HomeMy WebLinkAboutAQ_F_0700151_20200518_PRMT_Permit O9 64 7u+F Cyr
ROY COOPER
Governor6
MICHAEL S.REGAN =
Secretary
MICHAEL ABRACZINSKAS "
.f
Director
NORTH CAROLINA
Environmental Quality
May 18,2020
Mr.Jeff Harris
Chief Operating Officer
Iconic Marine Group,LLC
P. O.Drawer 457
Washington,North Carolina 27889
SUBJECT: Air Quality Permit No. 10534T02
Facility ID: 0700151
Iconic Marine Group,LLC
Washington,North Carolina
Beaufort County
Fee Class: Title V
PSD Class: Minor
Dear Mr.Harris:
In accordance with your completed Air Quality Permit Application for a modification for a 1st Time
Title V permit received March 23, 2020, we are forwarding herewith Air Quality Permit No. 10534T02 to
Iconic Marine Group, LLC, 1653 Whichards Beach Road, Washington, North Carolina authorizing the
construction and operation,of air emissions source(s)and associated air pollution control device(s)specified
herein. Additionally, any emissions activities determined from your Air Quality Permit Application as
being insignificant per 15A North Carolina Administrative Code 02Q .0503(8) have been listed for
informational purposes as an "ATTACHMENT." Please note the requirements for the annual compliance
certification are contained in General Condition P in Section 3. The current owner is responsible for
submitting a compliance certification for the entire year regardless of who owned the facility during the
year.
As the designated responsible official it is your responsibility to review, understand, and abide by
all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person
who operates any emission source and associated air pollution control device subject to any term or
condition of the attached permit reviews,understands, and abides by the condition(s) of the attached permit
that are applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to
you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. This hearing request must be in the form of a written
petition, conforming to NCGS (North Carolina General Statutes) 150B-23, and filed with both the Office of
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division
of Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The
form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of
Administrative Hearings. Please note that this permit will be stayed in its entirety upon receipt of the
request for a hearing. Unless a request for a hearing is made pursuant to NCGS 15013-23, this Air Quality
Permit shall be final and binding 30 days after issuance.
D Q2�
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA
Dsw rl or fmim66 bl aoaN
919.7OZ8400
Mr.Harris
May 18,2020
Page 2
Mr.Harris
May 18,2020
Page 3
You may request modification of your Air Quality Permit through informal means pursuant to
NCGS 150B-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that this Air Quality Permit will
become final and binding regardless of a request for informal modification unless a request for a hearing is
also made under NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of NCGS 143-215.108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure to
receive an Air Quality Permit or written approval prior to commencing construction is a violation of NCGS
143-215.108A and may subject the Permittee to civil or criminal penalties as described in NCGS 143-
215.114A and 143-215.114B.
Beaufort County has triggered increment tracking under PSD for PM10, SO2 and NOx. However,
this permit modification does not consume or expand increments for any pollutants.
This Air Quality Permit shall be effective from May 18, 2020 until April 30, 2025, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations as
specified therein.
Should you have any questions concerning this matter,please contact Judy lee at 919-707-8729 or
j udeeekncdenr.gov.
Sincerely_yours,
V�A4'
William D.Willets,P.E.,Chief,Permitting Section
Division of Air Quality,NCDEQ
c: Kelly Fortin,EPA Region 4
Washington Regional Office
Central Files
Connie Horne(cover letter only)
Mr.Harris
May 18,2020
Page 4
ATTACHMENT to Permit No. 10534T02
Insignificant Activities per 15A NCAC 02Q.0503(8)
Emission Source ID No. Emission Source Description
1-1 Solvent Cleaning Operations
1-2 One(1)resin storage tank(5,500 gallon capacity)
1-3 Twenty(20)gas-fired space heaters(125,000 to 175,000 Btu per hour capacity)
1-4 Eleven(11)gas-fired space heaters(325,000 to 375,000 Btu per hour capacity)
1-5 Three(3)gas-fired space heaters(2,000,000 to 2,600,000 Btu per hour capacity)
1-6 Two(2)gas-fired space heaters(3,500,000 to 4,000,000 Btu per hour capacity)
I-7 One(1)gas-fired space heater(6,650,000 Btu per hour capacity)
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement
or that the Permittee is exempted from demonstrating compliance with any applicable requirement.
2. When applicable,emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D.1100"Control of
Toxic Air Pollutants"or 02Q .0711 "Emission Rates Requiring a Permit."
3. For additional information regarding the applicability of MACT or GACT see the DAQ page titled"Specific
Permit Conditions Regulatory Guide."The link to this site is as follows:hgp:Hdeq.nc.gov/about/divisions/air-
gualit,/quality_permits/specific-permit-conditions-re ug latory_guide.
Mr.Harris
May 18,2020
Page 5
ATTACHMENT
Summary of Changes to Permit
The following changes were made to Iconic Marine Group,LLC—Washington,Air Permit No. 10534ROI:
Page No(s). Section Description of Changes
1 —29 Entire permit, Modified to reflect current permit number, issued and effective
where applicable dates and associated application information
Revised"300"format to Title V permit format per current
guidance
Replaced 02Q .0308(a)with 02Q .0508(f)
Added noncompliance statements
Attachment List of Updated descriptions to match application amendment.
Insignificant
Activities
Attachment Table of Changes Modified to reflect changes for this permit modification
3 Section 1 Updated page numbers on equipment table
Modified emission source IDs and descriptions to match
application amendment
4-8 Sections 2.LA. Combined all like sources under Fiberglass Boat Manufacturing
through 2.1.13. (to be consistent with other permits for Fiberglass facilities in
NC) and subject to the same State regulations to make the
facility's permit less repetitive
Modified emission source IDs and descriptions to match
application amendment
8—21 Removed Sections 2.LC through 2.1.I due to consolidating into
(removed) condition 2.LA.
4— 18 Sections 2.1 and Revised regulations per current Title V shell guidance and
2.2 MRRR consistency across Fiberglass Boat Manufacturing
facilities
10— 11 Section 2.2—A.3 Revised 15A 02D .1100 condition to included latest regulatory
language provided via email on September 24,2019
24—25 Section 2.2—A.6 Removed 15A NCAC 02Q .0207, 02Q .0304, 02D .0535 and
(previous through A.9 02D .0540 requirements per Title V permitting guidance
permit) Removed 15A NCAC 02 .0504—satisfied on January 2, 2018
and February 27,2020(Application No. 0700151.18A)
11 — 18 Section 2.2—B. Revised MACT Subpart VVVV per latest guidance and to be
consistent with other Fiberglass Boat Manufacturing facilities in
NC. Additional changes made were reference citations,
clarifications/corrections inadvertently missed during processing
of previous permits and Title V noncompliance statements added.
19—29 Section 3— Replaced"300"General and Specific Conditions with latest Title
General V General Conditions(version 5.3,08/21/2018)
Conditions
State of North Carolina
t,.r-��D E Q k, /) Department of Environmental Quality
NORTH CAROLINA Division of Air Quality
Department of Environmental Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
10534T02 10534R01 May 18, 2020 April 30, 2025
Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct
and operate the emission source(s)and associated air pollution control device(s) specified herein, in accordance with
the terms, conditions,and limitations within this permit. This permit is issued under the provisions of Article 21B of
Chapter 143, General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes
(15A NCAC), Subchapters 02D and 02Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 02Q, the Permittee shall not construct, operate, or modify any emission
source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application
to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Iconic Marine Group, LLC
Facility ID: 0700151
Facility Site Location: 1653 Whichards Beach Road
City, County, State,Zip: Washington,Beaufort County,NC,27889
Mailing Address: P.O.Drawer 457
City, State,Zip: Washington,NC,27889
Application Number: 0700151.18A
Complete Application Date: March 23,2020
Primary SIC Code: 3732
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington,NC,27889
Permit issued this the 18th day of May,2020
Wt'*f�vj' bkllfll�
William D. Willets,P.E., Chief, Air Permitting Section
By Authority of the Environmental Management Commission
Table Of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 Emission Source(s) Specific Limitations and Conditions (Including specific requirements,
testing,monitoring,recordkeeping, and reporting requirements)
2.2 Multiple Emission Source(s) Specific Limitations and Conditions (Including specific
requirements,testing,monitoring,recordkeeping, and reporting requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
Permit 10534T02
Page 3
SECTION I - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances:
Page Emission Source Emission Source Description Control Device Control Device
Number Description
4—6, Building No.3
9—11,
11—18 ES-03 Small Part Lamination&Mating C-3 Dry filters
MACT VVVV
7—8, Building ID No.4
9— 11,
11 —18 ES-04 Wood Finishing and Adhesive C-4 Dry filters
MACT VVVV Spraying
4—6, Building ID No. 5
9— 11,
11 —18 ES-05 Deck&Hull Lamination C-5 Dry filters
MACT VVVV
4—6, Building ID No. 10
9— 11,
11—18 ES-10 Mold Maintenance C-10 Dry filters
MACT VVVV
4—6, Building ID No. 11
9— 11,
11 —18 ES-11 Cruiser Lamination C-11 Dry filters
MACT VVVV
4—6, Building ID No. 15
9— 11,
11 —18 ES-15 Tooling C-15 Dry filters
MACT VVVV
4—6, Building ID No. 16
9- 11
ES-16 Paint Booth#1 C-16 Dry filters
4—6, Building ID No. 17
9- 11
ES-17 Paint Booth#2 C-17 Dry filters
4—6, Building ID No. 19
9- 11
ES-19 Paint Booth#3 C-19 Dry filters
Permit 10534T02
Page 4
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 — Emission Source(s) and Control Devices(s) Specific Limitations and
Conditions
The emission source(s)and associated air pollution control device(s) and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Fiberglass Boat Manufacturing Operations consisting of:
• Building ID No.3 (ID No.ES-03; Small Part Lamination &Mating) and associated dry
filters (ID No. C-3)
• Building ID No. 5 (ID No. ES-05; Deck& Hull Lamination) and associated dry filters (ID
No. C-5)
• Building ID No. 10 (ID No. ES-10; Mold Maintenance) and associated dry filters(ID No. C-
10)
• Building ID No. 11 (ID No.ES-11; Cruiser Lamination) and associated dry filters (ID No.
C-11)
• Building ID No. 15 (ID No. ES-15; Tooling) and associated dry filters (ID No. C-15)
• Building ID No. 16 (ID No. ES-16; Paint Booth#1) and associated dry filters(ID No. C-16)
• Building ID No. 17 (ID No. ES-17; Paint Booth#2) and associated dry filters (ID No. C-17)
• Building ID No. 19 (ID No. ES-19; Paint Booth#3) and associated dry filters(ID No. C-19)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter E=4.10(P )for process rates less than or equal to 30 tons per hour 15A NCAC 02D.0515
E=55.0 x P0-11 -40 for process rates greater than 30 tons per hour
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D.0521
Hazardous air HAP emission limits—See Section 2.2 B. 15A NCAC 02D.I 111
pollutants Building ID Nos. 16, 17 and 19 are not affected sources under (40 CFR Part 63—
Subpart VVVV[40 CFR§63.5683(d)and 63.5689] Subpart VVVV)
Odorous emissions State-enforceable only-See Section 2.2 A.4. 15A NCAC 02D.1806
Volatile organic Facility-wide less than 250 tons per year—See Section 2.2 A.1. 15A NCAC 02Q.0317
compounds
Toxic air pollutants State-enforceable only-See Section 2.2 A.2. 15A NCAC 02Q .0711
State-enforceable only-See Section 2.2 A.3. 15A NCAC 02D .1100
1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the lamination,mating and gel coating operations(ID No.ES-03,
ES-05 and ES-11);mold maintenance operations(ID No.ES-10);tooling operations (ID No.ES-15);
and painting operations(ID Nos.ES-16,ES-17 and ES-19)shall not exceed an allowable emission rate
as calculated by the following equations:
Permit 10534T02
Page 5
E=4.10 x P 0.17 (for process rates less than or equal to 30 tons per hour)
E=55.0 x P0.11 -40 (for process rates greater than 30 tons per hour)
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.La. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0515.
Monitoring [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the lamination,mating and gel coating operations(ID No.ES-03,ES-
05 and ES-11);mold maintenance operations (ID No.ES-10); tooling operations(ID No.ES-15); and
painting operations (ID Nos.ES-16,ES-17 and ES-19) shall be controlled by dry filter systems(ID
Nos. C-3, C-5, C-10,C-11,C-15 through C-17, and C-19). To ensure compliance,the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations, or if there are no manufacturer's
inspection and maintenance recommendations,as a minimum,the inspection and maintenance
requirement shall include the following:
i. a monthly visual inspection of the filters noting condition; and
ii. an annual(for each 12 month period following the initial inspection)inspection of the dry filter
system's structural integrity.
The Permittee Shall be deemed in noncompliance with 15A NCAC 02D .0515 if the dry filters are not
inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on the dry filter system; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the dry filter system within 30
days of a written request by the DAQ.
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 A.Lc and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
Page 6
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the lamination and mating operations(ID No.ES-03,ES-05 and ES-11);mold
maintenance operations(ID No.ES-10); tooling operations(ID No.ES-15); and painting operations
(ID Nos.ES-16,ES-17 and ES-19)shall not be more than 20 percent opacity when averaged over a
six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit give in Section 2.1 A.2.a above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To ensure compliance, once a month the Permittee shall observe the emission points of the lamination
and mating operations(ID No.ES-03,ES-05 and ES-11); mold maintenance operations (ID No.ES-
10);tooling operations (ID No.ES-15); and painting operations(ID Nos.ES-16,ES-17 and ES-19)
controlled by dry filter systems(ID Nos. C-3,C-5,C-10,C-11,C-15 through C-17, and C-19) for any
visible emissions above normal. The monthly observation must be made for each month of the calendar
year period to ensure compliance with this requirement. If visible emissions from these sources are
observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 02D .2610 (Method 9)for 12 minutes is below the limit given in Section 2.1 A.2.a
above.
The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if the required
monthly observations are not conducted as required; if the above-normal emissions are not corrected
within the monitoring period or the percent opacity demonstration cannot be made.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508 (Q
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Sections 2.1 A.2.c and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
Page 7
B. Building ID No. 04 (ID No. ES-4; Wood Finishing and Adhesive Spraying) with associated dry
filters (ID No. C-4)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter Adequate ductwork and properly designed collectors 15A NCAC 02D.0512
Visible emissions 20 percent opacity 15A NCAC 02D.0521
Hazardous air pollutants HAP emission limits—See Section 2.2 B. 15A NCAC 02D .I I 11
(40 CFR Part 63—
Subpart VVVV)
Odorous emissions State-enforceable only—See Section 2.2 A.4 15A NCAC 02D .1806
Volatile organic Less than 250 tons per year facility-wide-See Section 2.2 A.1. 15A NCAC 02Q .0317
compounds
Toxic air pollutants State-enforceable only-See Section 2.2 A.2. 15A NCAC 02Q.0711
State-enforceable only-See Section 2.2 A.3. 15A NCAC 02D.1100
1. 15A NCAC 02D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS
FINISHING PLANTS
a. The Permittee shall not cause, allow, or permit particulate matter caused by the working, sanding, or
finishing of wood to be discharged from any stack,vent,or building into the atmosphere without
providing,as a minimum for its collection, adequate duct work and properly designed collectors. In no
case shall the ambient air quality standards be exceeded beyond the property line.
Monitoring [15A NCAC 02Q .0508(f)]
b. Particulate matter emissions from the wood finishing and adhesive spraying(ID No.ES-04) shall be
controlled by a dry filter system(ID No. C-4). To ensure compliance,the Permittee shall perform
inspections and maintenance as recommended by the manufacturer,if any. As a minimum,the
inspection and maintenance program shall include:
i. monthly inspection of the dry filters noting the condition; and
ii. annual(for each 12 month period following the initial inspection)inspection of the associated
ductwork noting structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if the ductwork and/or
dry filters are not inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
c. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection; and
iii. the results of maintenance performed on any filters.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit the results of any maintenance performed on the filters or ductwork within
30 days of a written request by the DAQ.
Permit 10534T02
Page 8
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 B.Lb and c above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the wood finishing and adhesive spraying(ID No.ES-04)shall not be more than
20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods
may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour
period. In no event shall the six-minute average exceed 87 percent opacity.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 13.2.a above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To ensure compliance, once a month the Permittee shall observe the emission points of the wood
finishing and adhesive spraying(ID No. ES-04)controlled a dry filter system(ID No.C-4)for any
visible emissions above normal. The monthly observation must be made for each month of the calendar
year period to ensure compliance with this requirement. If visible emissions from this source are
observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 13.2.
a. above.
The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if the required
weekly observations are not conducted as required; if the above-normal emissions are not corrected
within the monitoring period or the percent opacity demonstration cannot be made.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508 (f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 B.2 c and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
Page 9
2.2 —Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-wide—All emission sources.
The following table provides a summary of limits and standards for the emission sources:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Facility-wide 15A NCAC 02Q .0317
Less than 250 tons per consecutive 12 months PSD Avoidance for
15 NCAC 02D .0530
Toxic air pollutants Facility-wide State Enforceable Only
Emissions limits for toxic air pollutant emission rates 15A NCAC 02D .0711
Toxic air pollutants Facility-wide State Enforceable Only
Modeled emission rates 15A NCAC 02D .1100
[except Building No. 10(ID No.ES-10)]
Odorous emissions Facility-wide State-enforceable only
Odorous emissions must be controlled 15A NCAC 02D .1806
1. 15A NCAC 02Q. 0317: AVOIDANCE CONDITIONS (PSD Avoidance)
for 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, facility-wide emissions shall be less than 250 tons of
volatile organic compounds(VOCs)per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material by the appropriate emission factor(EF). The
Permittee shall use either Unified Emission Factors(UEF)for Open Molding of Composites,AP-42
factors, or other such factors approved by the Division. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed the limit in Section 2.2.A.La. above.
Reporting [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities given in
Sections 2.2.A.Lb and c above 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 monthly VOC
emissions for the previous 17 months. The emissions must be calculated for each of the 12-month
periods over the previous 17 months.
State-enforceable only
2. 15A NCAC 02Q .0711: EMISSION RATES REQUIRING A PERMIT
a. The facility shall be operated and maintained in such a manner that any new, existing or increased actual
emissions of any Toxic Air Pollutant(TAP)listed in 15A NCAC 02Q .0711 or in this permit from all
sources at the facility(excluding those sources exempt under 15A NCAC 02Q .0702 "Exemptions"),
including fugitive emissions and emission sources not otherwise required to have a permit,will not
Permit 10534T02
Page 10
exceed its respective TAP permitting emission rates(TPER) listed in 15A NCAC 02Q .0711 without
first obtaining an air permit to construct or operate.
b. PRIOR to exceeding any of the TPERs listed in 15A NCAC 02Q .0711,the Permittee shall be
responsible for obtaining an air permit to emit TAPS and for demonstrating compliance with the
requirements found in 15A NCAC 02D .1100 "Control of Toxic Air Pollutants."
c. The Permittee shall maintain at the facility records of operational information sufficient for
demonstrating to the Division of Air Quality staff that actual TAPs are less than the rate listed in 15A
NCAC 02Q .0711.
d. The TPER table listed below is provided to assist the Permittee in determining when an air permit is
required pursuant to 15A NCAC 02Q .0711 and may not represent all TAPs being emitted from the
facility. This table will be updated at such time as the permit is either modified or renewed.
TPERs Limitations
Pollutant Carcinogens Chronic Toxicants Acute Systemic Toxicants Acute Irritants
(CAS Number) (lb/yr) (lb/day) (lb/hr) (lb/hr)
Ethyl Acetate
36
(141-78-6)
Methyl Ethyl Ketone 78 22.4
(78-93-3)
Methyl Isobutyl Ketone 52 7.6
(108-10-1)
Methylene Chloride 1600 0.39
(75-09-2)
Toluene 98 14.4
(108-88-3)
Xylene 57 16.4
(1330-20-7)
Formaldehyde
0.04
(50-0-0)
n-Hexane 23
(110-54-3)
State-enforceable only
3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. Pursuant to 15A NCAC 02D .1100 and in accordance with the approved application(0700151.19A) for
an air toxic compliance demonstration the following permit limit shall not be exceeded:
EMISSION SOURCE TOXIC AIR POLLUTANT EMISSION LIMIT
Building No. 3 (ID No.ES-03), Styrene(100-42-5) 45.0 lb/hr
Building No.4(ID No.ES-04),
Building No. 5 (ID No.ES-05),
Building No. 11 (ID No.ES-11),
Building No. 15(ID No.ES-15),
Building Nos. 16, 17 and 19
(ID Nos.ES-16,ES-17 and ES-19)
b. The Permittee has submitted a toxic air pollutant dispersion modeling analysis dated May 23,2019 for
the facility's toxic air pollutant emissions as listed in the above table. The modeling analysis was
reviewed and approved by the AQAB on July 17,2019. Placement of the emission sources,
configuration of the emission points, and operation of the sources shall be in accordance with the
Permit 10534T02
Page 11
submitted dispersion modeling analysis and should reflect any changes from the original analysis
submittal as outlined in the AQAB review memo.
c. For compliance purposes,the Permittee shall submit a report to the DAQ Regional Supervisor
postmarked on or before 30 days after each calendar year quarter containing the following:
i. The maximum hourly emission rate of styrene from the sources listed in 2.2 3.a. above.
State-enforceable only
4. 15A NCAC 02D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
B. Affected sources—National Emission Standards for Hazardous Air Pollutants for Boat
Manufacturing:
• Building No. 3 (ID No. ES-03),
• Building No. 4 (ID No. ES-04),
• Building No. 5 (ID No. ES-05),
• Building No. 10 (ID No. ES-10),
• Building No. 11 (ID No. ES-11), and
• Building No. 15 (ID No. ES-15).
1. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY for 40 CFR Part
63, Subpart VVVV: National Emission Standards for Hazardous Air Pollutants for Boat
Manufacturing
a. For each boat manufacturing emission source at this facility(ID Nos.ES-03,ES-04,ES-05,ES-10,ES-
11 and ES-15),the Permittee shall comply with all applicable provisions contained in Environmental
Management Commission Standard 15A NCAC 02D .1111 "Maximum Achievable Control
Technology"as promulgated in 40 CFR Part 63, Subpart VVVV"National Emission Standards for
Hazardous Air Pollutants for Boat Manufacturing,"including Subpart A"General Provisions." [40 CFR
§63.5683 and§63.5689]
Emission Limits for Open Molding Resin and Gel Coat Operations [40 CFR§63.56981
b. The Permittee shall limit organic HAP emissions from any of the following open molding operations to
the emission limit specified in Section 2.2 B.Lc below. Operations listed in Section 2.2 B.Ld are
exempt from this limit.
i Production resin.
ii. Pigmented gel coat.
iii. Clear gel coat.
iv. Tooling resin.
v. Tooling gel coat.
c. The Permittee shall limit organic HAP emissions from open molding operations to the limit specified
by Equation 1 of this condition below,based on a 12-month rolling average.
HAP Limit= [46(MR)+ 159(MpG) + 291(McG) + 54(MTR)+ 214(MTG)] (Equation 1)
Permit 10534T02
Page 12
Where:
HAP Limit = Total allowable organic HAP that can be emitted from the open molding
operations,kilograms.
MR = Mass of production resin used in the past 12 months, excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
MPG = Mass of pigmented gel coat used in the past 12 months,excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
MCA = Mass of clear gel coat used in the past 12 months, excluding any materials
exempt under Section 2.2 B.Lb above, in units of megagrams.
MT = Mass of tooling resin used in the past 12 months,excluding any materials
exempt under Section 2.2 B.Lb iv, above, in units of megagrams.
MTc = Mass of tooling gel coat used in the past 12 months, excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
d. The materials specified in i through iii below are exempt from the open molding emission limit
specified in Section 2.2 B.Lc above.
i. Production resins (including skin coat resins) that must meet specifications for use in military
vessels or must be approved by the U.S. Coast Guard for use in the construction of lifeboats,rescue
boats, and other life-saving appliances approved under 46 CFR Subchapter Q or the construction of
small passenger vessels regulated by 46 CFR Subchapter T. Production resins for which this
exemption is used must be applied with nonatomizing (non-spray) resin application equipment. A
record must be kept of the resins which are being used for this exemption.
ii. Pigmented, clear, and tooling gel coat used for part or mold repair and touch up. The total gel coat
materials included in this exemption must not exceed 1 percent by weight of all gel coat used at the
facility on a 12-month rolling-average basis. A record must be kept of the amount of gel coats
which are being used for this exemption and copies of calculations showing that the exempt amount
does not exceed 1 percent of all gel coat used.
iii. Pure, 100 percent vinylester resin used for skin coats. This exemption does not apply to blends of
vinylester and polyester resins used for skin coats. The total resin materials included in the
exemption cannot exceed 5 percent by weight of all resin used at the facility on a 12-month rolling-
average basis. A record must be kept of the amount of 100 percent vinylester skin coat resin used
per month that is eligible for this exemption and copies of calculations showing that the exempt
amount does not exceed 5 percent of all resin used.
Complying with the Open Molding Emission Limit [40 CFR§63.5701 and§63.5704]
e. The Permittee shall use one or more of the options listed in paragraphs i and ii below,to meet the
emission limit in paragraphs c and d in this section for the resins and gel coats used in open molding
operations at the facility.
i. Maximum achievable control technology(MACT)model point value averaging(emissions
averaging)option. Demonstrate that emissions from the open molding resin and gel coat operations
that are averaged meet the emission limit in paragraphs c and d above using the procedures
described in 40 CFR§63.5710. Compliance with this option is based on a 12-month rolling
average.
ii. Compliant materials option. Demonstrate compliance by using resins and gel coats that meet the
organic HAP content requirements in Table 1 below. Compliance with this option is based on a 12-
month rolling average.
Permit 10534T02
Page 13
Table 1: Alternative Organic HAP Content Requirements for Open Molding Resin and Gel Coat
Operations [40 CFR Part 63 Subpart VVVV,Table 21
You must not exceed this
For this operation- And this application weighted-average organic
method- HAP content(weight percent)
requirement-
1. Production resin operations Atomized(spray) 28 percent
2. Production resin operations Nonatomized(nonspray) 35 percent
3. Pigmented gel coat operations Any method 33 percent
4. Clear gel coat operations Any method 48 percent
5. Tooling resin operations Atomized(spray) 30 percent
6. Tooling resin operations Nonatomized(nonspray) 39 percent
7. Tooling gel coat operations Any method 40 percent
Demonstrating Compliance using Compliant Materials [40 CFR§63.5704(b) and §63.5713]
f. For each open molding operation complying using the compliant materials option, the Permittee must
demonstrate compliance by performing the steps in the following paragraphs i through iv:
i. Use the methods specified in paragraphs g through j of this section to determine the organic HAP
content of resins and gel coats.
ii. Complete the calculations described in paragraph j below to show that the weighted-average
organic HAP content does not exceed the limit specified in Table 1 above.
iii. Keep records as specified in paragraphs(A)through(D)below for each resin and gel coat.
(A) Hazardous air pollutant content.
(B) Application method for production resin and tooling resin. This record is not required if all
production resins and tooling resins are applied with nonatomized technology.
(C) Amount of material used per month. This record is not required for an operation if all
materials used for that operation comply with the organic HAP content requirements.
(D) Calculations performed, if required, to demonstrate compliance based on weighted-average
organic HAP content as described in paragraphs h through k of this section.
iv. Submit semiannual compliance reports to the Division as specified in paragraph aa. of this section.
g. Compliance using the organic HAP content requirements listed in Table I "Alternative Organic HAP
Content Requirements for Open Molding Resin and Gel Coat Operations," is based on a 12-month
rolling average that is calculated at the end of every month. If the Permittee is using filled material
(production resin or tooling resin), the Permittee must comply according to the procedure described
paragraph 1 of this section. [40 CFR§63.5713(a)]
h. At the end of the twelfth month after the Permittee's compliance date and at the end of every
subsequent month, review the organic HAP contents of the resins and gel coats used in the past 12
months in each operation. If all resins and gel coats used in an operation have organic HAP contents no
greater than the applicable organic HAP content limits in Table 1, then the Permittee is in compliance
with the emission limit specified in Section 2.2 B.l.c for that 12-month period for that operation. In
addition, the Permittee does not need to complete the weighted- average organic HAP content
calculation contained in paragraph j for that operation. [40 CFR§63.5713(b)]
Permit 10534T02
Page 14
i. At the end of every month, the Permittee must use Equation 2 of this condition to calculate the
weighted-average organic HAP content for all resins and gel coats used in each operation in the past 12
months.
M,HAP,.
Weighted-Average HAP Content (%)_ '-' (Equation 2)
M;
Where:
M, = Mass of open molding resin or gel coat"i"used during the past 12 months in an
operation,megagrams.
HAP, = Organic HAP content, by weight percent, of open molding resin or gel coat i
used in the past 12 months in an operation. Use the methods in Section 2.2 B.l.w
below to determine organic HAP content.
n = The number of different open molding resins or gel coats used during the past 12
months in an operation.
[40 CFR§63.5713(c)]
j. If the weighted-average organic HAP content does not exceed the applicable organic HAP content limit
specified in Table 1, then the Permittee is in compliance with the emission limit specified in Section 2.2
B.l.c. [40 CFR§63.5713(d)]
Demonstrating Compliance using Filled Resins [40 CFR§63.5710(d)and §63.5714]
k. i. If the Permittee is using a filled production resin or filled tooling resin,the Permittee must
demonstrate compliance for the filled material on an as-applied basis using Equation 3 of this
condition.
PVF =PV° 100 100 iller (Equation 3)
Where:
PVF = The as-applied MACT model point value for a filled production resin or
tooling resin,kilograms organic HAP per megagram of filled material.
PVu = The MACT model point value for the neat(unfilled)resin,before filler is
added,as calculated using the formulas in Table 2 "MACT Model Point
Value Formulas for Open Molding Operations"as contained in 40 CFR Part
63, Subpart VVVV(inserted below,for convenience).
Filler = The weight-percent of filler in the as applied filled resin system.
ii. If the filled resin is used as a production resin and the value of PVF calculated by Equation 3 of
Section 2.2 B.l.k.i, above, does not exceed 46 kilograms of organic HAP per megagram of filled
resin applied,then the filled resin is in compliance.
iii. If the filled resin is used as a tooling resin and the value of PVF calculated by Equation 3 of Section
2.2 B.l.k.i, above, does not exceed 54 kilograms of organic HAP per megagram of filled resin
applied,then the filled resin is in compliance.
Permit 10534T02
Page 15
Table 2: MACT Model Point Value Formulas for Open Molding Operations'
[40 CFR Part 63 Subpart VVVV,Table 31
Use this formula to calculate the
For this operation- And this application method- MACT model plant value for
each resin and gel coat-
1. Production resin,tooling a.Atomized 0.014 X (Resin HAP%)2.425
resin
b. Atomized,plus vacuum bagging 0.01185 X (Resin HAP%)2'425
with roll-out
c.Atomized,plus vacuum bagging 0.00945 x (Resin HAP%)2.425
without roll-out
d.Nonatomized 0.014 X (Resin HAP%)2.275
e.Nonatomized,plus vaccum bagging 0.0110 x (Resin HAP%)2.275
with roll-out
f.Nonatomized,plus vacuum bagging 0.0076 X (Resin HAP%)2.275
without roll-out
2. Pigmented gel coat, clear All methods 0.445 x (Gel coat HAP%)1.675
gel coat,tooling gel coat
Equations calculate MACT model point value in kilograms of organic HAP per megagrams of resin or gel coat
applied.The equations for vacuum bagging with roll-out are applicable when a facility rolls out the applied resin
and fabric prior to applying the vacuum bagging materials.The equations for vacuum bagging without roll-out are
applicable when a facility applies the vacuum bagging materials immediately after resin application without
rolling out the resin and fabric.HAP%=organic HAP content as supplied,expressed as a weight-percent value
between 0 and 100 percent.
Standards for Resin and Gel Coat Mixing Operations [40 CFR 63.5731]
1. The Permittee shall cover at all times all resin and gel coat mixing containers with a capacity equal to
or greater than 208 liters (55 gallons), including those used for on-site mixing of putties and
polyputties,must have a cover with no visible gaps in place at all times.
m. The work practice standard in paragraph m above, does not apply when material is being manually
added to or removed from a container, or when mixing or pumping equipment is being placed in or
removed from a container.
n. To demonstrate compliance with the work practice standard in paragraph m above, the Permittee must
visually inspect all mixing containers subject to this standard at least once per month. The inspection
should ensure that all containers have covers with no visible gaps between the cover and the container,
or between the cover and equipment passing through the cover.
o. The Permittee must keep records of which mixing containers are subject to this standard and the results
of the inspections,including a description of any repairs or corrective actions taken.
Standards for Resin and Gel Coat Application Equipment Cleaning Operations [40 CFR 63.5734
and 63.57371
p. For routine flushing of resin and gel coat application equipment(e.g., spray guns, flowcoaters, brushes,
rollers, and squeegees), the Permittee must use a cleaning solvent that contains no more than 5 percent
organic HAP by weight. For removing cured resin or gel coat from application equipment, no organic
HAP content limit applies.
q. The Permittee must store organic HAP-containing solvents used for removing cured resin or gel coat in
containers with covers. The covers must have no visible gaps and must be in place at all times, except
when equipment to be cleaned is placed in or removed from the container. On containers with a
capacity greater than 7.6 liters (2 gallons), the distance from the top of the container to the solvent
Permit 10534T02
Page 16
surface must be no less than 0.75 times the diameter of the container. Containers that store organic
HAP-containing solvents used for removing cured resin or gel coat are exempt from the requirements of
40 CFR Part 63, Subpart T (National Emission Standards for Halogenated Solvent Cleaning). Cured
resin or gel coat means resin or gel coat that has changed from a liquid to a solid.
r. Determine and record the organic HAP content of the cleaning solvents subject to the standards
specified in paragraphs q and r above,using the methods specified in Section 2.2 B.1.w below.
s. If the Permittee recycles cleaning solvents on site, the Permittee may use documentation from the
solvent manufacturer or supplier or a measurement of the organic HAP content of the cleaning solvent
as originally obtained from the solvent supplier for demonstrating compliance, subject to the conditions
in paragraph w below demonstrating compliance with organic HAP content limits.
t. At least once per month, the Permittee must visually inspect any containers holding organic HAP-
containing solvents used for removing cured resin and gel coat to ensure that the containers have covers
with no visible gaps. Keep records of the monthly inspections and any repairs made to the covers.
Demonstrating Compliance with Carpet and Fabric Adhesive Operations [40 CFR 63.5740]
u. The Permittee must use carpet and fabric adhesives that contain no more than 5 percent organic HAP by
weight.
v. To demonstrate compliance with the emission limit in paragraph v above, you must determine and
record the organic HAP content of the carpet and fabric adhesives using the methods in paragraph w
below.
Methods for Determining Organic Hazardous Air Pollutant Content [40 CFR 63.5758]
w. To determine the organic HAP content for each material used in the Permittee's open molding resin and
gel coat operations, carpet and fabric adhesive operations, or aluminum recreational boat surface
coating operations,the Permittee shall use one of the options in paragraph i through vi.
i. Method 311 (appendix A to 40 CFR Part 63). The Permittee may use Method 311 for determining
the mass fraction of organic HAP. Use the procedures specified in (A) and (B) below, when
determining organic HAP content by Method 311.
(A)Include in the organic HAP total each organic HAP that is measured to be present at 0.1
percent by mass or more for Occupational Safety and Health Administration (OSHA)-defined
carcinogens as specified in 29 CFR §1910.1200(d)(4) and at 1.0 percent by mass or more for
other compounds. For example, if toluene (not an OSHA carcinogen) is measured to be 0.5
percent of the material by mass, the Permittee does not need to include it in the organic HAP
total. Express the mass fraction of each organic HAP the Permittee measures as a value
truncated to four places after the decimal point(e.g., 0.1234).
(B) Calculate the total organic HAP content in the test material by adding up the individual organic
HAP contents and truncating the result to three places after the decimal point(e.g., 0.123).
ii. Method 24 (Appendix A to 40 CFR Part 63). The Permittee may use Method 24 to determine the
mass fraction of non-aqueous volatile matter of aluminum coatings and use that value as a
substitute for mass fraction of organic HAP.
iii. ASTM D1259-85 (Standard Test Method for Nonvolatile Content of Resins). The Permittee may
use ASTM D1259-85 (available for purchase from ASTM)to measure the mass fraction of volatile
matter of resins and gel coats for open molding operations and use that value as a substitute for
mass fraction of organic HAP.
iv. Alternative method. The Permittee may use an alternative test method for determining mass fraction
of organic HAP if the Permittee obtains prior approval by EPA Region IV. The Permittee must
follow the procedure in 40 CFR§63.7(f)to submit an alternative test method for approval.
v. Information from the supplier or manufacturer of the material. The Permittee may rely on
information other than that generated by the test methods specified in paragraphs i through iv,
above, such as manufacturer's formulation data, according to (A)through(C),below.
Permit 10534T02
Page 17
(A)Include in the organic HAP total each organic HAP that is present at 0.1 percent by mass or
more for OSHA-defined carcinogens as specified in 29 CFR §1910.1200(d)(4) and at 1.0
percent by mass or more for other compounds. For example, if toluene (not an OSHA
carcinogen) is 0.5 percent of the material by mass, the Permittee does not have to include it in
the organic HAP total.
(B) If the organic HAP content is provided by the material supplier or manufacturer as a range,then
the Permittee must use the upper limit of the range for determining compliance. If a separate
measurement of the total organic HAP content using the methods specified in Sections 2.2
B.l.w.i through iv, above, exceeds the upper limit of the range of the total organic HAP content
provided by the material supplier or manufacturer, then the Permittee must use the measured
organic HAP content to determine compliance.
(C) If the organic HAP content is provided as a single value, the Permittee may assume the value is
a manufacturing target value and actual organic HAP content may vary from the target value. If
a separate measurement of the total organic HAP content using the methods specified in
paragraphs i through iv, above, is less than 2 percentage points higher than the value for total
organic HAP content provided by the material supplier or manufacturer, then the Permittee may
use the provided value to demonstrate compliance. If the measured total organic HAP content
exceeds the provided value by 2 percentage points or more, then the Permittee must use the
measured organic HAP content to determine compliance.
vi. Solvent blends. Solvent blends may be listed as single components for some regulated materials in
certifications provided by manufacturers or suppliers. Solvent blends may contain organic HAP
which must be counted toward the total organic HAP content of the materials. When detailed
organic HAP content data for solvent blends are not available, the Permittee may use the values for
organic HAP content that are listed in Table 5 "Default Organic HAP Contents of Solvents and
Solvent Blends" or Table 6 "Default Organic HAP Contents of Petroleum Solvent Groups" as
contained in 40 CFR Part 63, Subpart VVVV. The Permittee may use Table 6 as contained in 40
CFR Part 63, Subpart VVVV, only if the solvent blends in the materials the Permittee use do not
match any of the solvent blends in Table 5 as contained in 40 CFR Part 63, Subpart VVVV, and the
Permittee knows only whether the blend is either aliphatic or aromatic. However, if test results
indicate higher values than those listed in Table 5 or 6 as contained in 40 CFR Part 63, Subpart
VVVV,then the test results must be used for determining compliance.
Table 6"Default Organic HAP Contents of Petroleum Solvent Groups"
Recordkeeping [15A NCAC 02Q .0508(f),40 CFR 63.5764,40 CFR 63.5767 and 40 CFR 63.57701
x. The Permittee shall keep the following records:
i. a copy of each notification and report that the Permittee submitted to comply with 40 CFR Part 63,
Subpart VVVV;
ii. all documentation supporting any notification or report that the Permittee submitted; and
iii. the total amounts of open molding production resin,pigmented gel coat, clear gel coat,tooling resin,
and tooling gel coat used per month and the weighted-average organic HAP contents for each
operation, expressed as weight-percent. For open molding production resin and tooling resin, the
Permittee shall also record the amounts of each applied by atomized and nonatomized methods.
y. The Permittee shall keep each record:
i. readily available and in a form so they can be easily inspected and reviewed.
ii. for 5 years following the date that each record is generated.
iii. on site for at least 2 years after the date that each record is generated. The Permittee can keep the
records offsite for the remaining 3 years.
iv. on paper or an electronic device.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I I I I if these records are not
maintained.
Permit 10534T02
Page 18
Reporting [15A NCAC 02Q .0508(f),40 CFR 63.5761 and 40 CFR 63.5764]
z. The Permittee shall submit a semiannual compliance report that covers the period from 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. All instances of deviations
from the requirements of this permit must be clearly identified. Each compliance report must be
postmarked no later than 60 days from the end of the semiannual reporting period. At a minimum,the
compliance report shall contain:
i. Company name and address;
ii. A statement by a responsible official with that official's name,title, and signature,certifying the
truth, accuracy, and completeness of the report;
iii. The date of the report and the beginning and ending dates of the reporting period;
iv. A description of any changes in the manufacturing process since the last compliance report;
v. A statement or table showing, for each regulated operation,the applicable organic HAP content
limit, application equipment requirement, or MACT model point value averaging provision with
which the facility is complying. The statement or table shall also show the actual weighted-average
organic HAP content or weighted-average MACT model point value(if applicable)for each
operation during each of the rolling 12-month averaging periods that end during the reporting
period;
vi. If the facility was in compliance with the emission limits and work practice standards during the
reporting period,the Permittee shall include a statement to that effect; and
vii. If the Permittee deviated from an emission limit or work practice standard during the reporting
period,the he shall also include the following information in the semiannual compliance report:
(A)A description of the operation involved in the deviation,
(B) The quantity, organic HAP content, and application method(if relevant)of the materials
involved in the deviation,
(C) A description of any corrective action the Permittee took to minimize the deviation and actions
he has taken to prevent it from happening again, and
(D)A statement of whether or not the facility was in compliance for the 12-month averaging period
that ended at the end of the reporting period.
aa. The Permittee must submit all of the notifications in Table 7 as contained in 40 CFR Part 63 Subpart
VVVV,that apply to the Permittee by the dates in the table. The notifications are described more fully
in 40 CFR Part 63, Subpart A"General Provisions,"referenced in Table 8 as contained in 40 CFR Part
63 Subpart VVVV. If the Permittee changes any information submitted in any notification,the
Permittee must submit the changes in writing to the Division within 15 calendar days after the change.
bb. The Permittee may switch between the compliance options(Emissions Averaging and Compliant
Materials)in 40 CFR Part 63, Subpart VVVV per the requirements of paragraphs i. and ii below. In all
cases,the Permittee shall submit notification to change options, in writing,to the Division of Air
Quality, 15 days prior to changing compliance options. [40 CFR 63.5710 and 40 CFR 63.5713]
i. Changing from compliant materials to 12-month emissions averaging: The Permittee shall begin
collecting resin and gel coat usage data on the date the compliance option is switched. The source
shall demonstrate compliance using the emissions averaging option for at least 12 consecutive
months.
ii. Changing from 12-month emissions averaging to compliant materials: The Permittee shall begin
complying with the compliant materials option on the date the compliance option is switched. Until
the full 12-month compliance period has ended the Permittee shall continue to collect resin and gel
coat usage data and calculate the 12-month emissions average.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I I I I if the reporting
requirements above are not met.
Permit 10534T02
Page 19
SECTION 3 — GENERAL CONDITIONS (version 5.3, 08/21/2018)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in
15A NCAC 02D and 02Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and
enforceable pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or
criminal penalties. Any unauthorized deviation from the conditions of this permit may constitute grounds
for revocation and/or enforcement action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other
aspects of the facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,
animal or plant life, or property caused by the construction or operation of this permitted facility, or from
penalties therefore, nor does it allow the Permittee to cause pollution in contravention of state laws or
rules, unless specifically authorized by an order from the North Carolina Environmental Management
Commission.
5. Except as identified as state-only requirements in this permit, all terms and conditions contained herein
shall be enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal
Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the
appropriate and valid permits issued by the DAQ, unless the source is exempted by rule. The DAQ may
issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in
violation of any of the applicable requirements. A permitted installation may only be operated,
maintained,constructed,expanded,or modified in a manner that is consistent with the terms of this permit.
B. Permit Availability[15A NCAC 02Q .0507(k)and.0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the
permit term one complete copy of the application and any information submitted in support of the application
package. The permit and application shall be made available to an authorized representative of Department of
Environmental Quality upon request.
C. Severability Clause [15A NCAC 02Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be
invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those
held to be invalid,shall remain valid and must be complied with.
D. Submissions [15A NCAC 02Q .0507(e)and 02Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data,
notifications, request for renewal, and any other information required by this permit shall be submitted to the
appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. For
continuous emissions monitoring systems (GEMS) reports, continuous opacity monitoring systems (COMS)
reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM certification reports, and NOx
budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall
be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
Permit 10534T02
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E. Duty to Comply [15A NCAC 02Q .0508(i)(3)]
The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in
this permit. Noncompliance with any permit condition except conditions identified as state-only requirements
constitutes a violation of the Federal Clean Air Act. Noncompliance with any permit condition is grounds for
enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a
permit renewal application.
F. Circumvention-STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall
reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated
without the concurrent operation of its associated air pollution control device(s)and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 02Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A
NCAC 02Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q
.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC
02Q.0524 and 02Q .0505.
3. Minor Permit Modifications [15A NCAC 02Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC
02Q .0515.
4. Significant Permit Modifications [15A NCAC 02Q.0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A
NCAC 02Q .0516.
5. Reopening for Cause [15A NCAC 02Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q
.0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in
Section 1 must be reported to the Regional Supervisor,DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes; or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any necessary changes
in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation
of the emission limitations specified herein.
2. Section 502(b)(10)Changes [15A NCAC 02Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition.
Such changes do not include changes that would violate applicable requirements or contravene
federally enforceable permit terms and conditions that are monitoring (including test methods),
recordkeeping,reporting,or compliance certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Permittee notifies the Director and EPA with written notification at least seven days before the
change is made; and
Permit 10534T02
Page 21
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions; and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or
renewed,whichever comes first.
3. Off Permit Changes [15A NCAC 02Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
a. the change affects only insignificant activities and the activities remain insignificant after the change;
or
b. the change is not covered under any applicable requirement.
4. Emissions Trading[15A NCAC 02Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D, including subsequently adopted
maximum achievable control technology standards, emissions trading shall be allowed without permit
revision pursuant to 15A NCAC 02Q .0523(c).
LA Reportin ,Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D .0535(f) and 02Q
.0508(f)(2)]
"Excess Emissions" - means an emission rate that exceeds any applicable emission limitation or standard
allowed by any rule in Sections .0500, .0900, .1200, or .1400 of Subchapter 02D; or by a permit condition; or
that exceeds an emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note:Definitions
of excess emissions under 02D.II10 and 02D.I II I shall apply where defined by rule)
"Deviations"- for the purposes of this condition, any action or condition not in accordance with the terms and
conditions of this permit including those attributable to upset conditions as well as excess emissions as defined
above lasting less than four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS (15A NCAC 02D .0524),NESHAPS (15A
NCAC 02D .1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of
excess emissions,reporting shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 02D .0524), NESHAPS (15A NCAC 02D .1110 or
A 111), or these rules do NOT define "excess emissions," the Permittee shall report excess emissions in
accordance with 15A NCAC 02D .0535 as follows:
a. Pursuant to 15A NCAC 02D .0535, if excess emissions last for more than four hours resulting from a
malfunction, a breakdown of process or control equipment, or any other abnormal condition, the
owner or operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern Time of
the Division's next business day of becoming aware of the occurrence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration; and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished; and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A
NCAC 02D .0535(f)(3).
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Permit Deviations
3. Pursuant to 15A NCAC 02Q .0508(f)(2), the Permittee shall report deviations from permit requirements
(terms and conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not
covered under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall
include the probable cause of such deviation and any corrective actions or preventative actions taken.
The responsible official shall certify all deviations from permit requirements.
LB Other Requirements under 15A NCAC 02D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D .0535,
including 15A NCAC 02D .0535(c)as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of
the appropriate rule unless the owner or operator of the sources demonstrates to the Director, that the
excess emissions are a result of a malfunction. The Director shall consider, along with any other pertinent
information,the criteria contained in 15A NCAC 02D .0535(c)(1)through(7).
2. 15A NCAC 02D .0535(g). Excess emissions during start-up and shut-down shall be considered a
violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are
unavoidable.
J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the
control of the facility, including acts of God, which situation requires immediate corrective action to
restore normal operation, and that causes the facility to exceed a technology-based emission limitation
under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency
shall not include noncompliance to the extent caused by improperly designed equipment, lack of
preventive maintenance,careless or improper operation,or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the conditions specified in 3.below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of
emissions that exceeded the standards or other requirements in the permit; and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time
when emission limitations were exceeded due to the emergency. This notice must contain a
description of the emergency, steps taken to mitigate emissions,and corrective actions taken.
4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the
burden of proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement
specified elsewhere herein.
K. Permit Renewal[15A NCAC 02Q .0508(e)and 02Q .0513(b)]
This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the
end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q
.0500 renewal application is submitted at least six months before the date of permit expiration. If the Permittee
or applicant has complied with 15A NCAC 02Q .0512(b)(1), this 15A NCAC 02Q .0500 permit shall not
expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC 02Q .0400
terminates the facility's right to operate unless a complete 15A NCAC 02Q .0400 renewal application is
submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q
Permit 10534T02
Page 23
.0400 requirements. In either of these events, all terms and conditions of these permits shall remain in effect
until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 02Q.0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information) [15A NCAC 02Q.0508(i)(9)]
1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the Director
may request in writing to determine whether cause exists for modifying, revoking and reissuing, or
terminating the permit or to determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies
are requested by the Director. For information claimed to be confidential,the Permittee may furnish such
records directly to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement[15A NCAC 02Q .0507(f)]
The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was
submitted in the permit application, shall promptly submit such supplementary facts or corrected information
to the DAQ. The Permittee shall also provide additional information as necessary to address any requirement
that becomes applicable to the facility after the date a complete permit application was submitted but prior to
the release of the draft permit.
O. Retention of Records [15A NCAC 02Q .0508(f)and 02Q .0508(1)]
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. Supporting
information includes all calibration and maintenance records and all original strip-chart recordings for
continuous monitoring information, and copies of all reports required by the permit. These records shall be
maintained in a form suitable and readily available for expeditious inspection and review. Any records
required by the conditions of this permit shall be kept on site and made available to DAQ personnel for
inspection upon request.
P. Compliance Certification [15A NCAC 02Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4,
61 Forsyth Street SW, Atlanta, GA 30303) postmarked on or before March 1 a compliance certification (for
the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the
permit, including emissions limitations, standards, or work practices. It shall be the responsibility of the
current owner to submit a compliance certification for the entire year regardless of who owned the facility
during the year. The compliance certification shall comply with additional requirements as may be specified
under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status (with the terms and conditions of the permit for the period covered by the
certification);
3. whether compliance was continuous or intermittent; and
4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official[15A NCAC 02Q.0520]
A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or
compliance certification required by this permit. All certifications shall state that based on information and
belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and
complete.
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R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable
requirements,where such applicable requirements are included and specifically identified in the permit as
of the date of permit issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission, Secretary of the Department, or Governor under NCGS 143-
215.3(a)(12),or EPA under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to
the effective date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV;or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain
information to determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit
revision made under 15A NCAC 02Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 02Q.05191
The Director may terminate,modify,or revoke and reissue this permit if:
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or
5. the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to
carry out the purpose of NCGS Chapter 143,Article 21B.
T. Insignificant Activities [15A NCAC 02Q .05031
Because an emission source or activity is insignificant does not mean that the emission source or activity is
exempted from any applicable requirement or that the owner or operator of the source is exempted from
demonstrating compliance with any applicable requirement. The Permittee shall have available at the facility
at all times and made available to an authorized representative upon request, documentation, including
calculations,if necessary,to demonstrate that an emission source or activity is insignificant.
U. Property Rights [I 5A NCAC 02Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry[15A NCAC 02Q .0508(1)and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow
the DAQ,or an authorized representative,to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is
conducted,or where records are kept under the conditions of the permit;
b. have access to and copy, at reasonable times, any records that are required to be kept under the
conditions of the permit;
c. inspect at reasonable times and using reasonable safety practices any source, equipment (including
monitoring and air pollution control equipment), practices, or operations regulated or required under
the permit; and
d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose of
assuring compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee
under Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for
purposes of inspection, and who presents appropriate credentials,nor shall any person obstruct,hamper, or
interfere with any such authorized representative while in the process of carrying out his official duties.
Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties.
Permit 10534T02
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W. Annual Fee Payment[15A NCAC 02Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q.0200.
2. Payment of fees may be by check or money order made payable to the N.C. Department of Environmental
Quality. Annual permit fee payments shall refer to the permit number.
3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate
action to terminate the permit under 15A NCAC 02Q.0519.
X. Annual Emission Inventory Requirements [15A NCAC 02Q .02071
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A
NCAC 02Q .0207(a) from each emission source within the facility during the previous calendar year. The
report shall be in or on such form as may be established by the Director. The accuracy of the report shall be
certified by a responsible official of the facility.
Y. Confidential Information [15A NCAC 02Q .0107 and 02Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q
.0107, the Permittee may also submit a copy of all such information and claim directly to the EPA upon
request. All requests for confidentiality must be in accordance with 15A NCAC 02Q .0107.
Z. Construction and Operation Permits [15A NCAC 02Q.0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified
facility or emission source which is not exempted from having a permit prior to the beginning of construction
or modification,in accordance with all applicable provisions of 15A NCAC 02Q .0100 and.0300.
AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A
NCAC 02Q .0505 and.0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q.0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of
substantial compliance history.
CC. Refrigerant Requirements(Stratospheric Ozone and Climate Protection) [15A NCAC 02Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which
use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons
listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,
and maintain such equipment according to the work practices, personnel certification requirements, and
certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the
environment during the repair, servicing, maintenance, or disposal of any such device except as provided
in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports
shall be submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases-Section 112(r) [15A NCAC 02Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section
112(r)of the Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part
68.
Permit 10534T02
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EE.Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) — FEDERALLY-
ENFORCEABLE ONLY
Although a risk management plan may not be required, if the Permittee produces,processes,handles,or stores
any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are
necessary to prevent the accidental release of such substance and to minimize the consequences of any release.
FF. Title IV Allowances [I5ANCAC 02Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not
use allowances as a defense to noncompliance with any other applicable requirement. The Permittee's
emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean
Air Act.
GG.Air Pollution Emergency Episode [15A NCAC 02D .03001
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to
operate in accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of
an approved plan,with the appropriate requirements specified in 15A NCAC 02D .0300.
HH.Registration of Air Pollution Sources [15A NCAC 02D .0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is
required to register a source of air pollution, this registration and required information will be in accordance
with 15A NCAC 02D .0202(b).
II. Ambient Air Ouality Standards [15A NCAC 02D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,
any source of air pollution shall be operated with such control or in such manner that the source shall not cause
the ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on
which the source is located. When controls more stringent than named in the applicable emission standards in
this permit are required to prevent violation of the ambient air quality standards or are required to create an
offset,the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q .0508(i)(16)]
Emission compliance testing shall be by the procedures of Section .2600, except as may be otherwise
required in Rules .0524, .0912, .1110, .1111, or .1415 of Subchapter 02D. If emissions testing is required by
this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance,
the Permittee shall perform such testing in accordance with 15A NCAC 02D .2600 and follow the procedures
outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing. Testing protocols are not required to be pre-approved by the
Director prior to air pollution testing. The Director shall review air emission testing protocols for pre-
approval prior to testing if requested by the owner or operator at least 45 days before conducting the
test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable
standard shall notify the Director at least 15 days before beginning the test so that the Director may at
his option observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates
during the period of air testing. The owner or operator of the source shall ensure that the equipment or
process being tested is operated at the production rate that best fulfills the purpose of the test. The
individual conducting the emission test shall describe the procedures used to obtain accurate process
data and include in the test report the average production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days
after sample collection unless otherwise specified in the specific conditions. The owner or operator may
request an extension to submit the final test report. The Director shall approve an extension request if he
finds that the extension request is a result of actions beyond the control of the owner or operator.
Permit 10534T02
Page 27
a. The Director shall make the final determination regarding any testing procedure deviation and the
validity of the compliance test. The Director may:
i. Allow deviations from a method specified under a rule in this Section if the owner or operator
of the source being tested demonstrates to the satisfaction of the Director that the specified
method is inappropriate for the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative
method is necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test
method is specified in this Section if the methods can be demonstrated to determine compliance
of permitted emission sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source
subject to a rule in this Subchapter to determine the compliance status of that source or to verify any
test data submitted relating to that source. Any test conducted by the Division of Air Quality using
the appropriate testing procedures described in Section 02D .2600 has precedence over all other
tests.
KK.Reopening for Cause [15A NCAC 02Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three
or more years;
b. additional requirements (including excess emission requirements) become applicable to a source
covered by Title IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or other terms or conditions of the permit;or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with
the applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable
requirement is promulgated. No reopening is required if the effective date of the requirement is after the
expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q
.0513(c).
3. Except for the state-enforceable only portion of the permit, the procedures set out in 15A NCAC 02Q
.0507, .0521, or .0522 shall be followed to reissue the permit. If the State-enforceable only portion of the
permit is reopened, the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall
affect only those parts of the permit for which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be
reopened, except in cases of imminent threat to public health or safety the notification period may be less
than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the
EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the
EPA a proposed determination of termination,modification,or revocation and reissuance,as appropriate.
LL.Reporting Requirements for Non-Operating Equipment [15A NCAC 02Q.0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is
taken from and placed into operation. When permitted equipment is not in operation, the requirements for
testing,monitoring,and recordkeeping are suspended until operation resumes.
Permit 10534T02
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MM. Fugitive Dust Control Requirement[15A NCAC 02D .0540]
As required by 15A NCAC 02D .0540 "Particulates from Fugitive Dust Emission Sources,"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. If substantive complaints or excessive fugitive dust emissions from
the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference
Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as
described in 02D .0540(f).
Permit 10534T02
Page 29
"Fugitive dust emissions" means particulate matter from process operations that does not pass through a
process stack or vent and that is generated within plant property boundaries from activities such as: unloading
and loading areas, process areas, stockpiles, stock pile working, plant parking lots, and plant roads (including
access roads and haul roads).
NN. Specific Permit Modifications [I 5A NCAC 02Q.0501 and.0523]
1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2), the Permittee shall file a Title V Air
Quality Permit Application for the air emission source(s) and associated air pollution control device(s)
on or before 12 months after commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2), the Permittee shall not begin
operation of the air emission source(s) and associated air pollution control device(s) until a Title V Air
Quality Permit Application is filed and a construction and operation permit following the procedures of
Section.0500(except for Rule .0504 of this Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 02Q .0523(a)(1)(C),the
Permittee shall notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth Street SW,
Atlanta, GA 30303) in writing at least seven days before the change is made. The written notification
shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit
renewal, the Permittee shall submit a page "E5" of the application forms signed by the responsible official
verifying that the application for the 502(b)(10) change/modification, is true, accurate, and complete.
Further note that modifications made pursuant to 502(b)(10) do not relieve the Permittee from satisfying
preconstruction requirements.
00. Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and.0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency(EPA),
EPA's decision to not object to the proposed permit is considered final and binding on the EPA and absent a
third party petition, the failure to object is the end of EPA's decision-making process with respect to the
revisions to the permit. The time period available to submit a public petition pursuant to 15A NCAC 02Q
.0518 begins at the end of the 45-day EPA review period.
Permit 10534T02
Page 30
ATTACHMENT
List of Acronyms
AOS Alternative Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
S02 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound
O9 64 7u+F Cyr
ROY COOPER
Governor6
MICHAEL S.REGAN =
Secretary
MICHAEL ABRACZINSKAS "
.f
Director
NORTH CAROLINA
Environmental Quality
May 18,2020
Mr.Jeff Harris
Chief Operating Officer
Iconic Marine Group,LLC
P. O.Drawer 457
Washington,North Carolina 27889
SUBJECT: Air Quality Permit No. 10534T02
Facility ID: 0700151
Iconic Marine Group,LLC
Washington,North Carolina
Beaufort County
Fee Class: Title V
PSD Class: Minor
Dear Mr.Harris:
In accordance with your completed Air Quality Permit Application for a modification for a 1st Time
Title V permit received March 23, 2020, we are forwarding herewith Air Quality Permit No. 10534T02 to
Iconic Marine Group, LLC, 1653 Whichards Beach Road, Washington, North Carolina authorizing the
construction and operation,of air emissions source(s)and associated air pollution control device(s)specified
herein. Additionally, any emissions activities determined from your Air Quality Permit Application as
being insignificant per 15A North Carolina Administrative Code 02Q .0503(8) have been listed for
informational purposes as an "ATTACHMENT." Please note the requirements for the annual compliance
certification are contained in General Condition P in Section 3. The current owner is responsible for
submitting a compliance certification for the entire year regardless of who owned the facility during the
year.
As the designated responsible official it is your responsibility to review, understand, and abide by
all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person
who operates any emission source and associated air pollution control device subject to any term or
condition of the attached permit reviews,understands, and abides by the condition(s) of the attached permit
that are applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to
you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. This hearing request must be in the form of a written
petition, conforming to NCGS (North Carolina General Statutes) 150B-23, and filed with both the Office of
Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division
of Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The
form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of
Administrative Hearings. Please note that this permit will be stayed in its entirety upon receipt of the
request for a hearing. Unless a request for a hearing is made pursuant to NCGS 15013-23, this Air Quality
Permit shall be final and binding 30 days after issuance.
D Q2�
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA
Dsw rl or fmim66 bl aoaN
919.7OZ8400
Mr.Harris
May 18,2020
Page 2
Mr.Harris
May 18,2020
Page 3
You may request modification of your Air Quality Permit through informal means pursuant to
NCGS 150B-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that this Air Quality Permit will
become final and binding regardless of a request for informal modification unless a request for a hearing is
also made under NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of NCGS 143-215.108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure to
receive an Air Quality Permit or written approval prior to commencing construction is a violation of NCGS
143-215.108A and may subject the Permittee to civil or criminal penalties as described in NCGS 143-
215.114A and 143-215.114B.
Beaufort County has triggered increment tracking under PSD for PM10, SO2 and NOx. However,
this permit modification does not consume or expand increments for any pollutants.
This Air Quality Permit shall be effective from May 18, 2020 until April 30, 2025, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations as
specified therein.
Should you have any questions concerning this matter,please contact Judy lee at 919-707-8729 or
j udeeekncdenr.gov.
Sincerely_yours,
V�A4'
William D.Willets,P.E.,Chief,Permitting Section
Division of Air Quality,NCDEQ
c: Kelly Fortin,EPA Region 4
Washington Regional Office
Central Files
Connie Horne(cover letter only)
Mr.Harris
May 18,2020
Page 4
ATTACHMENT to Permit No. 10534T02
Insignificant Activities per 15A NCAC 02Q.0503(8)
Emission Source ID No. Emission Source Description
1-1 Solvent Cleaning Operations
1-2 One(1)resin storage tank(5,500 gallon capacity)
1-3 Twenty(20)gas-fired space heaters(125,000 to 175,000 Btu per hour capacity)
1-4 Eleven(11)gas-fired space heaters(325,000 to 375,000 Btu per hour capacity)
1-5 Three(3)gas-fired space heaters(2,000,000 to 2,600,000 Btu per hour capacity)
1-6 Two(2)gas-fired space heaters(3,500,000 to 4,000,000 Btu per hour capacity)
I-7 One(1)gas-fired space heater(6,650,000 Btu per hour capacity)
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement
or that the Permittee is exempted from demonstrating compliance with any applicable requirement.
2. When applicable,emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D.1100"Control of
Toxic Air Pollutants"or 02Q .0711 "Emission Rates Requiring a Permit."
3. For additional information regarding the applicability of MACT or GACT see the DAQ page titled"Specific
Permit Conditions Regulatory Guide."The link to this site is as follows:hgp:Hdeq.nc.gov/about/divisions/air-
gualit,/quality_permits/specific-permit-conditions-re ug latory_guide.
Mr.Harris
May 18,2020
Page 5
ATTACHMENT
Summary of Changes to Permit
The following changes were made to Iconic Marine Group,LLC—Washington,Air Permit No. 10534ROI:
Page No(s). Section Description of Changes
1 —29 Entire permit, Modified to reflect current permit number, issued and effective
where applicable dates and associated application information
Revised"300"format to Title V permit format per current
guidance
Replaced 02Q .0308(a)with 02Q .0508(f)
Added noncompliance statements
Attachment List of Updated descriptions to match application amendment.
Insignificant
Activities
Attachment Table of Changes Modified to reflect changes for this permit modification
3 Section 1 Updated page numbers on equipment table
Modified emission source IDs and descriptions to match
application amendment
4-8 Sections 2.LA. Combined all like sources under Fiberglass Boat Manufacturing
through 2.1.13. (to be consistent with other permits for Fiberglass facilities in
NC) and subject to the same State regulations to make the
facility's permit less repetitive
Modified emission source IDs and descriptions to match
application amendment
8—21 Removed Sections 2.LC through 2.1.I due to consolidating into
(removed) condition 2.LA.
4— 18 Sections 2.1 and Revised regulations per current Title V shell guidance and
2.2 MRRR consistency across Fiberglass Boat Manufacturing
facilities
10— 11 Section 2.2—A.3 Revised 15A 02D .1100 condition to included latest regulatory
language provided via email on September 24,2019
24—25 Section 2.2—A.6 Removed 15A NCAC 02Q .0207, 02Q .0304, 02D .0535 and
(previous through A.9 02D .0540 requirements per Title V permitting guidance
permit) Removed 15A NCAC 02 .0504—satisfied on January 2, 2018
and February 27,2020(Application No. 0700151.18A)
11 — 18 Section 2.2—B. Revised MACT Subpart VVVV per latest guidance and to be
consistent with other Fiberglass Boat Manufacturing facilities in
NC. Additional changes made were reference citations,
clarifications/corrections inadvertently missed during processing
of previous permits and Title V noncompliance statements added.
19—29 Section 3— Replaced"300"General and Specific Conditions with latest Title
General V General Conditions(version 5.3,08/21/2018)
Conditions
State of North Carolina
t,.r-��D E Q k, /) Department of Environmental Quality
NORTH CAROLINA Division of Air Quality
Department of Environmental Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
10534T02 10534R01 May 18, 2020 April 30, 2025
Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct
and operate the emission source(s)and associated air pollution control device(s) specified herein, in accordance with
the terms, conditions,and limitations within this permit. This permit is issued under the provisions of Article 21B of
Chapter 143, General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes
(15A NCAC), Subchapters 02D and 02Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 02Q, the Permittee shall not construct, operate, or modify any emission
source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application
to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Iconic Marine Group, LLC
Facility ID: 0700151
Facility Site Location: 1653 Whichards Beach Road
City, County, State,Zip: Washington,Beaufort County,NC,27889
Mailing Address: P.O.Drawer 457
City, State,Zip: Washington,NC,27889
Application Number: 0700151.18A
Complete Application Date: March 23,2020
Primary SIC Code: 3732
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington,NC,27889
Permit issued this the 18th day of May,2020
Wt'*f�vj' bkllfll�
William D. Willets,P.E., Chief, Air Permitting Section
By Authority of the Environmental Management Commission
Table Of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 Emission Source(s) Specific Limitations and Conditions (Including specific requirements,
testing,monitoring,recordkeeping, and reporting requirements)
2.2 Multiple Emission Source(s) Specific Limitations and Conditions (Including specific
requirements,testing,monitoring,recordkeeping, and reporting requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
Permit 10534T02
Page 3
SECTION I - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances:
Page Emission Source Emission Source Description Control Device Control Device
Number Description
4—6, Building No.3
9—11,
11—18 ES-03 Small Part Lamination&Mating C-3 Dry filters
MACT VVVV
7—8, Building ID No.4
9— 11,
11 —18 ES-04 Wood Finishing and Adhesive C-4 Dry filters
MACT VVVV Spraying
4—6, Building ID No. 5
9— 11,
11 —18 ES-05 Deck&Hull Lamination C-5 Dry filters
MACT VVVV
4—6, Building ID No. 10
9— 11,
11—18 ES-10 Mold Maintenance C-10 Dry filters
MACT VVVV
4—6, Building ID No. 11
9— 11,
11 —18 ES-11 Cruiser Lamination C-11 Dry filters
MACT VVVV
4—6, Building ID No. 15
9— 11,
11 —18 ES-15 Tooling C-15 Dry filters
MACT VVVV
4—6, Building ID No. 16
9- 11
ES-16 Paint Booth#1 C-16 Dry filters
4—6, Building ID No. 17
9- 11
ES-17 Paint Booth#2 C-17 Dry filters
4—6, Building ID No. 19
9- 11
ES-19 Paint Booth#3 C-19 Dry filters
Permit 10534T02
Page 4
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 — Emission Source(s) and Control Devices(s) Specific Limitations and
Conditions
The emission source(s)and associated air pollution control device(s) and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Fiberglass Boat Manufacturing Operations consisting of:
• Building ID No.3 (ID No.ES-03; Small Part Lamination &Mating) and associated dry
filters (ID No. C-3)
• Building ID No. 5 (ID No. ES-05; Deck& Hull Lamination) and associated dry filters (ID
No. C-5)
• Building ID No. 10 (ID No. ES-10; Mold Maintenance) and associated dry filters(ID No. C-
10)
• Building ID No. 11 (ID No.ES-11; Cruiser Lamination) and associated dry filters (ID No.
C-11)
• Building ID No. 15 (ID No. ES-15; Tooling) and associated dry filters (ID No. C-15)
• Building ID No. 16 (ID No. ES-16; Paint Booth#1) and associated dry filters(ID No. C-16)
• Building ID No. 17 (ID No. ES-17; Paint Booth#2) and associated dry filters (ID No. C-17)
• Building ID No. 19 (ID No. ES-19; Paint Booth#3) and associated dry filters(ID No. C-19)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter E=4.10(P )for process rates less than or equal to 30 tons per hour 15A NCAC 02D.0515
E=55.0 x P0-11 -40 for process rates greater than 30 tons per hour
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D.0521
Hazardous air HAP emission limits—See Section 2.2 B. 15A NCAC 02D.I 111
pollutants Building ID Nos. 16, 17 and 19 are not affected sources under (40 CFR Part 63—
Subpart VVVV[40 CFR§63.5683(d)and 63.5689] Subpart VVVV)
Odorous emissions State-enforceable only-See Section 2.2 A.4. 15A NCAC 02D.1806
Volatile organic Facility-wide less than 250 tons per year—See Section 2.2 A.1. 15A NCAC 02Q.0317
compounds
Toxic air pollutants State-enforceable only-See Section 2.2 A.2. 15A NCAC 02Q .0711
State-enforceable only-See Section 2.2 A.3. 15A NCAC 02D .1100
1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the lamination,mating and gel coating operations(ID No.ES-03,
ES-05 and ES-11);mold maintenance operations(ID No.ES-10);tooling operations (ID No.ES-15);
and painting operations(ID Nos.ES-16,ES-17 and ES-19)shall not exceed an allowable emission rate
as calculated by the following equations:
Permit 10534T02
Page 5
E=4.10 x P 0.17 (for process rates less than or equal to 30 tons per hour)
E=55.0 x P0.11 -40 (for process rates greater than 30 tons per hour)
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.La. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0515.
Monitoring [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the lamination,mating and gel coating operations(ID No.ES-03,ES-
05 and ES-11);mold maintenance operations (ID No.ES-10); tooling operations(ID No.ES-15); and
painting operations (ID Nos.ES-16,ES-17 and ES-19) shall be controlled by dry filter systems(ID
Nos. C-3, C-5, C-10,C-11,C-15 through C-17, and C-19). To ensure compliance,the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations, or if there are no manufacturer's
inspection and maintenance recommendations,as a minimum,the inspection and maintenance
requirement shall include the following:
i. a monthly visual inspection of the filters noting condition; and
ii. an annual(for each 12 month period following the initial inspection)inspection of the dry filter
system's structural integrity.
The Permittee Shall be deemed in noncompliance with 15A NCAC 02D .0515 if the dry filters are not
inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on the dry filter system; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the dry filter system within 30
days of a written request by the DAQ.
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 A.Lc and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
Page 6
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the lamination and mating operations(ID No.ES-03,ES-05 and ES-11);mold
maintenance operations(ID No.ES-10); tooling operations(ID No.ES-15); and painting operations
(ID Nos.ES-16,ES-17 and ES-19)shall not be more than 20 percent opacity when averaged over a
six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit give in Section 2.1 A.2.a above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To ensure compliance, once a month the Permittee shall observe the emission points of the lamination
and mating operations(ID No.ES-03,ES-05 and ES-11); mold maintenance operations (ID No.ES-
10);tooling operations (ID No.ES-15); and painting operations(ID Nos.ES-16,ES-17 and ES-19)
controlled by dry filter systems(ID Nos. C-3,C-5,C-10,C-11,C-15 through C-17, and C-19) for any
visible emissions above normal. The monthly observation must be made for each month of the calendar
year period to ensure compliance with this requirement. If visible emissions from these sources are
observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 02D .2610 (Method 9)for 12 minutes is below the limit given in Section 2.1 A.2.a
above.
The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if the required
monthly observations are not conducted as required; if the above-normal emissions are not corrected
within the monitoring period or the percent opacity demonstration cannot be made.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508 (Q
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Sections 2.1 A.2.c and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
Page 7
B. Building ID No. 04 (ID No. ES-4; Wood Finishing and Adhesive Spraying) with associated dry
filters (ID No. C-4)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter Adequate ductwork and properly designed collectors 15A NCAC 02D.0512
Visible emissions 20 percent opacity 15A NCAC 02D.0521
Hazardous air pollutants HAP emission limits—See Section 2.2 B. 15A NCAC 02D .I I 11
(40 CFR Part 63—
Subpart VVVV)
Odorous emissions State-enforceable only—See Section 2.2 A.4 15A NCAC 02D .1806
Volatile organic Less than 250 tons per year facility-wide-See Section 2.2 A.1. 15A NCAC 02Q .0317
compounds
Toxic air pollutants State-enforceable only-See Section 2.2 A.2. 15A NCAC 02Q.0711
State-enforceable only-See Section 2.2 A.3. 15A NCAC 02D.1100
1. 15A NCAC 02D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS
FINISHING PLANTS
a. The Permittee shall not cause, allow, or permit particulate matter caused by the working, sanding, or
finishing of wood to be discharged from any stack,vent,or building into the atmosphere without
providing,as a minimum for its collection, adequate duct work and properly designed collectors. In no
case shall the ambient air quality standards be exceeded beyond the property line.
Monitoring [15A NCAC 02Q .0508(f)]
b. Particulate matter emissions from the wood finishing and adhesive spraying(ID No.ES-04) shall be
controlled by a dry filter system(ID No. C-4). To ensure compliance,the Permittee shall perform
inspections and maintenance as recommended by the manufacturer,if any. As a minimum,the
inspection and maintenance program shall include:
i. monthly inspection of the dry filters noting the condition; and
ii. annual(for each 12 month period following the initial inspection)inspection of the associated
ductwork noting structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if the ductwork and/or
dry filters are not inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
c. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection; and
iii. the results of maintenance performed on any filters.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0512 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit the results of any maintenance performed on the filters or ductwork within
30 days of a written request by the DAQ.
Permit 10534T02
Page 8
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 B.Lb and c above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the wood finishing and adhesive spraying(ID No.ES-04)shall not be more than
20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods
may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour
period. In no event shall the six-minute average exceed 87 percent opacity.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 13.2.a above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To ensure compliance, once a month the Permittee shall observe the emission points of the wood
finishing and adhesive spraying(ID No. ES-04)controlled a dry filter system(ID No.C-4)for any
visible emissions above normal. The monthly observation must be made for each month of the calendar
year period to ensure compliance with this requirement. If visible emissions from this source are
observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 13.2.
a. above.
The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if the required
weekly observations are not conducted as required; if the above-normal emissions are not corrected
within the monitoring period or the percent opacity demonstration cannot be made.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508 (f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 B.2 c and d above 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. All instances of deviations from the
requirements of this permit must be clearly identified.
Permit 10534T02
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2.2 —Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-wide—All emission sources.
The following table provides a summary of limits and standards for the emission sources:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Facility-wide 15A NCAC 02Q .0317
Less than 250 tons per consecutive 12 months PSD Avoidance for
15 NCAC 02D .0530
Toxic air pollutants Facility-wide State Enforceable Only
Emissions limits for toxic air pollutant emission rates 15A NCAC 02D .0711
Toxic air pollutants Facility-wide State Enforceable Only
Modeled emission rates 15A NCAC 02D .1100
[except Building No. 10(ID No.ES-10)]
Odorous emissions Facility-wide State-enforceable only
Odorous emissions must be controlled 15A NCAC 02D .1806
1. 15A NCAC 02Q. 0317: AVOIDANCE CONDITIONS (PSD Avoidance)
for 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, facility-wide emissions shall be less than 250 tons of
volatile organic compounds(VOCs)per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
b. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions
shall be determined by multiplying the total amount of each type of VOC-containing material consumed
during the month by the VOC content of the material by the appropriate emission factor(EF). The
Permittee shall use either Unified Emission Factors(UEF)for Open Molding of Composites,AP-42
factors, or other such factors approved by the Division. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
VOC emissions exceed the limit in Section 2.2.A.La. above.
Reporting [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities given in
Sections 2.2.A.Lb and c above 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 monthly VOC
emissions for the previous 17 months. The emissions must be calculated for each of the 12-month
periods over the previous 17 months.
State-enforceable only
2. 15A NCAC 02Q .0711: EMISSION RATES REQUIRING A PERMIT
a. The facility shall be operated and maintained in such a manner that any new, existing or increased actual
emissions of any Toxic Air Pollutant(TAP)listed in 15A NCAC 02Q .0711 or in this permit from all
sources at the facility(excluding those sources exempt under 15A NCAC 02Q .0702 "Exemptions"),
including fugitive emissions and emission sources not otherwise required to have a permit,will not
Permit 10534T02
Page 10
exceed its respective TAP permitting emission rates(TPER) listed in 15A NCAC 02Q .0711 without
first obtaining an air permit to construct or operate.
b. PRIOR to exceeding any of the TPERs listed in 15A NCAC 02Q .0711,the Permittee shall be
responsible for obtaining an air permit to emit TAPS and for demonstrating compliance with the
requirements found in 15A NCAC 02D .1100 "Control of Toxic Air Pollutants."
c. The Permittee shall maintain at the facility records of operational information sufficient for
demonstrating to the Division of Air Quality staff that actual TAPs are less than the rate listed in 15A
NCAC 02Q .0711.
d. The TPER table listed below is provided to assist the Permittee in determining when an air permit is
required pursuant to 15A NCAC 02Q .0711 and may not represent all TAPs being emitted from the
facility. This table will be updated at such time as the permit is either modified or renewed.
TPERs Limitations
Pollutant Carcinogens Chronic Toxicants Acute Systemic Toxicants Acute Irritants
(CAS Number) (lb/yr) (lb/day) (lb/hr) (lb/hr)
Ethyl Acetate
36
(141-78-6)
Methyl Ethyl Ketone 78 22.4
(78-93-3)
Methyl Isobutyl Ketone 52 7.6
(108-10-1)
Methylene Chloride 1600 0.39
(75-09-2)
Toluene 98 14.4
(108-88-3)
Xylene 57 16.4
(1330-20-7)
Formaldehyde
0.04
(50-0-0)
n-Hexane 23
(110-54-3)
State-enforceable only
3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. Pursuant to 15A NCAC 02D .1100 and in accordance with the approved application(0700151.19A) for
an air toxic compliance demonstration the following permit limit shall not be exceeded:
EMISSION SOURCE TOXIC AIR POLLUTANT EMISSION LIMIT
Building No. 3 (ID No.ES-03), Styrene(100-42-5) 45.0 lb/hr
Building No.4(ID No.ES-04),
Building No. 5 (ID No.ES-05),
Building No. 11 (ID No.ES-11),
Building No. 15(ID No.ES-15),
Building Nos. 16, 17 and 19
(ID Nos.ES-16,ES-17 and ES-19)
b. The Permittee has submitted a toxic air pollutant dispersion modeling analysis dated May 23,2019 for
the facility's toxic air pollutant emissions as listed in the above table. The modeling analysis was
reviewed and approved by the AQAB on July 17,2019. Placement of the emission sources,
configuration of the emission points, and operation of the sources shall be in accordance with the
Permit 10534T02
Page 11
submitted dispersion modeling analysis and should reflect any changes from the original analysis
submittal as outlined in the AQAB review memo.
c. For compliance purposes,the Permittee shall submit a report to the DAQ Regional Supervisor
postmarked on or before 30 days after each calendar year quarter containing the following:
i. The maximum hourly emission rate of styrene from the sources listed in 2.2 3.a. above.
State-enforceable only
4. 15A NCAC 02D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
B. Affected sources—National Emission Standards for Hazardous Air Pollutants for Boat
Manufacturing:
• Building No. 3 (ID No. ES-03),
• Building No. 4 (ID No. ES-04),
• Building No. 5 (ID No. ES-05),
• Building No. 10 (ID No. ES-10),
• Building No. 11 (ID No. ES-11), and
• Building No. 15 (ID No. ES-15).
1. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY for 40 CFR Part
63, Subpart VVVV: National Emission Standards for Hazardous Air Pollutants for Boat
Manufacturing
a. For each boat manufacturing emission source at this facility(ID Nos.ES-03,ES-04,ES-05,ES-10,ES-
11 and ES-15),the Permittee shall comply with all applicable provisions contained in Environmental
Management Commission Standard 15A NCAC 02D .1111 "Maximum Achievable Control
Technology"as promulgated in 40 CFR Part 63, Subpart VVVV"National Emission Standards for
Hazardous Air Pollutants for Boat Manufacturing,"including Subpart A"General Provisions." [40 CFR
§63.5683 and§63.5689]
Emission Limits for Open Molding Resin and Gel Coat Operations [40 CFR§63.56981
b. The Permittee shall limit organic HAP emissions from any of the following open molding operations to
the emission limit specified in Section 2.2 B.Lc below. Operations listed in Section 2.2 B.Ld are
exempt from this limit.
i Production resin.
ii. Pigmented gel coat.
iii. Clear gel coat.
iv. Tooling resin.
v. Tooling gel coat.
c. The Permittee shall limit organic HAP emissions from open molding operations to the limit specified
by Equation 1 of this condition below,based on a 12-month rolling average.
HAP Limit= [46(MR)+ 159(MpG) + 291(McG) + 54(MTR)+ 214(MTG)] (Equation 1)
Permit 10534T02
Page 12
Where:
HAP Limit = Total allowable organic HAP that can be emitted from the open molding
operations,kilograms.
MR = Mass of production resin used in the past 12 months, excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
MPG = Mass of pigmented gel coat used in the past 12 months,excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
MCA = Mass of clear gel coat used in the past 12 months, excluding any materials
exempt under Section 2.2 B.Lb above, in units of megagrams.
MT = Mass of tooling resin used in the past 12 months,excluding any materials
exempt under Section 2.2 B.Lb iv, above, in units of megagrams.
MTc = Mass of tooling gel coat used in the past 12 months, excluding any
materials exempt under Section 2.2 B.Lb above, in units of megagrams.
d. The materials specified in i through iii below are exempt from the open molding emission limit
specified in Section 2.2 B.Lc above.
i. Production resins (including skin coat resins) that must meet specifications for use in military
vessels or must be approved by the U.S. Coast Guard for use in the construction of lifeboats,rescue
boats, and other life-saving appliances approved under 46 CFR Subchapter Q or the construction of
small passenger vessels regulated by 46 CFR Subchapter T. Production resins for which this
exemption is used must be applied with nonatomizing (non-spray) resin application equipment. A
record must be kept of the resins which are being used for this exemption.
ii. Pigmented, clear, and tooling gel coat used for part or mold repair and touch up. The total gel coat
materials included in this exemption must not exceed 1 percent by weight of all gel coat used at the
facility on a 12-month rolling-average basis. A record must be kept of the amount of gel coats
which are being used for this exemption and copies of calculations showing that the exempt amount
does not exceed 1 percent of all gel coat used.
iii. Pure, 100 percent vinylester resin used for skin coats. This exemption does not apply to blends of
vinylester and polyester resins used for skin coats. The total resin materials included in the
exemption cannot exceed 5 percent by weight of all resin used at the facility on a 12-month rolling-
average basis. A record must be kept of the amount of 100 percent vinylester skin coat resin used
per month that is eligible for this exemption and copies of calculations showing that the exempt
amount does not exceed 5 percent of all resin used.
Complying with the Open Molding Emission Limit [40 CFR§63.5701 and§63.5704]
e. The Permittee shall use one or more of the options listed in paragraphs i and ii below,to meet the
emission limit in paragraphs c and d in this section for the resins and gel coats used in open molding
operations at the facility.
i. Maximum achievable control technology(MACT)model point value averaging(emissions
averaging)option. Demonstrate that emissions from the open molding resin and gel coat operations
that are averaged meet the emission limit in paragraphs c and d above using the procedures
described in 40 CFR§63.5710. Compliance with this option is based on a 12-month rolling
average.
ii. Compliant materials option. Demonstrate compliance by using resins and gel coats that meet the
organic HAP content requirements in Table 1 below. Compliance with this option is based on a 12-
month rolling average.
Permit 10534T02
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Table 1: Alternative Organic HAP Content Requirements for Open Molding Resin and Gel Coat
Operations [40 CFR Part 63 Subpart VVVV,Table 21
You must not exceed this
For this operation- And this application weighted-average organic
method- HAP content(weight percent)
requirement-
1. Production resin operations Atomized(spray) 28 percent
2. Production resin operations Nonatomized(nonspray) 35 percent
3. Pigmented gel coat operations Any method 33 percent
4. Clear gel coat operations Any method 48 percent
5. Tooling resin operations Atomized(spray) 30 percent
6. Tooling resin operations Nonatomized(nonspray) 39 percent
7. Tooling gel coat operations Any method 40 percent
Demonstrating Compliance using Compliant Materials [40 CFR§63.5704(b) and §63.5713]
f. For each open molding operation complying using the compliant materials option, the Permittee must
demonstrate compliance by performing the steps in the following paragraphs i through iv:
i. Use the methods specified in paragraphs g through j of this section to determine the organic HAP
content of resins and gel coats.
ii. Complete the calculations described in paragraph j below to show that the weighted-average
organic HAP content does not exceed the limit specified in Table 1 above.
iii. Keep records as specified in paragraphs(A)through(D)below for each resin and gel coat.
(A) Hazardous air pollutant content.
(B) Application method for production resin and tooling resin. This record is not required if all
production resins and tooling resins are applied with nonatomized technology.
(C) Amount of material used per month. This record is not required for an operation if all
materials used for that operation comply with the organic HAP content requirements.
(D) Calculations performed, if required, to demonstrate compliance based on weighted-average
organic HAP content as described in paragraphs h through k of this section.
iv. Submit semiannual compliance reports to the Division as specified in paragraph aa. of this section.
g. Compliance using the organic HAP content requirements listed in Table I "Alternative Organic HAP
Content Requirements for Open Molding Resin and Gel Coat Operations," is based on a 12-month
rolling average that is calculated at the end of every month. If the Permittee is using filled material
(production resin or tooling resin), the Permittee must comply according to the procedure described
paragraph 1 of this section. [40 CFR§63.5713(a)]
h. At the end of the twelfth month after the Permittee's compliance date and at the end of every
subsequent month, review the organic HAP contents of the resins and gel coats used in the past 12
months in each operation. If all resins and gel coats used in an operation have organic HAP contents no
greater than the applicable organic HAP content limits in Table 1, then the Permittee is in compliance
with the emission limit specified in Section 2.2 B.l.c for that 12-month period for that operation. In
addition, the Permittee does not need to complete the weighted- average organic HAP content
calculation contained in paragraph j for that operation. [40 CFR§63.5713(b)]
Permit 10534T02
Page 14
i. At the end of every month, the Permittee must use Equation 2 of this condition to calculate the
weighted-average organic HAP content for all resins and gel coats used in each operation in the past 12
months.
M,HAP,.
Weighted-Average HAP Content (%)_ '-' (Equation 2)
M;
Where:
M, = Mass of open molding resin or gel coat"i"used during the past 12 months in an
operation,megagrams.
HAP, = Organic HAP content, by weight percent, of open molding resin or gel coat i
used in the past 12 months in an operation. Use the methods in Section 2.2 B.l.w
below to determine organic HAP content.
n = The number of different open molding resins or gel coats used during the past 12
months in an operation.
[40 CFR§63.5713(c)]
j. If the weighted-average organic HAP content does not exceed the applicable organic HAP content limit
specified in Table 1, then the Permittee is in compliance with the emission limit specified in Section 2.2
B.l.c. [40 CFR§63.5713(d)]
Demonstrating Compliance using Filled Resins [40 CFR§63.5710(d)and §63.5714]
k. i. If the Permittee is using a filled production resin or filled tooling resin,the Permittee must
demonstrate compliance for the filled material on an as-applied basis using Equation 3 of this
condition.
PVF =PV° 100 100 iller (Equation 3)
Where:
PVF = The as-applied MACT model point value for a filled production resin or
tooling resin,kilograms organic HAP per megagram of filled material.
PVu = The MACT model point value for the neat(unfilled)resin,before filler is
added,as calculated using the formulas in Table 2 "MACT Model Point
Value Formulas for Open Molding Operations"as contained in 40 CFR Part
63, Subpart VVVV(inserted below,for convenience).
Filler = The weight-percent of filler in the as applied filled resin system.
ii. If the filled resin is used as a production resin and the value of PVF calculated by Equation 3 of
Section 2.2 B.l.k.i, above, does not exceed 46 kilograms of organic HAP per megagram of filled
resin applied,then the filled resin is in compliance.
iii. If the filled resin is used as a tooling resin and the value of PVF calculated by Equation 3 of Section
2.2 B.l.k.i, above, does not exceed 54 kilograms of organic HAP per megagram of filled resin
applied,then the filled resin is in compliance.
Permit 10534T02
Page 15
Table 2: MACT Model Point Value Formulas for Open Molding Operations'
[40 CFR Part 63 Subpart VVVV,Table 31
Use this formula to calculate the
For this operation- And this application method- MACT model plant value for
each resin and gel coat-
1. Production resin,tooling a.Atomized 0.014 X (Resin HAP%)2.425
resin
b. Atomized,plus vacuum bagging 0.01185 X (Resin HAP%)2'425
with roll-out
c.Atomized,plus vacuum bagging 0.00945 x (Resin HAP%)2.425
without roll-out
d.Nonatomized 0.014 X (Resin HAP%)2.275
e.Nonatomized,plus vaccum bagging 0.0110 x (Resin HAP%)2.275
with roll-out
f.Nonatomized,plus vacuum bagging 0.0076 X (Resin HAP%)2.275
without roll-out
2. Pigmented gel coat, clear All methods 0.445 x (Gel coat HAP%)1.675
gel coat,tooling gel coat
Equations calculate MACT model point value in kilograms of organic HAP per megagrams of resin or gel coat
applied.The equations for vacuum bagging with roll-out are applicable when a facility rolls out the applied resin
and fabric prior to applying the vacuum bagging materials.The equations for vacuum bagging without roll-out are
applicable when a facility applies the vacuum bagging materials immediately after resin application without
rolling out the resin and fabric.HAP%=organic HAP content as supplied,expressed as a weight-percent value
between 0 and 100 percent.
Standards for Resin and Gel Coat Mixing Operations [40 CFR 63.5731]
1. The Permittee shall cover at all times all resin and gel coat mixing containers with a capacity equal to
or greater than 208 liters (55 gallons), including those used for on-site mixing of putties and
polyputties,must have a cover with no visible gaps in place at all times.
m. The work practice standard in paragraph m above, does not apply when material is being manually
added to or removed from a container, or when mixing or pumping equipment is being placed in or
removed from a container.
n. To demonstrate compliance with the work practice standard in paragraph m above, the Permittee must
visually inspect all mixing containers subject to this standard at least once per month. The inspection
should ensure that all containers have covers with no visible gaps between the cover and the container,
or between the cover and equipment passing through the cover.
o. The Permittee must keep records of which mixing containers are subject to this standard and the results
of the inspections,including a description of any repairs or corrective actions taken.
Standards for Resin and Gel Coat Application Equipment Cleaning Operations [40 CFR 63.5734
and 63.57371
p. For routine flushing of resin and gel coat application equipment(e.g., spray guns, flowcoaters, brushes,
rollers, and squeegees), the Permittee must use a cleaning solvent that contains no more than 5 percent
organic HAP by weight. For removing cured resin or gel coat from application equipment, no organic
HAP content limit applies.
q. The Permittee must store organic HAP-containing solvents used for removing cured resin or gel coat in
containers with covers. The covers must have no visible gaps and must be in place at all times, except
when equipment to be cleaned is placed in or removed from the container. On containers with a
capacity greater than 7.6 liters (2 gallons), the distance from the top of the container to the solvent
Permit 10534T02
Page 16
surface must be no less than 0.75 times the diameter of the container. Containers that store organic
HAP-containing solvents used for removing cured resin or gel coat are exempt from the requirements of
40 CFR Part 63, Subpart T (National Emission Standards for Halogenated Solvent Cleaning). Cured
resin or gel coat means resin or gel coat that has changed from a liquid to a solid.
r. Determine and record the organic HAP content of the cleaning solvents subject to the standards
specified in paragraphs q and r above,using the methods specified in Section 2.2 B.1.w below.
s. If the Permittee recycles cleaning solvents on site, the Permittee may use documentation from the
solvent manufacturer or supplier or a measurement of the organic HAP content of the cleaning solvent
as originally obtained from the solvent supplier for demonstrating compliance, subject to the conditions
in paragraph w below demonstrating compliance with organic HAP content limits.
t. At least once per month, the Permittee must visually inspect any containers holding organic HAP-
containing solvents used for removing cured resin and gel coat to ensure that the containers have covers
with no visible gaps. Keep records of the monthly inspections and any repairs made to the covers.
Demonstrating Compliance with Carpet and Fabric Adhesive Operations [40 CFR 63.5740]
u. The Permittee must use carpet and fabric adhesives that contain no more than 5 percent organic HAP by
weight.
v. To demonstrate compliance with the emission limit in paragraph v above, you must determine and
record the organic HAP content of the carpet and fabric adhesives using the methods in paragraph w
below.
Methods for Determining Organic Hazardous Air Pollutant Content [40 CFR 63.5758]
w. To determine the organic HAP content for each material used in the Permittee's open molding resin and
gel coat operations, carpet and fabric adhesive operations, or aluminum recreational boat surface
coating operations,the Permittee shall use one of the options in paragraph i through vi.
i. Method 311 (appendix A to 40 CFR Part 63). The Permittee may use Method 311 for determining
the mass fraction of organic HAP. Use the procedures specified in (A) and (B) below, when
determining organic HAP content by Method 311.
(A)Include in the organic HAP total each organic HAP that is measured to be present at 0.1
percent by mass or more for Occupational Safety and Health Administration (OSHA)-defined
carcinogens as specified in 29 CFR §1910.1200(d)(4) and at 1.0 percent by mass or more for
other compounds. For example, if toluene (not an OSHA carcinogen) is measured to be 0.5
percent of the material by mass, the Permittee does not need to include it in the organic HAP
total. Express the mass fraction of each organic HAP the Permittee measures as a value
truncated to four places after the decimal point(e.g., 0.1234).
(B) Calculate the total organic HAP content in the test material by adding up the individual organic
HAP contents and truncating the result to three places after the decimal point(e.g., 0.123).
ii. Method 24 (Appendix A to 40 CFR Part 63). The Permittee may use Method 24 to determine the
mass fraction of non-aqueous volatile matter of aluminum coatings and use that value as a
substitute for mass fraction of organic HAP.
iii. ASTM D1259-85 (Standard Test Method for Nonvolatile Content of Resins). The Permittee may
use ASTM D1259-85 (available for purchase from ASTM)to measure the mass fraction of volatile
matter of resins and gel coats for open molding operations and use that value as a substitute for
mass fraction of organic HAP.
iv. Alternative method. The Permittee may use an alternative test method for determining mass fraction
of organic HAP if the Permittee obtains prior approval by EPA Region IV. The Permittee must
follow the procedure in 40 CFR§63.7(f)to submit an alternative test method for approval.
v. Information from the supplier or manufacturer of the material. The Permittee may rely on
information other than that generated by the test methods specified in paragraphs i through iv,
above, such as manufacturer's formulation data, according to (A)through(C),below.
Permit 10534T02
Page 17
(A)Include in the organic HAP total each organic HAP that is present at 0.1 percent by mass or
more for OSHA-defined carcinogens as specified in 29 CFR §1910.1200(d)(4) and at 1.0
percent by mass or more for other compounds. For example, if toluene (not an OSHA
carcinogen) is 0.5 percent of the material by mass, the Permittee does not have to include it in
the organic HAP total.
(B) If the organic HAP content is provided by the material supplier or manufacturer as a range,then
the Permittee must use the upper limit of the range for determining compliance. If a separate
measurement of the total organic HAP content using the methods specified in Sections 2.2
B.l.w.i through iv, above, exceeds the upper limit of the range of the total organic HAP content
provided by the material supplier or manufacturer, then the Permittee must use the measured
organic HAP content to determine compliance.
(C) If the organic HAP content is provided as a single value, the Permittee may assume the value is
a manufacturing target value and actual organic HAP content may vary from the target value. If
a separate measurement of the total organic HAP content using the methods specified in
paragraphs i through iv, above, is less than 2 percentage points higher than the value for total
organic HAP content provided by the material supplier or manufacturer, then the Permittee may
use the provided value to demonstrate compliance. If the measured total organic HAP content
exceeds the provided value by 2 percentage points or more, then the Permittee must use the
measured organic HAP content to determine compliance.
vi. Solvent blends. Solvent blends may be listed as single components for some regulated materials in
certifications provided by manufacturers or suppliers. Solvent blends may contain organic HAP
which must be counted toward the total organic HAP content of the materials. When detailed
organic HAP content data for solvent blends are not available, the Permittee may use the values for
organic HAP content that are listed in Table 5 "Default Organic HAP Contents of Solvents and
Solvent Blends" or Table 6 "Default Organic HAP Contents of Petroleum Solvent Groups" as
contained in 40 CFR Part 63, Subpart VVVV. The Permittee may use Table 6 as contained in 40
CFR Part 63, Subpart VVVV, only if the solvent blends in the materials the Permittee use do not
match any of the solvent blends in Table 5 as contained in 40 CFR Part 63, Subpart VVVV, and the
Permittee knows only whether the blend is either aliphatic or aromatic. However, if test results
indicate higher values than those listed in Table 5 or 6 as contained in 40 CFR Part 63, Subpart
VVVV,then the test results must be used for determining compliance.
Table 6"Default Organic HAP Contents of Petroleum Solvent Groups"
Recordkeeping [15A NCAC 02Q .0508(f),40 CFR 63.5764,40 CFR 63.5767 and 40 CFR 63.57701
x. The Permittee shall keep the following records:
i. a copy of each notification and report that the Permittee submitted to comply with 40 CFR Part 63,
Subpart VVVV;
ii. all documentation supporting any notification or report that the Permittee submitted; and
iii. the total amounts of open molding production resin,pigmented gel coat, clear gel coat,tooling resin,
and tooling gel coat used per month and the weighted-average organic HAP contents for each
operation, expressed as weight-percent. For open molding production resin and tooling resin, the
Permittee shall also record the amounts of each applied by atomized and nonatomized methods.
y. The Permittee shall keep each record:
i. readily available and in a form so they can be easily inspected and reviewed.
ii. for 5 years following the date that each record is generated.
iii. on site for at least 2 years after the date that each record is generated. The Permittee can keep the
records offsite for the remaining 3 years.
iv. on paper or an electronic device.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I I I I if these records are not
maintained.
Permit 10534T02
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Reporting [15A NCAC 02Q .0508(f),40 CFR 63.5761 and 40 CFR 63.5764]
z. The Permittee shall submit a semiannual compliance report that covers the period from 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. All instances of deviations
from the requirements of this permit must be clearly identified. Each compliance report must be
postmarked no later than 60 days from the end of the semiannual reporting period. At a minimum,the
compliance report shall contain:
i. Company name and address;
ii. A statement by a responsible official with that official's name,title, and signature,certifying the
truth, accuracy, and completeness of the report;
iii. The date of the report and the beginning and ending dates of the reporting period;
iv. A description of any changes in the manufacturing process since the last compliance report;
v. A statement or table showing, for each regulated operation,the applicable organic HAP content
limit, application equipment requirement, or MACT model point value averaging provision with
which the facility is complying. The statement or table shall also show the actual weighted-average
organic HAP content or weighted-average MACT model point value(if applicable)for each
operation during each of the rolling 12-month averaging periods that end during the reporting
period;
vi. If the facility was in compliance with the emission limits and work practice standards during the
reporting period,the Permittee shall include a statement to that effect; and
vii. If the Permittee deviated from an emission limit or work practice standard during the reporting
period,the he shall also include the following information in the semiannual compliance report:
(A)A description of the operation involved in the deviation,
(B) The quantity, organic HAP content, and application method(if relevant)of the materials
involved in the deviation,
(C) A description of any corrective action the Permittee took to minimize the deviation and actions
he has taken to prevent it from happening again, and
(D)A statement of whether or not the facility was in compliance for the 12-month averaging period
that ended at the end of the reporting period.
aa. The Permittee must submit all of the notifications in Table 7 as contained in 40 CFR Part 63 Subpart
VVVV,that apply to the Permittee by the dates in the table. The notifications are described more fully
in 40 CFR Part 63, Subpart A"General Provisions,"referenced in Table 8 as contained in 40 CFR Part
63 Subpart VVVV. If the Permittee changes any information submitted in any notification,the
Permittee must submit the changes in writing to the Division within 15 calendar days after the change.
bb. The Permittee may switch between the compliance options(Emissions Averaging and Compliant
Materials)in 40 CFR Part 63, Subpart VVVV per the requirements of paragraphs i. and ii below. In all
cases,the Permittee shall submit notification to change options, in writing,to the Division of Air
Quality, 15 days prior to changing compliance options. [40 CFR 63.5710 and 40 CFR 63.5713]
i. Changing from compliant materials to 12-month emissions averaging: The Permittee shall begin
collecting resin and gel coat usage data on the date the compliance option is switched. The source
shall demonstrate compliance using the emissions averaging option for at least 12 consecutive
months.
ii. Changing from 12-month emissions averaging to compliant materials: The Permittee shall begin
complying with the compliant materials option on the date the compliance option is switched. Until
the full 12-month compliance period has ended the Permittee shall continue to collect resin and gel
coat usage data and calculate the 12-month emissions average.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I I I I if the reporting
requirements above are not met.
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SECTION 3 — GENERAL CONDITIONS (version 5.3, 08/21/2018)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in
15A NCAC 02D and 02Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and
enforceable pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or
criminal penalties. Any unauthorized deviation from the conditions of this permit may constitute grounds
for revocation and/or enforcement action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other
aspects of the facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,
animal or plant life, or property caused by the construction or operation of this permitted facility, or from
penalties therefore, nor does it allow the Permittee to cause pollution in contravention of state laws or
rules, unless specifically authorized by an order from the North Carolina Environmental Management
Commission.
5. Except as identified as state-only requirements in this permit, all terms and conditions contained herein
shall be enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal
Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the
appropriate and valid permits issued by the DAQ, unless the source is exempted by rule. The DAQ may
issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in
violation of any of the applicable requirements. A permitted installation may only be operated,
maintained,constructed,expanded,or modified in a manner that is consistent with the terms of this permit.
B. Permit Availability[15A NCAC 02Q .0507(k)and.0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the
permit term one complete copy of the application and any information submitted in support of the application
package. The permit and application shall be made available to an authorized representative of Department of
Environmental Quality upon request.
C. Severability Clause [15A NCAC 02Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be
invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those
held to be invalid,shall remain valid and must be complied with.
D. Submissions [15A NCAC 02Q .0507(e)and 02Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data,
notifications, request for renewal, and any other information required by this permit shall be submitted to the
appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. For
continuous emissions monitoring systems (GEMS) reports, continuous opacity monitoring systems (COMS)
reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM certification reports, and NOx
budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall
be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
Permit 10534T02
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E. Duty to Comply [15A NCAC 02Q .0508(i)(3)]
The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in
this permit. Noncompliance with any permit condition except conditions identified as state-only requirements
constitutes a violation of the Federal Clean Air Act. Noncompliance with any permit condition is grounds for
enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a
permit renewal application.
F. Circumvention-STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall
reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated
without the concurrent operation of its associated air pollution control device(s)and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 02Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A
NCAC 02Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q
.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC
02Q.0524 and 02Q .0505.
3. Minor Permit Modifications [15A NCAC 02Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC
02Q .0515.
4. Significant Permit Modifications [15A NCAC 02Q.0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A
NCAC 02Q .0516.
5. Reopening for Cause [15A NCAC 02Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q
.0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in
Section 1 must be reported to the Regional Supervisor,DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes; or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any necessary changes
in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation
of the emission limitations specified herein.
2. Section 502(b)(10)Changes [15A NCAC 02Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition.
Such changes do not include changes that would violate applicable requirements or contravene
federally enforceable permit terms and conditions that are monitoring (including test methods),
recordkeeping,reporting,or compliance certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Permittee notifies the Director and EPA with written notification at least seven days before the
change is made; and
Permit 10534T02
Page 21
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions; and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or
renewed,whichever comes first.
3. Off Permit Changes [15A NCAC 02Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
a. the change affects only insignificant activities and the activities remain insignificant after the change;
or
b. the change is not covered under any applicable requirement.
4. Emissions Trading[15A NCAC 02Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D, including subsequently adopted
maximum achievable control technology standards, emissions trading shall be allowed without permit
revision pursuant to 15A NCAC 02Q .0523(c).
LA Reportin ,Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D .0535(f) and 02Q
.0508(f)(2)]
"Excess Emissions" - means an emission rate that exceeds any applicable emission limitation or standard
allowed by any rule in Sections .0500, .0900, .1200, or .1400 of Subchapter 02D; or by a permit condition; or
that exceeds an emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note:Definitions
of excess emissions under 02D.II10 and 02D.I II I shall apply where defined by rule)
"Deviations"- for the purposes of this condition, any action or condition not in accordance with the terms and
conditions of this permit including those attributable to upset conditions as well as excess emissions as defined
above lasting less than four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS (15A NCAC 02D .0524),NESHAPS (15A
NCAC 02D .1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of
excess emissions,reporting shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 02D .0524), NESHAPS (15A NCAC 02D .1110 or
A 111), or these rules do NOT define "excess emissions," the Permittee shall report excess emissions in
accordance with 15A NCAC 02D .0535 as follows:
a. Pursuant to 15A NCAC 02D .0535, if excess emissions last for more than four hours resulting from a
malfunction, a breakdown of process or control equipment, or any other abnormal condition, the
owner or operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern Time of
the Division's next business day of becoming aware of the occurrence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration; and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished; and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A
NCAC 02D .0535(f)(3).
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Permit Deviations
3. Pursuant to 15A NCAC 02Q .0508(f)(2), the Permittee shall report deviations from permit requirements
(terms and conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not
covered under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall
include the probable cause of such deviation and any corrective actions or preventative actions taken.
The responsible official shall certify all deviations from permit requirements.
LB Other Requirements under 15A NCAC 02D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D .0535,
including 15A NCAC 02D .0535(c)as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of
the appropriate rule unless the owner or operator of the sources demonstrates to the Director, that the
excess emissions are a result of a malfunction. The Director shall consider, along with any other pertinent
information,the criteria contained in 15A NCAC 02D .0535(c)(1)through(7).
2. 15A NCAC 02D .0535(g). Excess emissions during start-up and shut-down shall be considered a
violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are
unavoidable.
J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the
control of the facility, including acts of God, which situation requires immediate corrective action to
restore normal operation, and that causes the facility to exceed a technology-based emission limitation
under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency
shall not include noncompliance to the extent caused by improperly designed equipment, lack of
preventive maintenance,careless or improper operation,or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the conditions specified in 3.below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of
emissions that exceeded the standards or other requirements in the permit; and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time
when emission limitations were exceeded due to the emergency. This notice must contain a
description of the emergency, steps taken to mitigate emissions,and corrective actions taken.
4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the
burden of proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement
specified elsewhere herein.
K. Permit Renewal[15A NCAC 02Q .0508(e)and 02Q .0513(b)]
This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the
end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q
.0500 renewal application is submitted at least six months before the date of permit expiration. If the Permittee
or applicant has complied with 15A NCAC 02Q .0512(b)(1), this 15A NCAC 02Q .0500 permit shall not
expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC 02Q .0400
terminates the facility's right to operate unless a complete 15A NCAC 02Q .0400 renewal application is
submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q
Permit 10534T02
Page 23
.0400 requirements. In either of these events, all terms and conditions of these permits shall remain in effect
until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 02Q.0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information) [15A NCAC 02Q.0508(i)(9)]
1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the Director
may request in writing to determine whether cause exists for modifying, revoking and reissuing, or
terminating the permit or to determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies
are requested by the Director. For information claimed to be confidential,the Permittee may furnish such
records directly to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement[15A NCAC 02Q .0507(f)]
The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was
submitted in the permit application, shall promptly submit such supplementary facts or corrected information
to the DAQ. The Permittee shall also provide additional information as necessary to address any requirement
that becomes applicable to the facility after the date a complete permit application was submitted but prior to
the release of the draft permit.
O. Retention of Records [15A NCAC 02Q .0508(f)and 02Q .0508(1)]
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. Supporting
information includes all calibration and maintenance records and all original strip-chart recordings for
continuous monitoring information, and copies of all reports required by the permit. These records shall be
maintained in a form suitable and readily available for expeditious inspection and review. Any records
required by the conditions of this permit shall be kept on site and made available to DAQ personnel for
inspection upon request.
P. Compliance Certification [15A NCAC 02Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4,
61 Forsyth Street SW, Atlanta, GA 30303) postmarked on or before March 1 a compliance certification (for
the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the
permit, including emissions limitations, standards, or work practices. It shall be the responsibility of the
current owner to submit a compliance certification for the entire year regardless of who owned the facility
during the year. The compliance certification shall comply with additional requirements as may be specified
under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status (with the terms and conditions of the permit for the period covered by the
certification);
3. whether compliance was continuous or intermittent; and
4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official[15A NCAC 02Q.0520]
A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or
compliance certification required by this permit. All certifications shall state that based on information and
belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and
complete.
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R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable
requirements,where such applicable requirements are included and specifically identified in the permit as
of the date of permit issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission, Secretary of the Department, or Governor under NCGS 143-
215.3(a)(12),or EPA under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to
the effective date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV;or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain
information to determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit
revision made under 15A NCAC 02Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 02Q.05191
The Director may terminate,modify,or revoke and reissue this permit if:
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or
5. the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to
carry out the purpose of NCGS Chapter 143,Article 21B.
T. Insignificant Activities [15A NCAC 02Q .05031
Because an emission source or activity is insignificant does not mean that the emission source or activity is
exempted from any applicable requirement or that the owner or operator of the source is exempted from
demonstrating compliance with any applicable requirement. The Permittee shall have available at the facility
at all times and made available to an authorized representative upon request, documentation, including
calculations,if necessary,to demonstrate that an emission source or activity is insignificant.
U. Property Rights [I 5A NCAC 02Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry[15A NCAC 02Q .0508(1)and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow
the DAQ,or an authorized representative,to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is
conducted,or where records are kept under the conditions of the permit;
b. have access to and copy, at reasonable times, any records that are required to be kept under the
conditions of the permit;
c. inspect at reasonable times and using reasonable safety practices any source, equipment (including
monitoring and air pollution control equipment), practices, or operations regulated or required under
the permit; and
d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose of
assuring compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee
under Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for
purposes of inspection, and who presents appropriate credentials,nor shall any person obstruct,hamper, or
interfere with any such authorized representative while in the process of carrying out his official duties.
Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties.
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W. Annual Fee Payment[15A NCAC 02Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q.0200.
2. Payment of fees may be by check or money order made payable to the N.C. Department of Environmental
Quality. Annual permit fee payments shall refer to the permit number.
3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate
action to terminate the permit under 15A NCAC 02Q.0519.
X. Annual Emission Inventory Requirements [15A NCAC 02Q .02071
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A
NCAC 02Q .0207(a) from each emission source within the facility during the previous calendar year. The
report shall be in or on such form as may be established by the Director. The accuracy of the report shall be
certified by a responsible official of the facility.
Y. Confidential Information [15A NCAC 02Q .0107 and 02Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q
.0107, the Permittee may also submit a copy of all such information and claim directly to the EPA upon
request. All requests for confidentiality must be in accordance with 15A NCAC 02Q .0107.
Z. Construction and Operation Permits [15A NCAC 02Q.0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified
facility or emission source which is not exempted from having a permit prior to the beginning of construction
or modification,in accordance with all applicable provisions of 15A NCAC 02Q .0100 and.0300.
AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A
NCAC 02Q .0505 and.0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q.0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of
substantial compliance history.
CC. Refrigerant Requirements(Stratospheric Ozone and Climate Protection) [15A NCAC 02Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which
use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons
listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,
and maintain such equipment according to the work practices, personnel certification requirements, and
certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the
environment during the repair, servicing, maintenance, or disposal of any such device except as provided
in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports
shall be submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases-Section 112(r) [15A NCAC 02Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section
112(r)of the Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part
68.
Permit 10534T02
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EE.Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) — FEDERALLY-
ENFORCEABLE ONLY
Although a risk management plan may not be required, if the Permittee produces,processes,handles,or stores
any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are
necessary to prevent the accidental release of such substance and to minimize the consequences of any release.
FF. Title IV Allowances [I5ANCAC 02Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not
use allowances as a defense to noncompliance with any other applicable requirement. The Permittee's
emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean
Air Act.
GG.Air Pollution Emergency Episode [15A NCAC 02D .03001
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to
operate in accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of
an approved plan,with the appropriate requirements specified in 15A NCAC 02D .0300.
HH.Registration of Air Pollution Sources [15A NCAC 02D .0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is
required to register a source of air pollution, this registration and required information will be in accordance
with 15A NCAC 02D .0202(b).
II. Ambient Air Ouality Standards [15A NCAC 02D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,
any source of air pollution shall be operated with such control or in such manner that the source shall not cause
the ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on
which the source is located. When controls more stringent than named in the applicable emission standards in
this permit are required to prevent violation of the ambient air quality standards or are required to create an
offset,the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q .0508(i)(16)]
Emission compliance testing shall be by the procedures of Section .2600, except as may be otherwise
required in Rules .0524, .0912, .1110, .1111, or .1415 of Subchapter 02D. If emissions testing is required by
this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance,
the Permittee shall perform such testing in accordance with 15A NCAC 02D .2600 and follow the procedures
outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing. Testing protocols are not required to be pre-approved by the
Director prior to air pollution testing. The Director shall review air emission testing protocols for pre-
approval prior to testing if requested by the owner or operator at least 45 days before conducting the
test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable
standard shall notify the Director at least 15 days before beginning the test so that the Director may at
his option observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates
during the period of air testing. The owner or operator of the source shall ensure that the equipment or
process being tested is operated at the production rate that best fulfills the purpose of the test. The
individual conducting the emission test shall describe the procedures used to obtain accurate process
data and include in the test report the average production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days
after sample collection unless otherwise specified in the specific conditions. The owner or operator may
request an extension to submit the final test report. The Director shall approve an extension request if he
finds that the extension request is a result of actions beyond the control of the owner or operator.
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a. The Director shall make the final determination regarding any testing procedure deviation and the
validity of the compliance test. The Director may:
i. Allow deviations from a method specified under a rule in this Section if the owner or operator
of the source being tested demonstrates to the satisfaction of the Director that the specified
method is inappropriate for the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative
method is necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test
method is specified in this Section if the methods can be demonstrated to determine compliance
of permitted emission sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source
subject to a rule in this Subchapter to determine the compliance status of that source or to verify any
test data submitted relating to that source. Any test conducted by the Division of Air Quality using
the appropriate testing procedures described in Section 02D .2600 has precedence over all other
tests.
KK.Reopening for Cause [15A NCAC 02Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three
or more years;
b. additional requirements (including excess emission requirements) become applicable to a source
covered by Title IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or other terms or conditions of the permit;or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with
the applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable
requirement is promulgated. No reopening is required if the effective date of the requirement is after the
expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q
.0513(c).
3. Except for the state-enforceable only portion of the permit, the procedures set out in 15A NCAC 02Q
.0507, .0521, or .0522 shall be followed to reissue the permit. If the State-enforceable only portion of the
permit is reopened, the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall
affect only those parts of the permit for which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be
reopened, except in cases of imminent threat to public health or safety the notification period may be less
than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the
EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the
EPA a proposed determination of termination,modification,or revocation and reissuance,as appropriate.
LL.Reporting Requirements for Non-Operating Equipment [15A NCAC 02Q.0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is
taken from and placed into operation. When permitted equipment is not in operation, the requirements for
testing,monitoring,and recordkeeping are suspended until operation resumes.
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MM. Fugitive Dust Control Requirement[15A NCAC 02D .0540]
As required by 15A NCAC 02D .0540 "Particulates from Fugitive Dust Emission Sources,"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. If substantive complaints or excessive fugitive dust emissions from
the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference
Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as
described in 02D .0540(f).
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"Fugitive dust emissions" means particulate matter from process operations that does not pass through a
process stack or vent and that is generated within plant property boundaries from activities such as: unloading
and loading areas, process areas, stockpiles, stock pile working, plant parking lots, and plant roads (including
access roads and haul roads).
NN. Specific Permit Modifications [I 5A NCAC 02Q.0501 and.0523]
1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2), the Permittee shall file a Title V Air
Quality Permit Application for the air emission source(s) and associated air pollution control device(s)
on or before 12 months after commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2), the Permittee shall not begin
operation of the air emission source(s) and associated air pollution control device(s) until a Title V Air
Quality Permit Application is filed and a construction and operation permit following the procedures of
Section.0500(except for Rule .0504 of this Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 02Q .0523(a)(1)(C),the
Permittee shall notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth Street SW,
Atlanta, GA 30303) in writing at least seven days before the change is made. The written notification
shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit
renewal, the Permittee shall submit a page "E5" of the application forms signed by the responsible official
verifying that the application for the 502(b)(10) change/modification, is true, accurate, and complete.
Further note that modifications made pursuant to 502(b)(10) do not relieve the Permittee from satisfying
preconstruction requirements.
00. Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and.0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency(EPA),
EPA's decision to not object to the proposed permit is considered final and binding on the EPA and absent a
third party petition, the failure to object is the end of EPA's decision-making process with respect to the
revisions to the permit. The time period available to submit a public petition pursuant to 15A NCAC 02Q
.0518 begins at the end of the 45-day EPA review period.
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ATTACHMENT
List of Acronyms
AOS Alternative Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
S02 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound