime.The system goes off line unexpectedly, and it is then put back online as soon as
possible. However, the recordkeeping requirement, Stipulation 16.d.v., is tied to the assumption that the facility, at
times, can operate their emission sources uncontrolled. DAQ staff discussed this Stipulation with Mr.Harvey during
the 2017 inspection and in follow-up phone calls in May and June 2017. Mr.Harvey explained that when the process is
shutdown,control devices are not in operation. Thus,the facility has submitted the outage logs to DAQ,semi-annually.
DAQ determined that this method satisfies the permit condition. In the event that the facility takes maintenance
downtime in which the process stream is diverted from the control device, the facility will submit the written report
within seven days to DAQ.
A.17 LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT DETERIORATION" -In accordance
with 15A NCAC 2Q.0317,to comply with this permit and avoid the applicability of 15A NCAC 2D.0530,as requested by the
Permittee,emissions shall be limited as follows:
Emission Limit
Affected Source(s)
Pollutant((Tons Per Consecutive 12-month Period)
Facility Wide CO 100
Facility Wide VOC 100
I
Appears to be in compliance-the Synthetic Minor conditions ensure compliance with this stipulation.
(VI) GENERAL PERMIT CONDITIONS:
B.5 REPORTING REQUIREMENT-Any changes that would result in previously unpermitted,new,or increased emissions must
be reported to DAQ.
Appears to be in compliance—no such changes were made nor are planned per facility personnel.
B.14 PERMIT RETENTION REQUIREMENT-The Permittee shall retain a current copy of the air permit at the site.
Appears to be in compliance—a copy of Air Permit R21 was presented at my request during the inspection.
(VII) INSIGNICANT/EXEMPT SOURCES:
Source Exemption Regulation Source of Source of Title V Operating
TAPS. Pollutants.
IES-M-40-potassium hydroxide storage tank �Q.0102 (c)(1)(D)(iii) j No Yes Yes
(10,000 gallon storage capacity) j
IES-QCL-Quality control laboratory I2Q.0102 (c)(1)(C)(iv) j Yes Yes Yes
IES-M-96-diesel fuel storage tank(2,000 gallon! Yes
capacity) !2Q .0102(c)(1)(D)(i) Yes i Yes
IS-B-1 -natural gas fired boiler(25 million Btu
per hour maximum heat input rate) !2Q .0102(c)(2)(B)(ii) Yes Yes
IS-B-2-natural gas fired boiler(20.08 million No
Btu per hour maximum heat input rate) 2Q .0102 (c)(2)(B)(ii) Yes Yes
During the 2017 tour,a 250-gallon Fire System Diesel Fuel Tank and a diesel fire pump engine were
observed and should be added to the exempt list during the next permit renewal. The 255 hp engine
was manufactured by Cummins Engine Co.in June 1970. The engine is serviced yearly by C.Atlantic
in Greensboro,NC and the annual engine maintenance was last conducted on January 22,2019. The
2017 hour-meter reading was noted as 598.46 hours and the January 22,2019 hours-meter reading
was noted as 610 hours. The following data was noted: SBM No.33055;Engine#744187; and Model
#NT-280-IF.

(VHI) EMISSION INVENTORY:Most pollutants are below the deminimus. The drop in emissions is reported to be due to a drop in
business.
(IX) COMPLIANCE HISTORY: Arclin has two reported violations in recent years:
• On January 29,2016 a NOD was sent for deficiencies noted in the RMP resulting from a DAQ inspection on November 23,
2015.
• On November 15,2005 a NOV was sent for nonpayment of fees(2Q .0203).
• On December 21,2004 a NOV was sent for failing emission tests of the RTO(Permit Condition A.8.).
(X) PERFORMANCE TEST REVIEW: Stack testing has not been completed at this facility within the past five years.
(XI) CLEAN AIR ACT SECTION 112(r)REQUIREMENTS-Pursuant to 15A NCAC 2D.2100"Risk Management Program,"
if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal Clean Air
Act,then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68.
Arclin USA,LLC maintains formaldehyde onsite above the threshold quantity and is required to maintain a risk management
plan(RMP)under the 112(r)program. Arclin does have an active RMP for formaldehyde in eight covered processes: the two
plants(MF-1 and MF-2)and six resin kettles(ES-K series),which expires on January 7,2020. Gary Perlmutter,former RRO
personnel, performed a full 112(r) inspection on May 12, 2015 and found the facility to appear in compliance. The current
RMP was briefly reviewed on site,is dated 12/30/2019,and is due to be reviewed and updated by 12/30/2024. The facility was
reminded of the need to update their RMP by the due date and Mr.Bowman indicated that the facility has plans to do so.
(XH) CONCLUSIONS/RECOMMENDATIONS: Arclin USA,LLC appears to be in compliance with all conditions of its current
Air Permit No. 04162R21. I recommend that the facility be re-inspected in one year.