HomeMy WebLinkAboutAQ_F_0900009_20190314_PRMT_Permit ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS �•° _
Director
NORTH CAROLINA
Environmental Quality
March 14,2019
Mr.Brian D.Long
Plant Manager
Chemours Company-Fayetteville Works
22828 NC Highway 87 West
Fayetteville,North Carolina 28306-7332
SUBJECT: Air Quality Permit No.03735T44
Facility ID: 0900009
Chemours Company-Fayetteville Works
Fayetteville
Bladen County
Fee Class: Title V
Dear Mr_Long:
In accordance with your completed Air Quality Pen-nit Application for a significant modification
under 15A NCAC 02Q .0501(b)(2)of a Title V permit received July 2, 2018,we are forwarding herewith
Air Quality Permit No.03 735T44 to Chemours Company—Fayetteville Works,Fayetteville,Bladen County,
North Carolina authorizing the construction and operation of the emission 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
have been listed for informational purposes. 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 Adm in i strative
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.You may request modification of your Air Quality Permit through informal
means pursuant to NCGS 15013-22. This request must be submitted in writing to the Director and must
F North Carolina Depattment of Environmental Quality i Divisionof Air Quality
217 West Jones Street 1 1641 Mail Service Center f paleigh,North Carolina 27699-1641
k4klrl L'aF I
�° ' ` 919.707,84no
Mr.Brian D.Long
March 14, 2019
Page 2
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 sources) 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.
Biaden County has triggered increment tracking under PSD for PMIo and SOz. This permit
modification will result in an increase of 0.17 pounds per hour of PMio and 0.0095 pounds per hour of SOz.
This Air Quality Permit shall be effective from March 14, 2019 until March 31, 2021, 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 Heather Sands at
(919)707-8725.
Sincerely yours_
r,Williarzm D.Willets,P.E,Chief,Permitting Section
Division of Air Quality,NCDEQ
Enclosure
cc: Heather Ceron,EPA Region 4
Fayetteville Regional Office
Connie Horne(cover letter only)
Central Files
Mr.Brian D.Long
March 14,2019
Page 3
ATTACHMENT to Permit No.03735T44
Insignificant Activities per 15A NCAC 02Q.0503(8)
Source ID No. Emission Source Description
I-02 Waste DMSO Storage Tank
I-03 Fugitive Emissions of Methylene Chloride
I-04 Chlorination of Riverwater to control mussel growth in equipment
I-05 Sitewide Laboratory Emissions
I-06 Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension
I-07 Paint shop
1-08 Self-contained abrasive blasting cabinets
I-09 Paint spray booths
1-10 Abrasive blasting and painting building
I-12 IKM Dispersion Process
I-CT Cooling Tower(6,000 gallons per minute,expandable to 8,000 gallons per minute)
I-RICE-01 Diesel Engine for Stack Blower Emergency Electrical Generator
MALT ZZZZ
� I-RICE-02
MACT 02 Diesel Engine for Emergency Fire Water Pump
I-RICE-03
NSPS IM Diesel Engine for BFPO Barricade Emergency Electrical Generator
MACT ZZZZ
I-RICE-04
NSPS IIII Diesel-Fired Emergency Generator(320 hp)
MACT ZZZZ
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement or that
the owner or operator of the source 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 15A NCAC 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:http://deg.nc.govlaboutldivision_slair-
qualit}lair-civalitv-permits/specific-permit-conditions-re€rWatM--guide.
Mr.Brian D.Long
March 14,2019
Page 4
Summary of Changes to Permit
The following changes were made to the Chemours Company—Fayetteville Works,Air Permit No.03735T43.
Old Page New Page Condition No, Description of Change(s)
No. No.
Cover letter Cover letter -- -Amended application type,permit revision numbers and dates.
Cover letter Cover letter Summary of changes -Updated with summary of changes to permit.
attachment attachment to permit
Cover letter Cover letter Insignificant -Added Cooling Tower(ID No.I-CT);and
attachment attachment activities list -Added Diesel-Fired Emergency Generator ID No.I-RICE-04
1 I Permit Cover Page -Updated permit revision number and permit issuance date
3—58 3—73 All -Updated permit revision number in header;
-Updated pennit language to match permit shell.
3-4 3-4 Section 1.0 -Updated page numbers
-Rearranged sources in the FPSIIXM Process Area to group those sources
that will be controlled using similar control systems.
-Renamed existing baffle plate scrubbers installed on FPSIIXM Process
Area Sources as primary operating scenario(POS)
-Added Thermal Oxidizer and 4-Stage Scrubber System as the control
device under the alternative operating scenario for the FPS/I)C 4 Process
Area sources:HFPO Process,Vinyl Ethers North Process,Vinyl Ethers
South Process,RSU Process,FPS Liquid Waste Stabilization Process,MMF
Process,1XM Resins Process-except Fluorinator,E-2 Process,TFE/C07
Separation Process,HFPO Product Container Decontamination Process,
VEN Product Decontamination Process,and VES Product Container
Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-D,NS-E,NS-F,
NS-G-1,NS-IC,NS-M,NS-N,NS-O,and NS-P)
-Divided IXM Resins Process(ID No.NS-G)into two sources:NS-G-I—
IXM Resins Process(except Fluorinator)and NS-G-2—IXM Resins Process
Fluorinator;Changed reference to NS-G throughout the permit to incorporate
this change.
-Added sources from Lime Processing:Lime Silo(ID No.N5-R 1)
controlled by a hin vent baghouse(11)No.NCD-RI)and Lime Slaker(ID
No.N5-R2)controlled by a wet particulate scrubber(ID No.NCD-R2)
-Added V&North Indoor Fugitives(NS-B-2)to be controlled by Carbon
Adsorber(NCD-Q3).
-Added Carbon Adsorher(ACD-2)as a control device to Polymers
Processing Aid Process(AS-A
f 21 —35 21—39 Section 2.1 C -Updated condition header to reflect the current facility configuration under
the POS and the post-project configuration under the AOS.
-Updated the summary of limits and conditions to include the GenX
compounds.
-Added Condition C.1 to define the AOS.Remaining conditions in Section
2.1 C were renumbered.
-Added Condition C.3 for regulation 02D.0516, Sulfur Dioxide Emissions
from Combustion Sources for the Thermal Oxidizer.
-Added the outlet of the 4-State Scrubber(ID No.NCD-Q2)as an applicable
source under regulation 02D.0521,Control of Visible Emissions.
-Modified Conditions C.5,C.6,C.7 to add the POS and AOS to incorporate
the Thermal Oxidizer.
Mr.Brian D.Long
March 14, 2019
Page 5
Old Page New Page
No. No. Condition No. Description of Change(s)
-Modified the POS calculation in Condition C.5 to correct the scrubber
control efficiency from 99.6 percent to 99.1 percent.
-Modified Condition C.6 and C.10 to change the affected sources from NS-
G to NS-G-i and G-2 to reflect the change in designation for this source.
-Devised the equation in Condition C.7.c.iii to specify the 99.1 percent
removal efficiency of the scrubber;
-Reworded Condition C.7.c.iv to remove the scrubber phrase from the text
in this condition.Added POS to account for the acid fluoride VOC removal
efficiency of 99.1 percent and AOS to account for the 99.99 percent control
efficiency of the thermal oxidizer/scrubber system.
-Revised the VOC emission calculation in Condition C.8 to allow for the
99.99 percent VOC control efficiency of the Thermal Oxidizer.
-Corrected typographical error in Condition C.10.mm(changed MPCU to
MCPU).
-Added Condition C.11 to include regulation 02Q.0519:Termination,
Modification,Revocation of Permits.This condition addresses the
compliance requirements for the Thermal Oxidizer and the 4-Stage Caustic
Scrubber.
36 40 Section 2.1 D -Updated the summary of limits and standards table to include GenX
Compounds
NIA 45—47 Section 2.1 G -Added Condition for the regulatory requirements associated with the Lime
Silo ID No.NS-R and Lime Slaker(ID No.NS-112).
5—46 52—53 Section 2.2 B.2 -Updated table of emission limits for HF to account for the Thermal
4 l
Oxidizer.
NIA 55 Section 2.2 C.2 -Added a condition requiring the Permittee to submit a permit application
for the second step of the significant modification within 1 year of normal
operation.
NIA 56 Section 2.2 D -Added a condition requiring the Permittee to comply with a GenX
emissions limitation corresponding to the Consent Order.
49—58 64—72 Section 3.0 -Replaced General Conditions,version 4.0(12/17/15)with version 5.3
08/21/2018
State of North Carolina
DE Department of Environmental Quality
iw CIRTH CARCLINA
Of EMI Woft Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
03735T44 03735T43 March 14,2019 March 31, 2021
Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct and operate
the cmission 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 21 B 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: The Chemours Company FC, LLC
DBA, Chemours Company - Fayetteville Works
Facility ID: 0900009
Facility Site Location: 22828 NC Highway 87 W
City,County,State,Zip: Fayetteville,Bladen County,NC,28306-7332
Mailing Address: 22828 NC Highway 87 W
City,State,Zip: Fayetteville,NC,28306-7332
Application Number: 0900009.18E
Complete Application Date: July 16,2018
Primary SIC Code: 2821,3081,3083
Division of Air Quality, Fayetteville Regional Office
Regional Office Address: 225 Green Street,Suite 714
Fayetteville,NC 28301
Permit issued this the 14th day of March,2019
la rX 7. AW,
L�
William D. Willets, P.E., Chief,Air Permits 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)
2.3 Permit Shield for Nonapplicable Requirements
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
Permit No.03735T44
Page 3
SECTION 1 - 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 ollution control devices and a,.urtenances.
Page Emission Source Control DeviceNos. m No. Emission Source Description ID No. Control Deice Description
5 to 20, PS-A Natural g"o.2 fuel oil-fired boiler NIA NIA
42,48 Case-by-case (139.4 million Btu per hour maximum heat
MALT input)equipped with an oxygen trim
MALT DDDDD system
PS-B Natural gas/No.2 fuel oil-fired boiler NIA NIA
Case-by-ease (88.4 million Btu per hour maximum heat
MACT input)equipped with an oxygen trim
MACT DDDDD system
PS-C Natural gas/No.2 fuel oil-fired boiler(97 NIA NIA
NSPS De million Btu per hour maximum heat input)
Case-by-case equipped with a low-NOx burner and an
MACT oxygen trim system
MACT DDDDD
5,42 to PS-Temp Natural gas/No.2 fuel oil-fired temporary NIA NIA
44,48, boiler(Iess than 100.0 mullion Btu per
60 hour maximum heat input)
21 to 39, NS-A Hexafluoropropylene oxide(BYPO) POS POS
52 to 53, MACT FFFF process NCD-Hdrl Baffle-plate scrubber(7,000
56 to 59 NS-B Vinyl Ethers North process kilogram/hour liquid injection
MACT FFFF rate averaged over a 3-hour
NS-C Vinyl Ethers South process period)
MACT FFFF -or-
NS-D RSU Process NCD-Hdf2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection
NS-E FPS Liquid waste stabilization rate averaged over a 3-hour
NS-F MMF process period)
AOS AOS
NCD-Q 1 Thermal Oxidizer(10 million
Btu per hour,natural gas-fired)
-and-
NCD-Q2 4-Stage Scrubber:
Countercurrent Packed Bed
Stages 1,2,and 3;Caustic Stage
4 with minimum scrubber liquor
flow of 40 gallons per minute
and minimum pH of 7.1
21 to 39, NS-G-2 IXM Resins Process Fluorinator NCD-G2 Caustic scrubber
52 to 53,
56 to 59
21 to 22 NS-H IXM membrane process NIA NIA
NS-I IXM membrane coating NIA NIA
SW-1 Semiworks polymerization operation NIA NIA
SW-2 Semiworks laboratory hood NIA NIA
Permit No.03735T44
Page 4
Page Eaussion Source Emission Source Description Control Device Control Device Description
Nos. ID No. ID No.
21 to 39, NS-G-1 DCVI Resins Process(except Fluorinator) POS POS
52 to 53, N/A NIA
56 to 59 NS-K E-2 Process
NS-M TFElCO2 separation process AOS AOS
NCD-Q 1 Thermal Oxidizer(10 million
(NOTE:Although NS-Mis routed through Btu per hour,natural gas-fired)
one of two baffle plate scrubbers,NCD- -and-
Hdrl and NCD-Hdr2, the non-acid NCD-Q2 4-Stage Scrubber:
fluoride emissions from.this source are not Countercurrent Packed Bed
removed in the scrubber.) Stages 1,2,and 3;Caustic Stage
NS-N BFPO product container decontamination 4 with minimum scrubber liquor
process flow of 40 gallons per minute
(NOTE.Although NS-N is routed through and minimum pH of 7.1
one of two baffle plate scrubbers,NCD-
Hdrl and NCD-Hdr2, the non-acid
fluoride emissions from this source are not
removed in the scrubber.)
NS-O Vinyl Ethers North product container
decontamination process
(NOTE.Although NS-d is routed through
one of two baffle plate scrubbers,NCD-
Hdrl and NCD-Hdr2, the non-acid
fluoride emissions from this source are not
removed in the scrubber)
NS-P Vinyl Ethers South product container
decontamination process
(NOTE:Although NS-P is routed through
one of two baffle plate scrubbers,NCD-
Hdrl and NCD-Hdr2, the non-acid
fluoride emissions from.this source are not
removed in the scrubber.)
NS-B-2 VE-North Indoor Fugitives NCD-Q3 Carbon Adsorber
40, AS-A Polymer Processing Aid Process ACD-Al Wet scrubber(30 gallons per
52 to 53, minute water injection rate
56 to 59 averaged over a 3-hour period)
State-enforceable only
-and-
ACD-A2 Carbon Adsorber
WTS-A Extended aeration biological wastewater NIA NIA
treatment facility
41 WTS-B, Two(2)Indirect steam-heated rotary WTCD-1 Wet scrubber with nest
WTS-C sludge dryers eliminator
State-enforceable on2r
45 to 47 NS-R] Lime Silo NCD-Rl Pulse Jet Baghouse(300 square
feet of filter area)
45 to 47 NS-R2 Lime Slaker NCD-R2 Wet Particulate Scrubber
(minimum liquid injection rate of
2.9 gallons per minute)
Permit No.03735T44
Page 5
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 subj eet to the following
specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting requirements as
specified herein:
A. Three natural gas/No.Z fuel oil-fired boilers (ID Nos.PS-A,PS-B,and PS-Q
The following,table provides a sumrmrr of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate Matter Affected Sources:PS-A and PS-H 15A NCAC 02D.0503
0.2667 pounds particulate per million Btu heat inpnt
Affected Sources:PS-C
0.2268 pounds particulate per million Btu heat input
Sulfur Dioxide Affected Sources:PS-A and PS-B 15A NCAC 02D.0516
2.3 pounds SOz per million Btu heat input,each
Sulfur Dioxide Affected Source:PS-C(when firing fuel oil) 15A NCAC 02D.0524
Fuel oil sulfur content shall not exceed 0.5%by weight. (40 CFR Part 60,Subpart
Dc
Visible Emissions Affected Source:PS-A 15A NCAC 02D.0521(c)
40 percent opacity
Affected Source: PS-B and PS-C(when firing natural gas) 15ANCAC 02D.0521(d)
20 percent opacity
Visible Emissions Affected Source.• PS-C (when firing fuel oil) 15A NCAC 02D.0524
{40 CFR Part 60,Subpart
20 percent opacity De}
Nitrogen Oxides, Affected Source: PS-H 15A NCAC 02Q.0317
Sulfur Dioxide Nitrogen oxide<40 tons per year (PSD Avoidance)
Sulfur dioxide <40 tons per year
Sulfur Dioxide Affected Sources:PS-A,PS-B,PS-C,and PS-Temp 15A NCAC 02Q.0317
Sulfur dioxide<702.5 tons per year. (PSD Avoidance)
See Section 2.2 A.1 of this permit
Hazardous Air Pollutants Best Combustion Practices 15A NCAC 02D.1109
Hazardous Air Pollutants Affected Sources:PS-A,PS-C 15A NCAC 02D.1111 (40
Work Practices CFR Part 63,Subpart
Affected Sources: PS-B DDDDD)
1.1E-03 lb HCl/million Btu of heat input
2.0E-6 lb Hglmillion Btu of heat input
130 parts per million CO by volume,dry basis,corrected to 3
percent oxygen
6.2E-05 lb TSMlnvllion Btu of heat input
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of natural gas and No.2 fuel oil that are discharged from the
affected boilers(ED Nos.PS-A and PS-H)into the atmosphere shall not exceed 0.2667 pounds per million Btu heat
input.
b. Emissions of particulate matter from the combustion of natural gas and No.2 fuel oil that are discharged from the
affected boiler(ID No.PS-C)into the atmosphere shall not exceed 0.2268 pounds per million Stu heat input.
Permit No.03735T44
Page 6
Testin [15ANCAC 02Q.0508(f)]
c. If emissions testing is required,the testing shall be performed in accordance General Condition JJ.If the results of
this test are above the limits given in Section 2.1 A.La or A.l.b,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0503.
Monitoriu ecordkee in Re ortin [I 5A NCAC 02Q.0508(t)]
d. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of natural gas or No.2
fuel oil in these boilers(ID Nos.PS-A,PS-B and PS-C).
2. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from the affected boilers(ID Nos.PS-A and PS-R)when firing natural gas or No.2
fuel oil,and from the affected boiler(ID No.PS-C)when firing natural gas only,shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other
substances shall be included when determining compliance with this standard.
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.2.a,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/Recordkeeping_1Recordkeening [I5A NCAC 02Q.0508(f)]
c. No monitoringlrecordkeeping is required for sulfur dioxide emissions from the firing of natural gas or fuel oil in
these boilers(ID Nos.PS-A,PS-B and PS-C).
3. 15A NCAC 02D.0521. CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected boiler(ID No.PS-A)shall not be more than 40 percent opacity when averaged
over a six-minute period. However,six-minute averaging periods may exceed 40 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 90
percent opacity,
b. Visible emissions from the affected boiler(ID No.PS-B)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.
c. Visible emissions from the affected boiler(ID No.PS-C)shall not be more than 20 percent opacity when averaged
over a six-minute period when natural gas is fired in the boiler.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)]
d. 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.3.a through A.3.c,above,the Permittee shall be deemed
in noncompliance with 15A NCAC 02D.0521.
MoultoringJRecordkeeping euortine[15ANCAC 02Q .0508(f)]
e. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas or No.2 fuel
oil in these boilers(1D Nos.PS-A,PS-B and PS-C).
4. 15A NCAC 02D.0524:New Source Performance Standards(40 CFR 60,Subpart Dc)
a. For the affected boiler(ID No.PS-C),while Firing No.2 fuel oil only,the Permittee shall comply with all applicable
provisions,including the notification,testing,recordkeeping,and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 02D.0524, "New Source Performance Standards"
(NSPS)as promulgated in 40 CFR 60,Subpart Dc,including Subpar:A,"General Provisions."
Permit No.03735T44
Page 7
Emission Limitations
b. The maximum sulfur content of any fuel oil received and fired in the affected boiler(ID No.PS-Q shall not exceed
0.5 percent by weight. [40 CFR 60.42c(d)]
c. Visible emissions from the affected boiler(113 No.PS-C)shall not be more than 20 percent opacity when averaged
over a six-minute period,except for one six-minute period per hour of not more than 27 percent opacity. [40 CFR
60.43c(c)l
d. The opacity standards in Section 2.1 A.4.c,above,applies at all times when firing No.2 fuel oil,except during
periods of startup,shutdown or malfunction,[40 CFR 60.43c(d)]
e. No fuel sulfur limits or opacity limits apply under 15A NCAC 02D,0524 when firing natural gas in the affected
boiler(ID No.PS-Q.
Test[15A NCAC 02Q.0508(f)]
f. 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 limits given in Section 2.1 A.4.b or A-4.c,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0524.
g. The Permittee shall conduct an initial performance test using Method 9 of Appendix A-4 of 40 CFR Part 60 and in
accordance with General Condition JJ to demonstrate compliance with the opacity limit in Section 2.1 A.4.c,above,
and as follows. [40 CFR 60.47c(a)]
L The Permittee shall conduct the performance test within 180 days of initial startup.
U. The Permittee shall conduct subsequent Method 9 of Appendix A-4 of 40 CFR Part 60 performance tests
according to the schedule specified in Section 2.1 A.4.i,below.
iii. The observation period for Method 9 of Appendix A-4 of 40 CFR Part 60 performance tests may be reduced
from 3 hours to 60 minutes if all 6-minute averages are less than 10 percent and all individual 15-second
observations are less than or equal to 20 percent during the initial 60 minutes of observation.
If the results of this test are above the limits in Section 2.1 A.4.c,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0524.
Fuel Sulfur Monitoring [15A NCAC 02Q.0508(f)]
h. To assure compliance with the fuel sulfur limit in Section 2.1 A.4.b,above,the Permittee shall retain a copy of the
fuel supplier certification for any fuel oil fired at the affected boiler(ID No.PS-C). The fuel supplier certification
shall include the following information:
i. The name of the oil supplier;
ii. The sulfur content of the oil(in%by weight);and
iii. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil
in 40 CFR 60.41 c.
The Perm itree shall he deemed in noncompliance with 15A NCAC 02D.0524 if the sulfur content of the oil exceeds
the limit provided in Section 2.I.A.4.b of this permit or if fuel supplier certifications are not retained as described
above.[40 CFR 60.46c(e), 40 CFR 60.48c(fi]
❑vanity Monitorine[15A NCAC 02Q.0508(f)]
i. After completion of the initial performance testing in Section 2.1 A.4.g,above:,the Permittee shall comply with
visible emissions morritoring according to the following:
i. The Permittee shall conduct subsequent Method 9 performance tests using the applicable schedule in Section
2.1 A.4.i(i)(A)through AA.i(i)(D),below,or within 45 days of switching fuel combustion from natural gas to
No.2 fuel oil,whichever is later,as determined by the most recent Method 9 performance test results.The
observation period for Method 9 performance tests may be reduced from 3 hours to 60 minutes if all 6-minute
averages are less than 10 percent and all individual 15-second observations are less than or equal to 20 percent
during the initial 60 minutes of observation,[40 CFR 60.47c(a)(1)]
A. If no visible emissions are observed,a subsequent Method 9 performance test must be completed within 12
calendar months from the date that the most recent performance test was conducted;
B. If visible emissions are observed but the maximum 6-minute average opacity is less than or equal to 5
percent,a subsequent Method 9 performance test must be completed within 6 calendar months from the
date that the most recent performance test was conducted;
Permit No.03735T44
Page 8
C. If the maximum 6-minute average opacity is greater than 5 percent but less than or equal to 10 percent,a
subsequent Method 9 performance test must be completed within 3 calendar months from the date that the
most recent performance test was conducted;or
D. If the maximum 6-minute average opacity is greater than 10 percent,a subsequent Method 9 performance
test must be completed within 45 calendar days from the date that the most recent performance test was
conducted.
ii. If the maximum 6-minute opacity is less than 10 percent during the most recent Method 9 performance test,the
Permittee may,as an alternative to performing subsequent Method 9 performance tests,elect to perform
subsequent monitoring using Method 22 according to the procedures specified in Section 2.1 AA.i(ii)(A)and
AA.i(ii)(B)below.[40 CFR 60.47c(a)(2)]
(A) The Permittee shall conduct 10 minute observations(during normal operation)each operating day the
affected boiler(ID No.PS-C)fires No.2 fuel oil using Method 22 and demonstrate that the sum of the
occurrences of any visible emissions is not in excess of 5 percent of the observation period(i.e.,30 seconds
per 10 minute period).If the sum of the occurrence of any visible emissions is greater than 30 seconds
during the initial 10 minute observation,immediately conduct a 30 minute observation.If the sum of the
occurrence of visible emissions is greater than 5 percent of the observation period(i.e.,90 seconds per 30
minute period), the owner or operator shall either document and adjust the operation of the facility and
demonstrate within 24 hours that the sum of the occurrence of visible emissions is equal to or less than 5
percent during a 30 minute observation(i.e.,90 seconds)or conduct a new Method 9 performance test
using the procedures in condition(i)(i)above within 45 calendar days.
(B) If no visible emissions are observed for 10 operating days during which No.2 fuel oil is fired,observations
can be reduced to once every 7 operating days during which No.2 fuel oil is fired.If any visible emissions
are observed,daily observations shall be resumed.
The Permittee shall be decmed in noncompliance with 15A NCAC 02D.0524 if the opacity monitoring is not
conducted as specified.
Recordkeepin [15A NCAC 024.0508(f)and 40 CFR 60.48c(g)(2)]
j. The Permittee shall record and maintain records of the amounts of each fuel Fired during each month.The Permittee
shall be deemed in noncompliance with 15A NCAC 02D.0524 if records of the amount of each fuel fired during
each month are not maintained.
k The Permittee shall maintain records of No.2 fuel oil supplier certifications as specified in Section 2.1 A.4.h.i,
above.[40 CFR 60.48c(e)(2I), (f}(l)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if records of fuel sulfur content
monitoring are not maintained.
1. The Permittee shall keep the following opacity monitoring records:[40 CFR 60.48c(c)(I), (2)]
i. For each performance test conducted using Method 9 of appendix A-4 of 40 CFR Part 60, the Permittee shall
keep the records including the following:
(A) Dates and time intervals of all opacity observation periods;
(B) Name,affiliation,and copy of current visible emission reading certification for each visible emission
observer participating in the performance test;and
(C) Copies of all visible emission observer opacity field data sheets.
ii. For each performance test conducted using Method 22 of appendix A-4 of 40 CFR Part 60,the Permittee shall
keep the records including the following:
(A) Dates and time intervals of all visible emissions observation periods;
(B) Name and affiliation for each visible emission observer participating in the performance test;
(C) Copies of all visible emission observer opacity field data sheets;and
(D) Documentation of any adjustments made and the time the adjustments were completed to the affected
facility operation by the Permittee to demonstrate compliance with the applicable monitoring requirements.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0524 if these opacity monitoring records
are not maintained.
m. The Permittee shall maintain records of any occurrence and duration of any startup,shutdown,or malfunction in the
operation the affected boiler(ID No.PS-Q.[40 CFR 60.7(b)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524 if the records of startups,shutdowns,
and malfunctions are not maintained.
Permit No.03735T44
Page 9
o. All records required under Section 2.1 AA j through A.4.m shall be maintained by the Permittee for a period of two
years following the date of such record.[40 CFR 60.48c(i)]
The Permittee shall he deemed in noncompliance with 15A NCAC 02D .0524 if the records are not maintained for
the duration of 2 years.
Initial Notification[I5ANCAC 02Q.0508(f)]
p. The Permittee shall suhmit a construction notification of the date construction of the affected boiler(ID No.PS-C)
is commenced,postmarked no later than 30 days after such date.[40 CFR 60.7(a)(I)J
q. The Permittee shall submit an initial notification to the Regional Supervisor within 15 days of actual startup of the
affected boiler(ID No.PS-Q. The notification shall include:
i. The actual date of initial startup;and,
ii. The design heat input capacity of the boiler and identification of fuels to be combusted in the boiler.
[40 CFR 60.48c(a), 40 CFR 60.7(a)(3)]
Reporting r15A NCAC 02Q.0508(f)]
r. The Permittee shall submit a semiannual summary report 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 noncompliance from the requirements of this permit
and excess emissions must be clearly identified.The summary report shall include the following information:
i. Fuel supplier certification(s)for distillate fuel oil,as provided in Section 2.1.A.4.e of this permit;and
ii. A certified statement signed by the Permittee that the records of fuel supplier certification(s)submitted
represents all of the fuel fired at the affected boiler(ID No.PS-C)during the semiannual period.
iii. Records from any subsequent performance tests conducted as required in Section 2.1 A.4.1,above.
5. 15A NCAC 02Q.D317:AVOIDANCE CONDITIONS
for 15A NCAC 42D.D53D:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the affected
boiler(ID No.PS-H only)shall discharge into the atmosphere less than the following,per consecutive 12-month
period.
Pollutant Emission Limitation
(tons per►•ear)
Nitrogen Oxide 40
Sulfur Dioxide 40
Testing[15ANCAC 02Q.0508(f)]
b. if emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test are above the limit given in Section 2.1 A.5.a,above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0530.
Monitoring/Recordkeepima[I5ANCAC 02Q.0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a logbook(written or in electronic format),as follows:
i. The total quantity(in million standard cubic feet)of natural gas fired at the affected boiler;
ii. The total quantity(in 1,000 gallons)of No.2 fuel oil fired at the affected boiler;and,
iii. The fuel oil supplier certification for any fuel oil fired at the affected boiler(ID No.PS-H),including the sulfur
content of the fuel oil(in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if records of the fuel usage and fuel
oil sulfur contents are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling NOx emissions from the affected boiler(ID No.PS-H)
within 30 days after the end of each calendar month. Calculations shall be recorded in a logbook(written or
electronic format),according to the following formulas:
i. Calculate NOx emissions from the previous calendar month using the following equation:
Peanut No.03735T44
Page 10
Exox =20*Qfo2 +100*Qng
Where, Exox = NOx emissions(pounds)during the previous calendar month;
Qra = Quantity of fuel oil fired during the previous calendar month(1,000 gallons);
and,
Q- = Quantity of natural gas fired during the previous calendar month(million
standard cubic feet).
ii. Sum the NOx emissions from the affected boiler for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling NOx emission totals are greater than the NOx emission limit
provided in Section 2.1 A.5.a of this permit.
e. The Penmittee shall calculate monthly and 12-month rolling S02 emissions from the affected boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook(written or electronic format),
according to the following formulas:
i. Calculate S02 emissions from the previous calendar month using the following equation:
ES02=142 *Sfo2 *Qfn2 +0.6*Q„S
Where, Es02 = S02 emissions(pounds)during the previous calendar month;
S roa _ Sulfur content in the fuel oil(percent by weight).
Qro2 = Quantity of fuel oil fired during the previous calendar month(1,000 gallons);
and,
Qns = Quantity of natural gas fired during the previous calendar month(mullion
standard cubic feet).
ii. Sum the S02 emissions from the affected boiler for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling S02 emission totals are greater than the S02 emission limit
provided in Section 2.1 A5.a of this permit.
Reporting[15ANCAC 02Q ,0508(f))
f. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and December,and July
30 of each calendar year for the preceding six-month period between January and June. The report shall contain the
following:
i. The monthly NOx and 902 emissions from the affected boiler for the previous 17 calendar months;
ii. The 12-month rolling NOx and S02 emissions for each 12-month period ending during the reporting period;
and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
6. 15A NCAC 02D.1109.Case-by-Case MACT
a. The initial compliance date for the emission limitations and associated monitoring,recardkeeping,and reporting
requirements listed below is December 12,2013 for each boiler(ID Nos.PS-A,PS-B,and PS-C). These
conditions need not be included on the annual compliance certification until after the initial compliance date. These
limits apply except for periods of startup,shutdown,and malfunction.The Permittee shall follow the procedures in
15A NCAC 02D.0535 for any excess emissions that occur during periods of startup,shutdown,or malfunction.
h. The Permittee shall comply with this CAA§1120)standard until May 19,2019. The initial compliance date for the
applicable CAA§112(d)standard for"National Emission Standards for Hazardous Air Pollutants for Industrial,
Commercial,and Institutional Boilers and Process Heaters"is May 20,2019.On and after May 20,2019,the
Permittee shall comply with Section 2.1 A.7 for boilers( ID Nos.PS-A and PS-C)and Section 2.1 A.8 fnr boiler
(ID No.PS-B).
Permit No.03735T44
Page l 1
Testine[15A NCAC 02Q .0508(f)]
c. if emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ.
Work Practice Standards[15A NCAC 02Q .0508(f)]
d. The Permittee shall perform an annual boiler inspection and maintenance on each boiler(H)Nos.PS-A,PS-B,and
PS-C)as recommended by the manufacturer,or as a minimum,the inspection and maintenance requirement shall
include the following:
i. Inspect the burner,and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame pattern;and,
iii, Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and Functioning
properly.
The Permittee shall conduct at least one tune-up per calendar year to demonstrate compliance with this requirement.
The Permittee shall he deemed in noncompliance with 15A NCAC 02D.1109 if the affected boilers are not
inspected and maintained as required above.
e. The results of any required annual burner inspection and maintenance conducted on each boiler(ID Nos.PS-A,PS-
B,and PS-C)shall be maintained in a logbook(written or electronic format)on-site and made available to an
authorized representative upon request. The logbook sball record the following:
i. The date of each recorded action;
ii. The results of each inspection;and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if these records are not maintained.
Reporting[15A NCAC 02Q .0508(f)]
f. Notifications.The Permitter shall submit an initial notification according to 40 CFR 63.9(b)(4)and(5)not later than
15 days after the actual date of startup of boiler(H)No.PS-C). The Permittee shall be deemed in noncompliance
with 15A NCAC 02D. 1109 if this initial notification is not submitted.
g. Semiannual Summary Report. The Permittee shall submit a summary report 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 first summary report shall be required on
January 30,2014. The report shall include the following:
i. Company name and address;
ii. Statement by a responsible official with that official's name,title,and signature,certifying the trutb,accuracy,
and completeness of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;and,
iv. Signed statement indicating that no new types of fuel were fired in the affected sources.
7. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability
a. For the boilers(ID Nos.PS-A and PS-C),the Permittee shall comply with all applicable provisions for the"unit
designed to burn gas 1 subcategory,"including the monitoring,recordkeeping,and reporting contained in
Environmental Management Commission Standard 15A NCAC 02D .1111 "Maximum Achievable Control
Technology"(MALT)as promulgated in 40 CFR 63,Subpart DDDDD."National Emission Standards for
Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and Process Heaters"
and Subpart A"General Provisions."
[40 CFR 63.7485,63.7490(d),63.7499(1)]
b. In order for the boilers(ID Nos.PS-A and PS-C)to be considered in the"unit designed to bum gas 1 subcategory,"
the Permittee sball only bum liquid fuel for periodic testing of liquid fuel,maintenance,or operator training,not to
exceed a combined total of 48 hours during any calendar year,and during periods of gas curtailment or gas supply
interruptions of any duration.The Permittee shall be deemed in noncompliance with 15A NCAC 02D,1111 if the
No.2 fuel oil is burned in the boilers(II)Nos.PS-A and PS-C)for periodic testing of liquid fuel,maintenance or
operator training for more than 48 hours during any calendar year or if No.2 fuel oil is burned in the boilers(II)
Nos.PS-A and PS-C)during any periods other than gas curtailment or gas supply interruption. [40 CFR 63.7575]
Permit No.03735T44
Page 12
Definitions and Nomenclature
c. For the purpose of Section 2.1 7.A,the definitions and nomenclature contained in 40 CFR 63.7575 shall apply.
40 CFR Part 63 Subpart A-General Provisions
d. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A,General Provisions,according to the
applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63,Subpart DDDDD. [40 CFR
63.75651
Compliance Date
e. The Permittee shall comply with the CAA§1120)standards in Section 2.1 A.6 through May 19,2019. [40 CFR
63.7495(a)and(b),63.56(b)]
i. On and after May 20,2019,the Permittee shall comply with the requirements of Section 2.1 A.7 for the boiler
(ID No.PS-A)
ii. The Permittee shall comply with the requirements of this section for boiler(lD No.PS-C)on May 20,2019 or
upon startup,whichever is later.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.11 i 1 if the compliance dates are not met.
Notifications
f. As specified in 40 CFR 63.9(b)(4)and(5),if the initial startup of the boiler(ID No.PS-C)is after May 20,2019,
the Permittee shall submit an Initial Notification not later than 15 days after the actual date of startup of the boiler.
140 CFR 63.7545(c)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the Initial Notification is not
submitted.
g. The Permittee shall submit a Notification of Compliance Status for the boilers(ID Nos.PS-A and PS-C). The
notification must be signed by a responsible official and postmarked before the close of business within 60 days of
the compliance date specified in Section 2.1 A.7.e,above.The notification shall contain the following:
i. A description of the boilers(1D Nos.PS-A and PS-C),including a statement that the boilers are in"the unit
designed to bum gas 1 subcategory,"the design heat input capacity of the boilers,and description of the fuel(s)
burned.
ii. The following certification(s)of compliance,as applicable:
A. A signed certification that the facility completed the required initial tune-up for all of the boilers covered by
40 CFR Part 63,Subpart DDDDD and at this site according to the procedures Section 2.1 A.7.j,below;and
B. A signed certification that either the energy assessment performed according to Section 2.1 A.Tri,below,
and that the assessment is an accurate depiction of the facility at the time of the assessment,or that the
maximum number of on-site technical hours specified in the definition of energy assessment applicable to
the facility has been expended.
[40 CFR 63.7545(e)(8)and 63.7530(e),and(f)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the Notification of Compliance
Status is not submitted.
h. The Permittee shall submit a notification of intent to fire an alternative fuel within 48 hours of the declaration of
each period of natural gas curtailment or supply interruption.The notification must include the following
information:
i. Company name and address;
ii. Identification of the affected boiler;
iii. Reason the Permittee is unable to use natural gas or equivalent fuel,including the date when the natural gas
curtailment was declared or the natural gas supply interruption began;
iv. The type of alternative fuel the Permittee intends to use;and
v. Dates when the alternative fuel use is expected to begin and end.
[40 CFR 63.7545(f)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the notification of intent to fire an
alternative fuel is not submitted.
General Compliance Requirements
i. The Permittee shall comply with the work practicc standards in Section 2.1 A.7 j,below at all times the boilers(ID
Nos.PS-A and PS-C)are operating. [40 CFR 63.7500(f)and 63.7505(a)]
Permit No.03735T44
Page 13
Work Practice Standards[15A NCAC 02Q.0508(f)]
j. The Permittee shall conduct a tune-up of the boilers(ID Nos.PS-A and PS-C)as specified below.The Permittee
shall conduct the tune-up while burning the type of fuel that provided the majority of the heat input to the boiler of
the 12 months prior to the tune-up.
i As applicable,the Permittee shall inspect the burner.and clean or replace any components of the burner as
necessary. The Permittee may perform the burner inspection at any time prior to the tune-up or delay the burner
inspection until the next scheduled or unscheduled shutdown,but each burner must he inspected at least once
every 72 months.
ii. Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame pattern. The
adjustment should be consistent with the manufacturer's specifications,if available;
iii. Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctly calibrated and
Functioning properly.The Permittee may delay the inspection until the next scheduled unit shutdown.
iv. Optimize total emissions of carbon monoxide.This optimization should be consistent with the manufacturer's
specifications,if available,and with any NOx requirement to which the unit is subject.
v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by volume,and
oxygen in volume percent,before and after the adjustments are made(measurements may he either on a dry or
wet basis,as long as it is the same basis before and after the adjustments are made).Measurements may be
taken using a portable CO analyzer.
❑i. The oxygen level shall be set no lower than the oxygen concentration measured during the most recent tune-up.
[40 CFR 63.7500(a)and 63.7540(a)(10)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if these work practice standards are
not met.
k. The tune-ups for the boilers(ID Nos.PS-A and PS-C)shall be conducted according to the following schedule.
[Table 3 of Subpart DDDDD]
i. The initial tune-up for the existing boiler(ID No.PS-A)shall be conducted no later than May 20,2019. [40
CFR 63.7510(e)]
ii. The initial tune-up for the new boiler(ID No.PS-C)shall be no later than 61 months after initial startup of the
unit. [40 CFR 63.7510(g)and 63.7515(d)]
iii, Subsequent tune-ups for each boiler(ID Nos.PS-A and PS-C)shall be conducted every 5 years and no more
than 61 months after the previous tune-up. [40 CFR 63.7540(a)(12),63.7515(d)]
The Permittec shall be deemed in noncompliance with 15A NCAC 02D .1111 if the initial and annual tune-ups are
not conducted as specified.
1. If the boilers(ID Nos.PS-A and PS-C)are not operating on the required date for a tune-up,the tune-up must he
conducted within 30 calendar days of startup. [40 CFR 63.7515(g)and 63.7540(a)(13)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the delayed tune-up is not
conducted within 30 calendar days of startup.
m. At all times,the Permittee shall operate and maintain the boiler,including associated air pollution control equipment
and monitoring equipment,in a manner consistent with safety and good air pollution control practices for
minimizing emissions.Determination of whether such operation and maintenance procedures are being used will be
based on information available to DAQ that may include,but is not limited to,monitoring results,review of
operation and maintenance procedures,review of operation and maintenance records,and inspection of the source.
[40 CFR 63.7500(a)(3)]
The Permirtee shall be deemed in noncompliance with 15A NCAC 02D.1 f 11 if the boiler is not operated in a
manner consistent with safety and good air pollution control practices for minimizing emissions.
n. To demonstrate initial compliance,the Permittee shall also conduct a one-time energy assessment for the existing
boiler(ID No.PS-A)performed by a qualified energy assessor.The energy assessment must be conducted no later
than May 20,2019.The energy assessment must include the following with extent of the evaluation for the
following appropriate for the 32 on-site technical hours as defined in 40 CFR 63.7575. [40 CFR 63.7500(a)(1),
Table 3]
i. A visual inspection of the boiler or process heater system.
ii. An evaluation of operating characteristics of the boiler or process heater systems,specifications of energy using
systems,operating and maintenance procedures,and unusual operating constraints.
iii. An inventory of major energy use systems consuming energy from affected boilers and process heaters and
which are under the control of the boiler/process heater ownerloperator.
Permit No.03735T44
Page 14
iv. A review of available architectural and engineering plans,facility operation and maintenance procedures and
logs,and fuel usage.
v. A review of the facility's energy management program and provide recommendations for improvements
consistent with the definition of energy management program,if identified.
vi. A list of cost-effective energy conservation measures that are within the facility's control.
vii. A list of the energy savings potential of the energy conservation measures identified.
viii. A comprehensive report detailing the ways to improve efficiency,the cost of specific improvements,benefits,
and the time frame for recouping these investments.
ix. An energy assessment completed on or after January 1,2008,that meets or is amended to meet the energy
assessment requirements in Section 2.1 A.87.n(i)through A.7.n(viii),above,satisfies the energy assessment
requirement.If the Permittee operates under an energy management program developed according to the
ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year
between January 1,2008 and May 20,2019,that includes the boilers(ID No.PS-A)also satisfies the energy
assessment requirement.
Recordkeepina Requirements[15A NCAC 02Q.0508(f)]
o. The Permittee shall keep the following records:
i. A copy of each notification and report submitted to comply with Section 2.1 A.7,including all documentation
supporting any Initial Notification or Notification of Compliance Status,or semiannual compliance report that
has been submitted,according to the requirements in 40 CFR 63.1 0(b)(2)(xiv). [40 CFR 63.7555(a)(1)]
ii. A report,maintained on-site and submitted to DAQ if requested,containing the information in paragraphs(A)
through(C)below[40 CFR 63.7540(a)(10)(vi)]:
(A) The concentrations of carbon monoxide in the effluent stream of each boiler(ID Nos.PS-A and PS-C)in
parts per million by volume,and oxygen in volume percent,measured before and after the tune-ups of the
boilers(ID Nos.PS-A and PS-C);
(S) A description of any corrective actions taken as a part of the tune-up;and
(C) The type and amount of fuel used over the 12 months prior to the tune-ups,but only if the boilers were
physically and legally capable of using more than one type of fuel during that period.Units sharing a fuel
meter may estimate the fuel use by each unit.
iii. The associated records for compliance with the work practice standards in Section 2.1 A.7.i through A.7.m,
above,including the occurrence and duration of each malfunction of operation(i.e.,process equipment)or the
required air pollution control and monitoring equipment. [40 CFR 63.10(b)(2)1
iv. Records of the total hours per calendar year that alternative fuel is burned in the boilers(ID Nos.PS-A and PS-
C)and the total hours per calendar year that the boilers operated during periods of gas curtailment or gas supply
emergencies. [40 CFR 63.7555(h)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if these records are not maintained.
p. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review;
ii. keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective
action,report,or record;and
iii. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if records are not maintained as
specified above. [40 CFR 63.7560 and 63.10(b)(1)]
Reporting Requirements[15A NCAC 02Q.0508(f)]
q. The Permittee shall submit compliance reports to the DAQ every five years.The first report shall cover the period
beginning on the compliance date specified in Section 2.1 A.7.e,above,and ending on December 31 within five
years after the compliance date in Section 2.1 A.7.e,above.Subsequent reports shall cover the five-year periods
from January 1 to December 31.The compliance reports shall be postmarked on or before January 31.
[40 CFR 63.7550(a),(b)and 63,10(a)(4),(5)]
r. The Permittee shall submit the annual compliance report via the CEDRI. (CEDRI can be accessed through the EPA's
Central Data Exchange,CDX.)The Permittee shall use the appropriate electronic report in CEDRI 40 CFR Part 63,
Subpart DDDDD.Instead of using the electronic report in CEDRI for this 40 CFR Part 63,Subpart DDDDD,the
Permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site
(http:llwww,epa.gov/tin/chief/cedri/index.html),once the XML schema is available,If the reporting form specific to
Permit No.03735T44
Page 15
40 CFR Part 63,Subpart DDDDD is not available in CEDRI at the time that the report is due,the Permittec shall
submit the report to DAQ.The Permittee shall begin submitting reports via CEDRI no later than 90 days after the
form becomes available in CEDRI. [40 CFR 63.7550(h)(3)]
s. The Pemvttcc shall include the following information in the annual compliance report:
i. Company and facility name and address;
ii. Process unit information,emissions limitations,and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. The date of the most recent tune-up for each boiler(ID Nos.PS-A and PS-C)required according to Section 2.1
A.7 j.Include the date of the most recent burner inspection if it was not done as scheduled and was delayed
until the next scheduled or unscheduled unit shutdown;and
v. If there are no periods of noncompliance from the requirements of the work practice requirements in Section 2.1
A.7 j,above,a statement that there were no deviations from the work practice standards during the reporting
period.
[40 CFR 63.7550(a)and(c)(1),(c)(5)(i)through(iii),(c)(5)(xiv),(c)(5)(xvii),and Table 9]
t. If the Permittee has a period of noncompliance with a work practice standard for periods of startup and shutdown
during the reporting period, the compliance report must also contain the following information:
i. A description of the period of noncompliance and which work practice standard from which the Permittee was
in noncompliance;and
ii. Information on the number,duration,and cause of periods of noncompliance(including unknown cause),as
applicable,and the corrective action taken.
[40 CFR 63.7540(b),63.7550(a)and(d)and Table 9]
S. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[40 CFR 63.7485,63.7490(d),63.7499(q)and(u)]
a. For the existing boiler(ID No.PS-B)designed to burn light liquid fuel with a heat input capacity 10 million Stu per
hour or greater,the Permittee shall comply with all applicable provisions,including the monitoring,recordkeeping,
and reporting contained in Environmental Management Commission Standard 15A NCAC 02D.1111 "Maximum
Achievable Control Technology"(MALT)as promulgated in 40 CFR 63, Subpart DDDDD"National Emission
Standards for Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and
Process Heaters"(Subpart DDDDD)and Subpart A"General Provisions."
Definitions and Nomenclature[40 CFR 63.75751
b. For the purpose of this permit condition,the definitions and nomenclature contained in 40 CFR 63.7575 shall apply.
40 CFR Part 63 Subpart A General Provisions[40 CFR 63,7565]
c. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A General Provisions according to the
applicability of Subpart A to such sources as identified in Table 10 to Subpart 5D.
Compliance Date[40 CFR 63.56(b)and 63.7510(e)]
d. The Permittee shall comply with the CAA§1120)standard in Section 2.1 A.6 through May 19,2019. The
Permittee shall be subject to the requirements of this standard starting May 20,2019.
e. The Permittee shall:
i. Complete the initial tune up and the one-time energy assessment specified in Section 2.1 A-8.s through A.B.u_no
later than May 20,2019.
ii. Complete the initial compliance requirements in Section 2.1 A.81 through A.S.n, below,no later than
November 16,2019 and according to the applicable provisions in 40 CFR 63.7(a)(2).
General Compliance Requirements 140 CFR 63.7500(a)(3),63.7505(a)]
f. At all times the boiler(ID No.PS-B)is operating,the Permittee shall be in compliance with the emission standards
in Section 2.1 A.8.h,except during periods of startup and shutdown.During startup and shutdown,the Permitter
shall comply with the requirements of Section 2.1 A.8.v and A,S.w.
g. At all times, then Permittee shall operate and maintain the boiler(ID No.PS-B),including associated air pollution
control equipment and monitoring equipment,in a manner consistent with safety and good air pollution control
practices for minimizing emissions.Determination of whether such operation and maintenance procedures are being
Permit No.03735T44
Page 16
used will be based on information available to the Administrator that may include,but is not limited to,monitoring
results,review of operation and maintenance procedures,review of operation and maintenance records,and
inspection of the source.
Emission Limits[15A NCAC 02Q.0508(f),40 CFR 63.7500(a)(1),Table 2 of 40 CFR Part 63,Subpart DDDDD]
h. The boiler(ID No.PS-B)shall meet the following emission limits:
Pollutant Emission Limit
Hydrochloric acid 1.l E-03 lb per million Btu of heat input
Mercury 2.011-06 lb per million Btu of heat input
Carbon monoxide 130 ppm by volume on a dry basis corrected to 3 percent
oxygen
Filterable particulate matter 7.9E-03 lb per million Btu of heat input
or Total suspended metals or 6.2E-05 lb per million Btu of heat input
Testing[15A NCAC 02Q.0508(t)]
i. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test(s)are above the limit given in Section 2.1 AXX above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .1111.
Notifications 115A NCAC 02Q.0508(t)]
j. The Permittee shall submit the following notifications:
i. A Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled
to begin. [40 CFR 63.7545(d)]
ii. The Permittee shall submit the Notification of Compliance Status,including performance test results and fuel
analyses,before the close of business on the 60th day following the completion of the performance test and
other initial compliance demonstrations for the boiler(ID No.PS-B). The Notification of Compliance Status
report must contain all the information specified in 40 CFR 63.7545(e)(1)through(8),as applicable. [40 CFR
63.9(h)(2)(ii),63.10(d)(2),63.7530(e)and 63.7545(e)]
The pennittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the notifications are not submitted
as required above.
Initial compliance requirements[15ANCAC 02Q.0508(t)]
k. The Permittee shall demonstrate compliance with the CO emission limits in Section 2.1 A.81,above,by developing
a site-specific stack test plan and conducting initial performance stack tests according to the schedule specified in
Section 2.1 A.8.e,above.The Permittee shall conduct each performance stack test according to the procedures in 40
CFR 63.7520. [40 CFR 63.7510(a)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the site-specific test plan and initial
stack tests are not conducted as required above.
1. The Permittee shall demonstrate initial compliance with the hydrogen chloride,mercury and total selected metal
emission limits in Section 2.1 A.8.h,above,according to the fallowing:
i. The Permittee shall develop a site-specific fuel monitoring plan according to the schedule specified in Section
2.1 A.8.e,above.
ii. The Permittee shall conduct a fuel analysis according to 40 CFR 63.7521 and the procedures in 40 CFR
63.7530(c).
iii. As an alternative,the Permittee may demonstrate initial compliance via performance stack testing as specified
in 40 CFR 63.7510(a).
[40 CFR 63.7510(a)and(b)and 63.7530(c)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the initial compliance requirements
for hydrogen chloride,mercury and total selected metals are not conducted as required above.
m. The Permittee shall establish an oxygen operating limit for the oxygen trim system installed on the boiler(ID No.
PS-B)according to the procedures in 40 CFR 63.7530(b)(4)(viii)and Table 7 of Part 63,Subpart DDDDD.
[40 CFR 63.7510(a)(3)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the operating limits are not
established as required above.
Permit No.03735T44
Page 17
n. The Permittee shall meet the work practice standard requirements specified in Section 2.1 A.8.s and A.8.t,below.
The Permittee shall demonstrate initial compliance with the work practice standard according to the schedule in
Section 2.1 A.8.e,above. [40 CFR 63.7510(e)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the work practice standards are not
met as required above.
Subsequent performance test requirements[15A NCAC 02Q .0508(f)]
o. If the boiler(ID No.PS-B)combusts ultra-low sulfur liquid fuel,the Permittee is not required to conduct subsequent
performance tests(i.e.,stack tests or fuel analyses)iFthe pollutants measured during the initial compliance
performance tests meet the emission limits in Section 2.1 A.8.k above.The Permittee shall demonstrate ongoing
compliance with the emissions limits by monitoring and recording the type of fuel combusted on a monthly basis,as
required in Section 2.1 A.8.r,below. [40 CFR 63.7515(h)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the type of fuel combusted is not
monitored and recorded monthly as required.
p. If the Permittee intends to use a fuel other than ultra-low sulfur liquid fuel,natural gas,refinery gas,or other gas 1
fuel, the Permittee shall conduct new performance tests(i.e.,stack tests or fuel analyses)within 60 days of burning
the new fuel type.In addition, the Permittee shall comply with the following:
i. The Permittee shall conduct subsequent stack tests on an annual basis.Each annual performance stack test shall
be completed no more than 13 months after the previous performance test.The Permittee may conduct
subsequent performance tests at a reduced frequency if the requirements in 40 CFR 63.7515(b)and(c)are met.
[40 CFR 63.7515(a)]
ii. The Permittee shall conduct all subsequent fuel analyses and determine the hydrogen chloride,mercury,and
total selected metals emission rates on a monthly basis.The Permittee may conduct subsequent fuel analyses at
a reduced frequency if the requirements in 40 CFR 63.7515(e)are met.The Permittee shall conduct the fuel
analysis according to the following procedures
(A) Conduct monthly fuel analysis for each pollutant according to 40 CFR part 63,Subpart DDDDD,Table 6;
(B) Reduce the data to 12-month rolling averages;
(C) Maintain the 12-month rolling averages at or below the applicable emission limit in Section 2.1 A.B.h,
above,and
(D) Calculate the applicable emission rate from the boiler(ID No.PS-B)or process heater in units of lb per
million Btu using equations 15, 17, 18,and/or 19,in 40 CFR 63.7530.
[40 CFR 63.7515(e)and 63.7540(a)and Table 8 of Part 63,Subpart DDDDD]
iii. The Permittee shall confirm or reestablish operating limits during performance tests. [40 CFR 63.7540(a)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the subsequent performance test
requirements are not conducted as required.
Monitoring requirements[15A NCAC 02Q.0508(f)]
q. The Permittee shall install,operate,and maintain an oxygen trim system on the boiler(ID No.PS-B)according to
the following procedures:
L The Permittee shall operate the oxygen trim system with the oxygen level set no lower than the lowest hourly
average oxygen concentration measured during the most recent CO performance test as the operating limit for
oxygen.
ii. The CPMS must complete a minimum of one cycle of operation every 15-minutes.The Permittee shall have a
minimum of four successive cycles of operation,one representing each of the four 15-minute periods in an
hour,to have a valid hour of data.
iii. The Permittee shall operate the monitoring system as specified in 40 CFR 63.7535(b),and comply with the data
calculation requirements specified in 40 CFR 63.7535(c).
iv. Any 15-minute period for which the monitoring system is out-of-control and data are not available for a
required calculation constitutes a period of noncompliance from the monitoring requirements.Other situations
that constitute a monitoring noncompliance are specified in 40 CFR 63.7535(d).
v. The Permittee shall determine the 30-day rolling average of all recorded readings,except as provided in 40 CFR
63.7535(c),
vi. The Permittee shall record the results of each inspection,calibration,and validation check.
[40 CFR 63.7525(a)and(d)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I 111 if the oxygen trim system monitoring
requirements are not met.
Permit No.03735T44
Page 18
r. The Permittee shall monitor the type and amount of all fuels burned in the boiler(1D No.PS-S)to demonstrate that
all fuel types and mixtures of fuels burned would result in equal to or lower emissions of hydrogen chloride,
mercury,and TSM than the applicable emission limit for each pollutant. [40 CFR 63.7540(a)(2)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.111I if the fuel type and amount is not
monitored as required above.
Work Practice Standards[15A NCAC 02Q.0508(f)]
s. The Permittee shall conduct the tune-up of the boiler(ID No.PS-S)while burning the type of fuel(or fuels in case
of units that routinely burn a mixture)that provided the majority of the heat input to the boiler or process heater over
the 12 months prior to the tune-up. The Permittee shall conduct the tune-up of the boiler(ID No.PS-S)as follows:
i. As applicable,the Permittee shall inspect the burner,and clean or replace any components of the burner as
necessary. The Permittee may perform the burner inspection any time prior to the tune-up or delay the burner
inspection until the next scheduled or unscheduled unit shutdown but each burner must be inspected at least
once every 72 months;
ii. The Permittee shall inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the
flame pattern.The adjustment should be consistent with the manufacturers specifications,if available;
iii. The Permittee shall inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is
correctly calibrated and functioning properly(you may delay the inspection until the next scheduled unit
shutdown);
iv. The Permittee shall optimize total emissions of carbon monoxide.This optimization should he consistent with
the manufacturers specifications,if available,and with any NOx requirement to which the unit is subject;and
v. The Permittee shall measure the concentrations in the effluent stream of carbon monoxide in parts per million,
by volume,and oxygen in volume percent,before and after the adjustments are made(measurements may be
either on a dry or wet basis,as long as it is the same basis before and after the adjustments are made).
Measurements may be taken using a portable CO analyzer.
[40 CFR 63.7500(a),63.7540(a)(10)and(12)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if these work practice standards are
not met.
t. Each tune-up for the boiler(ID No.PS-S)shall be conducted eery five years and no more than 61 months after the
previous tune-up.If the unit is not operating on the required date for a tune-up,the tune-up must be conducted
within 30 calendar days of startup. [40 CFR 63.7515(d),63.7515(g),and 63.7540(a)(l 3)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the tuneups are not conducted
according to the required schedule.
Enerev Assessment Rey„uirements[15A NCAC 02Q.0508(f)]
u. The Permittee shall have a one-time energy assessment performed by a qualified energy assessor for the boiler(ID
No.PS-S).The energy assessment must address the following requirements,with the extent of the evaluation far
Section 2.1 A.8.u(i)through A.8.u(v),below,appropriate for the on-site technical hours listed in 40 CFR 63.7575.
An energy assessment completed on or after January 1,2008,that meets or is amended to meet the following energy
assessment requirements,satisfies the energy assessment requirement.If the Permittee operates under an energy
management program developed according to the ENERGY STAR guidelines for energy management or compatible
with ISO 50001 for at least one year between January 1,2008 and May 20,2019,that includes the boiler(11D No.
PS-S)also satisfies the energy assessment requirement.
i. A visual inspection of the boiler or process heater system.
ii. An evaluation of operating characteristics of the hoiler or process beater systems,specifications of energy using
systems,operating and maintenance procedures,and unusual operating constraints.
iii. An inventory of major energy use systems consuming energy from the boiler(11D No.PS-E)and which are
under the control of the boiler/process heater owner/operator.
iv. A review of available architectural and engineering plans,facility operation and maintenance procedures and
logs,and fuel usage.
v. A review of the facility's energy management program and provide recommendations for improvements
consistent with the definition of energy management program,if identified.
❑i. A list of cost-effective energy conservation measures that are within the facility's control.
❑ii. A list of the energy savings potential of the energy conservation measures identified.
❑iii.A comprehensive report detailing the ways to improve efficiency,the cost of specific improvements,henefits,
and the time frame for recouping those investments.
Permit No. 03735T44
Page 19
[40 CFR 63.7500(a)(1)and Table 3 to Part 63,Subpart DDDDD]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the requirements in energy
assessment requirements are not met.
Startups and Shutdowns
v. The Pennittee shall comply with all applicable emission limits at all times except during startup and shutdown
periods.The Permittee shall meet the startup work practice requirements below.
L All continuous monitoring systems(CMS)shall be operated during startup,
ii. For startup of the boiler(ll]No.PS-B),one or a combination of the following clean fuels shall be used:Natural
gas,synthetic natural gas,propane,other Gas 1 fuels,distillate oil,syngas,ultra-low sulfur diesel,fuel oil-
soaked rags,kerosene,hydrogen,paper,cardboard,refinery gas,liquefied petroleum gas,clean dry biomass,
and any fuels meeting the appropriate HCl,mercury and TSM emission standards by fuel analysis.
iii. The Permittee has the option of complying using either of the following work practice standards.
(A) If complying using definition(1)of"startup"in 40 CFR 63.7575,once the Permittee starts firing fuels that
are not clean fuels,the Pennittee shall vent emissions to the main stack(s)and engage all of the applicable
control devices. Startup ends when steam or heat is supplied for any purpose,OR
(B) If complying using definition(2)of"startup"in 40 CFR 63.7575,once the Permittee stares to feed fuels
that are not clean fuels,the Permittee shall vent emissions to the main stack(s)and engage all of the
applicable control devices so as to comply with the emission limits within 4 hours of start of supplying
useful thermal energy.The Permittee shall engage and operate PM control within one hour of first feeding
fuels that are not clean Fuels.The Permittee shall starl all applicable control devices as expeditiously as
possible,but,in any case,when necessary to comply with other standards applicable to the source by a
permit limit or a rule other than this section that require operation of the control devices.The Pennittee
shall develop and implement a written startup and shutdown plan,as specified in 40 CFR 63.7505(e).
iv, The Permittee shall collect monitoring data during periods of startup,as specified in 40 CFR 63.7535(b).
v. The Permittee shall keep records during periods of startup and provide reports concerning activities and periods
of startup,as specified in 40 CFR 63.7555.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the startup procedures are not
followed.
w. The Permiree shall comply with all applicable emission limits at all times except during startup and shutdown
periods.The Permittee shall meet the shutdown work practice requirements below.
i. The Permittee shall operate all CMS during shutdown.
ii. While firing fuels that are not clean fuels during shutdown,the Permittee shall vent emissions to the main
stack(s)and operate all applicable control devices when necessary to comply with other standards applicable to
the source that require operation of the control device.
iii. If,in addition to the fuel used prior to initiation of shutdown,another fuel must be used to support the shutdown
process,that additional fuel must be one or a combination of the following clean Fuels:Natural gas,synthetic
natural gas,propane,other Gas 1 fuels,distillate oil,syngas,ultra-low sulfur diesel,refinery gas,and liquefied
petroleum gas.
iv. The Permittee shall collect monitoring data during periods of shutdown,as specified in 40 CFR 63.7535(b).
v. The Permittee shall keep records during periods of shutdown.
vi. The Permitee shall provide reports concerning activities and periods of shutdown,as specified in 40 CFR
63.7555.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the shutdown procedures are not
followed.
Reeordkeepinp,Requirements[15A NCAC 02Q.0508(f)]
x. The Permittee shall keep the following records:
i. A copy of each notification and report submitted to comply with 40 CFR Part 63, Subpart DDDDD and Section
2.1 A-8,including all documentation supporting any Initial Notification or Notification of Compliance Status,or
semiannual compliance report that has been submitted,
[40 CFR 63.10(b)(2)(xiv)and 63.7555(a)(1)]
ii. Records of performance tests,fuel analyses,or other compliance demonstrations and performance evaluations.
[40 CFR 63.1 0(b)(2)(viii)]
iii. A report,maintained on-site and suhmitted to DAQ,if requested,containing the information in the following
paragraphs:
Permit No. 03735T44
Page 20
(A) The concentrations of carbon monoxide in the effluent stream of the boiler(ID No.PS-B)in parts per
million by volume,and oxygen in volume percent,measured at high Fire or typical operating load, before
and after the tune-up of the boiler or process heater;
(B) A description of any corrective actions taken as a part of the tune-up;and
(C) The type and amount of fuel used over the 12 months prior to the annual adjustment,but only if the unit
was physically and legally capable of using more than one type of fuel during that period.Units sharing a
fuel meter may estimate the fuel use by each unit.
[40 CFR 63.7540(a)(10)(vi)]
iv, For each continuous monitoring system,keep the following records.
(A) Records described in 40 CFR 63.1 0(b)(2)(vii)through(xi).
(B) Previous(i.e., superseded)versions of the performance evaluation plan as required in 40 CFR 63.8(d)(3).
(C) Request for alternatives to relative accuracy test for CEMS as required in 40 CFR 63.8(f)(6)(i).
(D) Records of the date and time that each period of noncompliance started and stopped.
[40 CFR 63.7555(b)]
❑. Keep records required in Table 8 of 40 CFR Part 63,Subpart DDDDD including records of all monitoring data
and calculated averages for applicable operating limits,such as operating load,to show continuous compliance
with each emission limit and operating limit that applies.
vi. Keep the applicable records in 40 CFR 63.7555(d)(1)through(d)(13).
[40 CFR 63.7555]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if these records are not maintained.
y. The Permittee shall:
i. Maintain records in a form suitable and readily available for expeditious review;
ii. Keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective
action,report,or record;and
iii. Keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years.
[40 CFR 63.7560 and 63.10(b)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.l l l l if the recordkeeping requirements
above are not met.
Reporting Re uirements[15A NCAC 02Q.0508(f)]
a. The Permittee shall submit a compliance report to the DAQ on a semi-annual basis,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.
i. The first compliance report shall be postmarked on or before July 30,2019 and cover the period from May 20,
2019 through June 30,2019.
ii. The compliance reports shall also be submitted electronically to the EPA via the procedures in 40 CFR
63.7550(h).
aa. The compliance report shall contain:
i. The information specified in 40 CFR 63.7550(c),as applicable.
ii. For each period of noncompliance with an emission limit or operating limit, the report shall contain the
information in40 CFR 63.7550(d)and(e),as applicable.
[40 CFR 63.7550(c)]
bb. Within 60 days after the date of completing each performance test(defined in 40 CFR 63.2)including any
associated fuel analyses and/or CMS performance evaluation(defined in 40 CFR 63.2)as required by 40 CFR Part
63,Subpart DDDDD,the Permittee shall submit the results to the DAQ pursuant to 40 CFR 63.10(d)(2)and to the
EPA via the procedures in 40 CFR 63.7550(h). [40 CFR 63.7550(h)]
Permit No.03735T44
Page 21
B. [RESERVED]
C. FPSI.tXM Process Area consisting of:
Primary Operating Scenario US) Alternative Operating Scenario AOS
The following emission units are controlled by one of The following emission units are controlled by a thermal
two baffle plate scrubbers(ID Nos.NCD-Hdr1 or oxidizer(ID No.NCD-Q1)in series with a 4-stage
NCD-Hdr2) scrubber(ID No.NCD- 2
NS-A Hexafluoropropylene oxide(HFPO) NS-A Hexafluoropropylene oxide(HYPO)Process
Process
NS-B Vinyl Ethers North Process NS-B Vinyl Ethers North Process
NS-C Vinyl Ethers South Process NS-C Vinyl Ethers South Process
NS-D RSU Process NS-D RSU Process
NS-E Liquid Waste Stabilization Process NS-E Liquid Waste Stabilization Process
NS-F MMF Process NS-F MMF Process
NS-G-1 IXM Resins Process_except Fluorinator
The following sources are not controlled in the baffle NS-K E-2 Process
plate scrubbers(ID Nos.NCD-Hdrl and NCD-Hdr2)
NS-G-I IXM Resins Process—except Fluorinator NS-M TFE/CO2 Separation Process
NS-K E-2 Process NS-N HFPU Product Container Decontamination
Process
NS-M TFEICO2 Separation Process* NS-O Vinyl Ethers North Product Container
Decontamination Process
NS-N BFPO Product Container NS-P Vinyl Ethers South Product Container
Decontamination Process* Decontamination Process
NS-U Vinyl Ethers North Product Container
Decontamination Process*
NS-P Vinyl Ethers South Product Container
Decontamination Process*
*These sources arc routed through one of the baffle plate scrubbers(ID Nos.NCD-HdrI or NCD-Hdr2)but the scrubber does not control
the non-acid fluoride VOC emissions from these sources(POS).
The following emission unit is controlled by a caustic scrubber(ID No.NCD G2)(PUS and AOS):
LXM Resins Process—Fluorinator(ID No.NS-G-2)
The following sources are not controlled(POS and AOS):
IXM Membrane Process(ID No.NS-H),
IXM Membrane Coating(ID No.NS-I),
Semiworks Polymerization Operation(ID No.SW-1),and
Semiworks Laboratory Hood(ID No. SW-2)
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 Affected Sources: ID No.NS-I 15A NCAC 02D.0515
E=4,10 PO,61 for P<30 tonslhour
where:
E=allowable emission rate in pounds per hour,and
P=process weight rate in tons per hour
Sulfur Dioxide Affected Source:ID No.NCD-Q1 15A NCAC 02D.0514
2.31b SO2 per mullion Btu heat input
Visible Emissions Affected Sources: ID No.NS-I and NCD-Q2 15A NCAC 02D.0521
20%visible opacity emissions
Permit No. 03735T44
Page 22
Regulated Pollutant Limits/Standards Applicable Regulation
Odors State-enforceable only 15A NCAC 02D.1806
See Section 2.2 B.5
Toxic Air Pollutants State-enforceable only(all FPNVLXM process 15A NCAC 02D A 100
units)
Toxic air pollutant limits shall not be exceeded. See
Sections 2.2 B.1 and 2.2 B.2
Volatile Organic Affected Sources: ID No.NS-B 15A NCAC 02Q.0317
Compounds VOC emissions<68.9 tons(12-month (PSD Avoidance)
Affected Sources: ID No.NS-Gl
VOC emissions<40 tons(12-month
Affected Sources: ID No.NS-A
VOC emissions<85.3 tons(12-month
Affected Sources: ID No.NS-N
VOC emissions<40 tons(12-month
Volatile Organic Affected Sources:ID No.NS-I 15A NCAC 02D.0530(u)
Compounds Reporting for Projected Actual VOC Emissions
Hazardous Air Affected Sources: ID Nos.NS-A,NS-B,NS-C,NS- 15A NCAC 02D.1111
Pollutants G-1,and NS-G-2 (40 CFR 63, Subpart FEFF)
LDAR,wastewater,and heat exchanger requirements.
All PFASI (including State-enforceable only(all FPM(FXM process 15A NCAC 02Q.0519
GenX Compounds) units) Consent Orden
99.99 percent emission reduction of all PFAS
(including Gen7{Compounds)
GenX Compounds3 State-enforceable only(all FPN II.XM process 15A NCAC 02Q.0519
units) Consent Order
See Section 2.2 D.1
1. 15A NCAC 02Q.0508(j):ALTERNATIVE OPERATING SCENARIOS
The Permittee,contemporaneously with malting a change from one alternative operating scenario to another,shall record
in a logbook(written or electronic format)the scenario under which it is operating. [15A NCAC 02Q.05086)]
a. The Primary Operating Scenario(POS)is defined as follows:
i. The HFPO,Vinyl Ethers North,Vinyl Ethers South,RSU,FPS Liquid Waste Stabilization,and MVIF Processes
(m Nos.NS-A,NS-B,NS-C,NS-D,NS-E,and NS-F)controlled by one of two baffle-plate scrubbers(ID
Nos.NCD-Hdr1 and NCD-Hdr2);
ii. The TFE-0O2 Separation,HFPO Container Decontamination,VEN Container Decontamination,and VES
Container Decontamination Processes(m Nos.NS-M,NS-N,NS-O,and NS-P)are routed to the baffle plate
scrubbers(but the emission reduction is insignificant);and
iii. The IXM Resins Process—except Fluorinator and E-2 Process(ID Nos.NS-G-1 and NS-K)are uncontrolled.
b. The Alternative Operating Scenario(AOS)is defined as the HFPO Process,Vinyl Ethers North Process,Vinyl
Ethers South Process,RSU Process,FPS Liquid Waste Stabilization Process,MMF Process,IXM Resins Process-
except Fluorinator,E-2 Process,TFElCO2 Separation Process,HFPO Product Container Decontamination Process,
VEN Product Decontamination Process,and VES Product Container Decontamination Process(ID Nos.NS-A,NS-
B,NS-C,NS-D,NS-E,NS-F,NS-G-1,NS-K,NS-M,NS-N,NS-O,and NS-P)are controlled by the Thermal
Oxidizer(ID Nos.NCD-Ql)in series with the 4-Stage Scrubber(ID No.NCD-Q2).
c. Under both the POS and AOS, the LXM Resins Process—Fluorinator(ID No.NS-G-2)is controlled by a caustic
scrubber(ID No.NCD-G2)and the IXM Membrane Process,IXM Membrane Coaling,Semiworks Polymerization
Operation,and Semiworks Laboratory Hood(ID No.NS-H,NS-I,SW-1 and SW-2)are uncontrolled.
'PFAS means per-and polylluomalkyl substances.
'"Consent Order"means the Consent Order entered on February 25,200,in State of North Carolina,ex rek.,Michael S.Regan,Secretary,North Carolina
Department of Environmental Quality v.The Chentours Company FC,LLC,17 CVS 580(Bladen County).
3"GenX Compounds"means HFPO Dimer Acid,also known as C3 Dimer Acid(CAS No. 13252-13-6);HFPO Dimer Acid Fluoride,also known as C3
Dimer Acid Fluoride(CAS No.2062-98-8);and REPO Dimer Acid Ammonium Salt,also known as C3 Dimer Acid Ammonium Salt(CAS No.62037-50-
3}.
Permit No. 03735T44
Page 23
d. The Permittm shall permanently switch to the AOS no later than December 31,2019.Once the Permittee begins
operation under the AOS,they shall no longer operate under the POS.The Permittee shall submit a notification to
DAQ within 10 days of permanently switching to the AOS.
2. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the membrane coating process(ID No.NS-I)shall not exceed an allowable
emission rate as calculated by the following equation:
E=4.10xP°67
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 C.2.a,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0515.
MonitoringlRecordkeetain .[15ANCAC 02Q.0508(f)]
c. The Permittee shall maintain production records such that the process rates"P" in tons per hour,as specified by the
formulas contained above(or the formulas contained in 15A NCAC 02D.0515)can he derived,and shall make
these records available to a DAQ authorized representative upon request.The Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0515 if the production records are not maintained or the types of materials
and finishes are not monitored.
Reporting[15A NCAC 02Q.0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities specified in Section 2.1
C.2.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 noncompliance from the requirements of this permit must be clearly identified.
3. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. AOS:Emissions of sulfur dioxide from the Thermal Oxidizer(ID No.NCD-Ql)shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other
substances shall be included when determining compliance with this standard.
Testing[15ANCAC 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 C.3.a above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/IlecordkeepinafReporting[15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of natural gas in the
Thermal Oxidizer(ID No.NCD-Q1).
4. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the membrane coating process(ID No.NS-I)and the outlet of the 4-Stage Scrubber(ro No.
NCD-Q2)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 CA.a,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0521.
Permit No.03735T44
Page 24
MonitoringlRecordkeepina/Reporting[15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from these sources.
5. 15A NCAC 02Q.0317: AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D,0530(g)for major sources and major modifications,the Vinyl
Ethers North process(ID No.NS-B)shall discharge into the atmosphere less than 68.9 tons of VOCs per
consecutive 12-month period.
Testin¢[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.5.a,above,the
Pennittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
Monitorin_-/Recordkeepiny_[15A NCAC 02Q.0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 C.5.a,above,within 30 days of the end of each
calendar month the Permittee shall create and retain production records and estimate associated VOC emissions for
the previous calendar month,as follows:
i. Determine the process vent mass flow rates of non-acid fluoride VOC(Q,,AF)and acid fluoride VOC(QAF)prior
to the control device during the previous calendar month(in lb/month);
ii. Calculate the VOC emissions(Ev)from the process vents during the previous calendar month(in lb/month)
using one of the following equations:
(A) POS:Use the following equation,considering the 99.1 percent removal efficiency of the baffle plate
scrubber(ID Nos.NCD-Hdrl and NCD-Hdr2):
Ev = Q1AF +0.009 x QAF
(B) AOS:Use the following equation,considering the 99.99 percent control efficiency of the Thermal Oxidizer
and 4-Stage Scrubber System(ID Nos.NCD-Ql and NCD-Q2):
Ev =0.0001x (Q"F +QAF)
iii. Record the total solvents used(M)in the affected facility during the previous calendar month(in lb/month);
iv. Record the total solvent waste generation(W)for the affected facility during the previous calendar month(in
lb/month);
v. Calculate the solvent VOC emissions(Es)from the affected facility during the previous calendar month(in
lb/month)using the following equation:
ES = M -- W
vi. Determine the VOC emissions from maintenance emissions(EM)during the previous calendar month(in
lb/month).
vii. Calculate the VOC emissions from fugitive emissions(EF)using accepted practices during the previous
calendar month(in lb/month).
viii. Record VOC emissions from any accidental releases(EA)during the previous calendar month(in lb/month).
ix. Calculate the total process VOC emissions(E)using the following equation(in ton/month):
E = (Ey +ES +EM +EF +EA)l(2,000 lh'tort)
x. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC
emissions(E),as calculated in Section 2.1 C.5.c.ix,above,for the previous consecutive 12 months.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D,0530 if the above records are not created
and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 C.5.c.x,above,exceeds the
limit in Section 2.1 C.5.a of this permit.
d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if the records are not maintained in a logbook on-sine and are not available upon request.
Permit No.03735T44
Page 25
Reporting(15ANCAC 02Q.0508(f)]
e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in
Section 23 C.5.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. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
6. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the IXM
Resins Process(except Fluorinator)and the LXM Resins Process Fluorinator(ID Nos.NS-G-1 and NS-G-2)shall
discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.6.a,above, the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
Monitorin2lRecordkeeping[15A NCAC 02Q.0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 C.6.a,within 30 days of the end of each calendar
month the Permittee shall create and retain production records and estimate associated VOC emissions for the
previous calendar month,as follows:
i. Record the total raw materials fed(M)to the affected facility during the previous calendar month(in kglmonth);
ii. Record the total transformed materials collected(P)for the affected facility during the previous calendar month
(in kg/month);
iii. Record the total untransformed materials collected(W)for the affected facility during the previous calendar
month(in kg/month);
iv. Determine the VOC emissions from the filling of storage tanks(S)for the affected facility during the previous
calendar month(in kg/month);
v. Calculate the VOC emissions(E)from the affected facility during the previous calendar month(in ton/month)
using the following equations:
(A) POS: Calculate VOC emissions:
E = (M—P—W+5) * (2.2 lb'kg)1(2,000 lblton)
(B)AOS:Calculate VOC emissions including the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.
NCD-Q1 and NCD-Q2)control efficiency of 99.99 percent:
E = (1 —0.9999) * (M—P—W+5)*(2.2 lb'kg)/(2,000 lbltor,)
vi. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC
emissions(E),as calculated in Section 2.1 C.6.c.iv,above,for the previous consecutive 12-months,
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are not created
and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 C.6.c.v,above,exceeds the
limit in Section 2.1 C.6.a of this permit.
d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if the records are not maintained in a logbook on-site and are not available upon request.
Reporting [l5A NCAC 02Q.0508(f)]
e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in
Section 2.1 C.6.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. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
Permit No.03735T44
Page 26
7. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the HFPO
process(ID No.NS-A)shall discharge into the atmosphere less than 85.3 tons of VOCs'per consecutive 12-month
period.
Ted[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.7.a,above,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
MonitoringlRecordkeepins[15A NCAC 02Q.0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 C.7.a,above,within 30 days of the end of each
calendar month the Permittee shall create and retain production records and estimate associated VOC emissions for
the previous calendar month,as follows:
i. Record the total raw material HFP consumed(Mu")in the affected facility during the previous calendar month;
ii. Record the average vent flow rate and composition from the AF column(QAc)and Stripper columns(Qsc)
during the previous calendar month;
iii. Determine process VOC emissions(EP,in lb/month)using a combination of ratios of vent rates(QAc and Qsc)
to HFP consumption(MHFP)from the process flowsheet and actual vent data,determine the process VOC
emissions(EF.,in thlmonth)from the AF column(EAc),stripper column(Esc),solvent recycle tank(EsnT),
solvent reclamation converters(EsRc),and routine decontamination of HFP unloading system(EDc)using the
following equation and the control efficiencies specified in the following paragraphs;
HP = EAC + ESC +ESRT +EDC
(A) POS:Using the baffle-plate scrubber(ED No.NCD-Hdrl or NCD-Hdr2)acid fluoride VOC control
efficiency of99.1 percent;and
(B) AOS:Using a thermal oxidizer and 4-stage scrubber(ED Nos.NCD-Q1 and NCD-Q2)total VOC control
efficiency of 99.99 percent.
iv. Calculate the VOC emissions(in lb/month)through the one of the control devices as specified below from
maintenance activity(EM)based on vessel volumes and vapor density for each occurrence of this activity during
the previous calendar month:
(A) POS: the baffle-plate scrubber(ID No.NCD-Hdrl or NCD-Hdr2)using an acid fluoride VOC control
efficiency of 99.1 percent;or
(B) AOS: the thermal oxidizer and 4-stage scrubber(ID Nos.NCD-Q1 and NCD-Q2)using a total VOC
control efficiency of 99.99 percent.
v. Calculate the VOC emissions(in lb/month)from fugitive emissions(EF)using accepted practices during the
previous calendar month.
vi. Record VOC emissions(in lb/month)from any accidental releases(EA)during the previous calendar month.
vii. Calculate the VOC emissions(E)from the affected facility during the previous calendar month(in ton/month)
using the following equation:
E = (Ep +EM +EF +EA)I(7-,000 lbltart)
viii.Calculate the 12-month rolling VOC emissions(in tonlmonth)from the affected facility by summing the
monthly VOC emissions(E),as calculated in 2.1 C.7.c.vii,above,for the previous consecutive 12-months.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the above records are not created
and retained,or if the 12-month rolling VOC emission rate calculated in Section 2.1 C.7.c.viii,above,exceeds the
limit in Section 2.1 C.7.a of this permit.
d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if the records are not maintained in a logbook on-site and are not available upon request.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in
Section 2.1 C.7.c and d,above,postmarked on or before January 30 of each calendar year for the preceding six-
Permit No.03735T44
Page 27
month period between July and December,and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
S. 15A NCAC 02Q.0317:AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the HFPO
Product Container Decontamination Process(ID No.NS-N)shall discharge into the atmosphere less than 40.0 tons
of VOCs per consecutive 12-month period.
Testing[15ANCAC 02Q.0508(f)]
b. If emissions testing is required,the Permittee shall perform•such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.8.a,above,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
MonitorintJRecordkeepin [15A NCAC 02Q.0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 C.8.a,above,within 30 days of the end of each
calendar month the Permittee shall create and retain records and estimate associated VOC emissions for the previous
calendar month,as follows:
i. Create a record of each container received at the facility including:
(A) The date the container was decontaminated;and,
(B) The total mass of VOC released from the container(in lb).
ii. Calculate the VOC emissions from the process during the previous calendar month(in lb/month)by:
(A) Summing the quantity of VOC released from each container decontaminated during the previous calendar
month;and
(B) AOS:Using a total VOC control efficiency of 99.99 percent associated with the thermal oxidizer and 4-
stage scrubber system(ID No.NCD-Q1 and NCD-Q2).
iii. Calculate the VOC emissions from the process during the previous consecutive 12-month period(in tons/i 2-
months)by summing the quantity of VOC released for the previous twelve(12)calendar months.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the abovc records are not created
and retained,or if the 12-month rolling VOC emission rate calculated above exceeds the limit in Section 2.1 C.8.a of
this permit.
d. Required records shall be maintained in a logbook(written or electronic format)on-site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if the records are not maintained in a logbook on-site and are not available upon request.
Reporting[I5A NCAC 02Q.0508(f)]
e. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities specified in
Section 2.1 C.8.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. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period;and.
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
9. 15A NCAC 02D.0530(u): USE OF PROJECTED ACTUAL EMISSIONS TO AVOID APPLICABILITY OF
REQUIREMENTS OF PSD
a. The Permittee has used projected actual emissions to avoid applicability of prevention of significant deterioration
requirements pursuant to application 0900009.15A for the Spray Coating Throughput Increase Project,consisting of
an expansion in the capacity of the spray coating process within the LXM Membrane Coating Process(ID No.NS-I).
In order to verify the assumptions used in the projected actual emissions calculations,the Permittee shall comply
with the requirements in Section 2.1 C.9.b,below.
MonitorinpJRecordkeepine/Reporting[I5ANCAC 02D.0530(u)and 02Q.0308]
b. The Permittee shall perform the following:
Permit No.0373ST44
Page 28
i. Upon commencement of regular operation of the modified unit,the Permittee shall maintain records of annual
VOC emissions from the lJCM Membrane Coating Process(ID No.NS-I)in tons per year,on a calendar year
basis related to the Spray Coating Throughput Increase Project.The Permittee shall calculate these annual
emissions for 10 years following startup of regular operations of the modified unit.
ii. The Permittee shall submit a report to the director within 60 days after the end of each calendar year during
which these records must be generated. The report shall contain the items listed in 40 CFR 51.166(r)(6)(v)(a)
through(c).
iii. The Permittee shall make the information documented and maintained under this condition available to the
Director or the general public pursuant to the requirements in 40 CFR 70.4(b)(3)(viii).
iv, The Permittee shall provide a comparison of the reported actual emissions(post-construction emissions)for
each of the ten calendar years to the projected actual emissions(pre-construction projection)as included below:
Projected Actual Emissions*
Pollutant (tans per year
VOC 67.27
*These projections are not cnton;eable limitations. If projected emissions are exceeded,
consistent with 15A NCAC 02D.0530,the Permittee shall include,in its annual report,un
explanation as to why the actual rates exceeded the projection,
10. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(MACT),
40 CFR 63,Subpart FFFF:NESHAP for Miscellaneous Organic Chemical Manufacturing(MON)
a. For each miscellaneous organic chemical manufacturing process unit,MCPU,(ID Nos.NS-A,NS-B,NS-C,
NS-G-1,and NS-G-2),the Permittee shall comply with all applicable provisions,including the notification,testing,
recordkeeping,and monitoring requirements contained in Environmental Management Commission Standard 15A
NCAC 02D .11 11,"Maximum Achievable Control Technology"as promulgated in 40 CFR 63,Subpart FFFF,
including Subpart A,"General Provisions".
❑perating Standards[15ANCAC 02Q.0508(f)]
b. Opening a safety device,as defined in 40 CFR 63.2550,is allowed at any time conditions require it to avoid unsafe
conditions.[40 CFR 63.2450(p)]
Equipment Identification&Special Designations(40 CFR 63.2480(a),40 CFR 63.10221
c. The Permittee shall identify each pump,compressor,agitator,pressure relief device,sampling connection system,
open-ended valve or line,valve,connector,and instrumentation system in organic HAP service within each MCPU
(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-G-2). Identification of the equipment does not require physical
tagging of the equipment. For example,the equipment may be identified on a plant site plan,in log entries,by
designation of process unit or affected facility boundaries by some form of weatherproof identification,or by other
appropriate methods.
i. The following additional equipment identification requirements also apply:
(A)Connectors need not be individually identified if all affected connectors in a designated area or length of
pipe are identified as a group,and the number of connectors subject is indicated.
(H) Identify pressure relief devices equipped with upstream rupture disks,as described in Section 2.1 C.IO.y,
below;and,
(C) The identity,either by list,location(area or group),or other method,of equipment in organic HAP service
less than 300 hours per calendar year.
ii. The Permittee shall identify unsafe-to-monitor valves,pumps,connectors or agitators.Unsafe-to-monitor
valves,pumps,connectors or agitators are equipment for which the Permittee has determined that monitoring
personnel would be exposed to an immediate danger as a consequence of complying with the monitoring
requirements for valves,pumps,connectors or agitators in this section.The Permittee shall provide an
explanation why the equipment is unsafe-to-monitor and record the planned schedule for monitoring this
equipment.
iii. The Permittee shall identify difficult-to-monitor valves or agitators.Difficult-to-monitor valves or agitators are
those that cannot he monitored without elevating the monitoring personnel more than 7 feet above a support
surface or is not accessible in a safe manner when it is in organic HAP service.The Permittee shall provide an
explanation why the equipment is difficult-to-monitor,and record the planned schedule for monitoring this
equipment.
Permit No.03735T44
Page 29
iv. The Permittee shall identify unsafe-to-repair connectors.Unsafe-to-repair connectors are those that cannot be
repaired if the Permittee determines that repair personnel would be exposed to an immediate danger as a
consequence of complying with the repair requirements in Section 2.1 C.1 O.bb through C.IO.dd,below,and if
the connector will be repaired before the end of the next process MCPU shutdown.The Permittee shall keep a
record of the explanation why the connector is unsafe-to-repair.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if affected equipment is not identified
as required above.
d. If the Permittee designates equipment as unsafe-to-monitor or difficult to monitor,the Permittee shall create written
plans as specified below.The Permittee shall retain the written plans on-site,and make them available to NC DAQ
for review upon request. [40 CFR 63.1022(c)(4)]
i. Unsafe-to-monitor.The Permittee shall create and implement a written plan that requires monitoring of the
equipment as frequently as practical during safe-to-monitor times,but not more frequently than the periodic
monitoring schedule otherwise applicable,and repair procedures that are consistent with the requirements of
this permit.
ii. Difficult-to-monitor.The Permittee shall create and implement a written plan that requires monitoring of the
equipment at least once per calendar year and repair procedures that are consistent with the requirements of this
permit.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the required plans are not created,
implemented,and retained.
Equipment Leak Standards&Inspections [40 CFR 63.2480(a),40 CFR 63, Subpart UU]
Standards for Valves in Light Li uid Gas and Vapor Service[40 CFR 63.10251
e. The instrument reading that defines a leaking valve is 500 ppm or greater.
f. Instrument inspection. The Permittee shall monitor valves in each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,
and NS-G-2)for leaks using the instrument monitoring methods described in 40 CFR 63.1023(b)and(c)at the
frequency specified below:
i. If at least the greater of 2 valves or 2%of the valves in a process unit leak,as calculated according to Section
2.1 C.10.g,below,the Permittee shall monitor each valve once per month.
ii. At each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-G-2)with less than the greater of 2 leaking
valves or 2 percent leaking valves,monitor each valve once each calendar quarter,except as provided in iii.,iv.,
or,v.below.
iii. At each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-G-2)with less than 1 percent leaking valves,
the Permittee may elect to monitor each valve once every two quarters.
iv. At each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-G-2)with less than 0.5 percent leaking valves,
the Permittee may elect to monitor each valve once every four quarters.
v. At each MCPU(m Nos.NS-A.NS-B,NS-C,NS-G-1,and NS-G-2)with less than 0.25 percent leaking valves,
the Permittee may elect to monitor each valve once every 2 years.
The Permittee may choose to subdivide the valves in the MCPUs(m Nos.NS-A,NS-B,NS-C,and NS-G-1,and
NS-G-2)or groups of process units and apply the provisions above to each subgroup. If the Permittee elects to
subdivide the valves,it shall comply with the provisions of 40 CFR 63.1025(b)(4). The Permittee shall be deemed
in noncompliance with 15A NCAC 02D.1111 if it does not meet the instrument inspection requirements listed
above.
g. The percentage of leaking valves,used to determine the required monitoring frequency in Section 2.1 C.10.f,above,
shall be calculated according to the procedures in 40 CFR 63.1025(c).The Permittee shall be deemed in
noncompliance with 15A NCAC 02D.1111 if the percentage of leaking valves is not calculated as required[40
CFR 63.1025(c)]
h. The Permttee shall create and retain a record of the monitoring schedule for each process unit.The Penni ttee shall
be deemed in noncompliance with 15A NCAC 02D.1111 if it does not keep this record.[40 CFR 63. 1025(b)(3)(vi),
40 CFR 63. I038(c)(1)(i)]
i. if a leak is identified:
i. It shall be repaired as provided in the repair provisions of Section 2.1 C.1 O,bb through C.10.dd.
Permit No.03735T44
Page 30
ii. After a leak has been repaired, the valve shall be monitored at least once within the first 3 months after its
repair. This requirement is in addition to the monitoring required to satisfy the definition of repaired and first
attempt at repair. The required periodic monitoring in Section 2.1 C.101 above,may be used if it satisfies the
tinting requirement of this condition. If a leak is detected by this follow-up monitoring,follow the provisions below
to determine whether that valve must be counted as a leaking valve:
(A) If the periodic monitoring was used to satisfy the follow-up monitoring requirement,then the valve shall be
counted as a leaking valve.
(B) If other monitoring is used satisfy the follow-up monitoring requirements,then the valve shall be counted
as a leaking valve unless it is repaired and shown by periodic monitoring not to be leaking.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not meet the requirements
listed above.
j. Unsafe-to-monitor valves.Any valve that is designated unsafe-to-monitor according to Section 2.1 C.IO.c,above,is
exempt from the monitoring and repair requirements specified in Section 2.1 C.1OXand C.IO.i,above,and the
Permittee shall monitor the valve according to the written plan in Section 2.1 C.1 O.d. The Permittee shall be deemed
in noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements.
k. Difficult-to-monitor valves. Any valve that is designated as difficult-to-monitor according to Section 2.1 C.IO.c,
above,is exempt from the monitoring requirements of Section 2.1 C.1O.f and C.1 OJ,above,and the Permittee shall
monitor the valve according to the written plan in Section 2.1 C.I OA The Permittee shall be deemed in
noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements.
Standards for Pumps in Light Liquid Service[40 CFR 63.10261
1. The instrument reading that defines a leaking pump is 1,000 ppm or greater. Repair is not required unless an
instrument reading of 2,000 ppm or greater is detected. [40 CFR 63.1026(b)(2)(W)and(b)(3)]
m. Visual inspection. Each pump within the MCPUs(ID Nos.NS-A,NS-B,NS-C,NS-t:.-1,and NS-t:.-2)shall be
checked by visual inspection each calendar week for indications of liquids dripping from the pump seal. The visual
inspection shall be consistent with the methods described in 40 CFR 63.1023(d). The Permittee shall document that
the inspection was conducted and the date of the inspection. If there are indications of liquids dripping from the
pump seal at the time of the weekly inspection,follow either of the following procedures:
i. Conduct instrument monitoring of the pump using the methods described in 40 CFR 63.1023(b)and(c).If the
instrument reading is 1,000 ppm or greater,a leak is indicated and the Permittee shall repair the leak as
provided in Section 2.1 C.IO.bb through C.IO.dd,below,unless the reading is less than 2,000 ppm;or
ii. Eliminate the visual indications of liquids dripping.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.l 1 I I if it does not monitor and repair
pumps as listed above. [40 CFR 63.1026(b)(4), 40 CFR 63.1038(c)(2)(i)]
n, Instrument inspection. The Permittee shall monitor affected pumps once per calendar month using the instrument
monitoring methods described in 40 CFR 63.1023(b)and(c). Leaks shall he repaired as provided in Section 2.1
C.1O.bb. through C.IO.dd,below.The Permittee shall calculate the percent leaking pumps using the procedures
specified in 40 CFR 63.1026(c).
i. If,when calculated on a 6-month rolling average,at least the greater of either 10 percent of the pumps in a
MCPU or three pumps in a MCPU leaf the Permitter,shall implement a quality improvement program for
pumps that meets the requirements in 40 CFR 63.1035.
ii. The number of pumps at a.MCPU shall be the sum of all the pumps in organic HAP service,except that pumps
found leaking in a continuous process unit within one month after startup of the pump shall not count in the
percent leaking pumps calculation for that one monitoring period only.
iii. The Permittee shall comply with the quality improvement plan until the number of leaking pumps is less than
the greater of either 10 percent of the pumps or three pumps,calculated on a 6-month rolling average.
f40 CFR 63.102 6(b)(1), (c)and(d)j
The Permittee shall he deemed in noncompliance with 15A NCAC 02D.I I I I if it does not monitor and repair
pumps as required above.
Permit No.03735T44
Page 31
o. Unsafe-to-monitor pumps. Any pump that is designated as unsafe-to-monitor according to Section 2.1 C.10.c,above,
is exempt from the inspection requirements provided in Section 2.1 C.10.m and C.10.n,above,and the Permittee
shall monitor and inspect the pump in accordance with the written plan in Section 2.1 C.10.d. The Permittee shall
be deemed in noncompliance with 15A NCAC 0213.1111 if it does not meet these requirements,[40 CFR
63.1026(e)(6)]
Standards for Connectors in Gas and Vapor and Light Liquid Service[40 CFR 63.2480(b)(4),63.1029]
p. The Permittee shall comply with the requirements of 40 CFR 63.1027 for connectors in gas/vapor and light liquid
service.The Permittee may elect to comply with the requirements in Section 2.1 C.10.q through C.10.t,below,for
connectors in heavy liquid service. [40 CFR 63.2480(h)(4)]
q. The Permittee shall monitor connectors in each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-C-2)within
5 calendar days for leaks using the instrument monitoring methods described in 40 CFR 63.1023(b)and(c),as
applicable,if evidence of a potential leak to the atmosphere is found by visual,audible,olfactory,or any other
detection method,unless the potential leak is repaired according to Section 2.1 C.10.s,below.[40 CFR
63.1029(b)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.l 11 l if it does not monitor the connectors
as required above.
r, If an instrument reading of 500 parts per mullion or greater is measured as required in Section 2.1 C.l0.q,above,a
leak is detected.The Permittee shall repair the leak according to Section 2.1 C.IO.bb through C.10.dd,below.NCAC
02DI40 CER 63.1029(b)(2)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the leak is not repaired as required.
s. For equipment identified in Section 2.1 C.IO.q,above,that is not monitored by the method specified in 40 CFR
63.1023(b)and(c),as applicable,a leak is considered repaired one of the following conditions is met[40 CFR
63.1029(c)]:
i. the visual,audible,olfactory,or other indication of a leak to the atmosphere has been eliminated;or
ii. no bubbles are observed at potential leak sites during a leak check using soap solution;or
iu. the system will hold a test pressure.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if leaks are not repaired as required
above.
t. The following are special provisions for connectors:
i. Unsafe-to-repair connectors.Any connector that is designated as unsafe-to-repair as described in Section 2.1
C.1O.c,above,is exempt from the repair requirements in Section 2.1 C.10.bb,below.The Permittee shall
monitor these connectors according to the written plan as specified in Section 2.1 C.1O.d,above.
u. Inaccessible, ceramic, or ceramic-lined connectors. Any connector that is inaccessible or that is ceramic-lined
(e.g.,porcelain,glass,or glass-lined)is exempt from the monitoring requirements specified in 40 CFR
63.1023(b)and(c);From the leak repair requirements of Section 2.1 C.10.bb,below;from the recordkeeping
and reporting requirements in this section.
(A) An inaccessible connector is one of the following:[40 CFR 63.1027(e)]
(1) Buried;
(2) Insulated in a manner that prevents access to the connector by a monitor probe;
(3) Obstructed by equipment or piping that prevents access to the connector by a monitor probe;
(4) Unable to be reached from a whecled scissor-lift or hydraulic-type scaffold that would allow access to
connectors up to 7.6 meters(25 feet)above the ground.
(5) Inaccessible because it would require elevating the monitoring personnel more than 2 meters(7 feet)
above a permanent support surface or would require the erection of scaffold;
(6) Not able to be accessed at any time in a safe manner to perform monitoring.Unsafe access includes,
but is not limited to,the use of a wheeled scissor-lift on unstable or uneven terrain,the use of a
motorized man-lift basket in areas where an ignition potential exists,or access would require near
proximity to hazards such as electrical lines,or would risk damage to equipment.
Permit No.03735T44
Page 32
(B) If any inaccessible,ceramic or ceramic-lined connector is observed by visual,audible,olfactory,or other
means to be leaking,the visual,audible,olfactory,or other indications of a leak to the atmosphere shall be
eliminated as soon as practical.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the special provisions for
connectors are not Followed as described above.
Standards for Agitators in Gas and Vapor and Light Liquid Service 140 CFR 63.10281
u. The instrument reading that defines a leaking agitator is 10,000 ppm or greater.
v. The Permittee shall conduct visual and instrument inspections as provided below[40 CFR 63.1028, 40 CFR
63.1038(c)(4)(i)]:
i. Visual inspection. Each agitator within each MCPU(ID Nos.NS-A,NS-B,NS-C,NS-G-1,and NS-G-2)shall
be checked by visual inspection each calendar week for indications of liquids dripping from the agitator seal.
The Permittee shall document that the inspection was conducted and the date of the inspection. If are
indications of liquids dripping from the agitator seal at the time of the weekly inspection, the Permittee shall
follow one of the following procedures:[40 CFR 63.1028(c)(3)]
(A) The Permittee shall conduct instrument monitoring of the agitator seal using the methods described in 40
CFR 63.1023(b)and(c).If the instrument reading indicates a leak(i.e.,the reading is 10,000 ppm or
greater),it shall be repaired as provided in the repair provisions of Section 2.1 C.10.bb through C.10.dd,
below;or
(B) The Permittee shall eliminate the visual indications of liquids dripping.
(C) The Permittee shall document each visual agitator inspection.
ii. Instrument inspection. The Pennittee shall monitor each affected agitator within each MCPU(ID Nos.NS-A,
NS-B,NS-C,NS-G-1,and NS-G2)once per calendar month using the instrument monitoring methods
described in 40 CFR 63.1023(b)and(c). Leaks shall be repaired as provided in the repair provisions of Section
2.1 C.10.bb through C.10.dd,below.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I I I I if it does not monitor and repair
agitators as required above.
w. Special provisions for agitators.If the Permittee designates agitator seals as either unsafe-to-monitor or difficult-to-
monitor,the permittee shall comply with the following:
i. Unsafe-to-monitor agitator seals.Any agitator seal that is designated as unsafe-to-monitor according to Section
2.1 C.10.c,above,is exempt from the monitoring and repair requirements in Section 2.1 C.10.v,above.The
Permittee shall monitor the unsafe-to-monitor agitator according to the written plan,as required in Section 2.1
C.IU.d,above.
ii. Difficult-to-monitor agitator seals. Any agitator seal that is designated as difficult-to-monitor according to
Section 2.1 C.10.c,above,is exempt from the monitoring requirements of Section 2.1 C.IO.v,above,and the
Permittee shall monitor the agitator seal according to the written plan as required in Section 2.1 C.10.d,above.
The Pennittee shall be deemed in noncompliance with 15A NCAC 02D.I I I t if it does not meet these requirements
Standards for Pressure Relief Valves[40 CFR 63.1030]
x. The instrument reading that defines a leaking pressure relief valve is 500 ppm or greater. This standard does not
apply during pressure releases as provided in Section 2.1 C.10.y,below. After each pressure release,the pressure
relief device shall be returned to a condition indicated by an instrument reading of less than 500 parts per million,as
soon as practical,but no later than 5 calendar days after each pressure release.
y. Instrument inspection. The pressure relief device shall be monitored as follows:
i. The Permittee shall monitor no later than five calendar days after each pressure release to confirm the condition
indicated by an instrument reading of less than 500 parts per million above background using the instrument
monitoring methods described in 40 CFR 63.1023(b)and(c).
ii. Record the dates and results of the monitoring following a pressure release including the background level
measured and the maximum instrument reading measured.
iii. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is exempt
from the requirements of Section 2.1 C.IO.x and C.IO.y,provided the Permittee installs a replacement rupture
Permit No.03735T44
Page 33
disk upstream of the pressure relief device as soon as practical after each pressure release but no later than 5
calendar days after each pressure release,except as allowed under the delay of repair provisions in Section 2.1
C.IO.cc,below.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if it does not monitor and maintain
pressure relief valves as required above.[40 CFR 63.1038(c)(5)]
Equipment Leak Identification[40 CFR 63.2480(a)]
x. When a leak is detected using either sensory or instrument monitoring methods,a weatherproof and readily visible
identification shall be attached to the leaking equipment. The Permittee shall be deemed in noncompliance with
15A NCAC 02D.1111 if each detected leak is not identified as provided above. [40 CFR 63.1023(e)(1)]
aa. Leak identifications that are placed on leaking equipment may he removed as follows:
i. Leak identification on a valve in gas/vapor or light liquid service may be removed after it has been re-monitored
as required in Section C.1OJ,above,and no leak has been detected during that monitoring.
ii. Leak identification on pumps,agitators,connectors(complying with Section 2.1 C.10.q,above)and pressure
relief valves may be removed after it is repaired.
[40 CFR 63.1024(c)]
Equipment Leak Repair[40 CFR 63.2480(a),40 CFR 63,Subpart UU]
bb. The Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days after it is
detected,except where"Delay of Repair"or"Unsafe to Repair"provisions apply. A First attempt at repair shall be
made no later than 5 calendar days after the leak is detected. [40 CFR 63.1024]
i. First attempt at repair for pumps includes,but is not limited to,tightening the packing gland nuts and/or
ensuring that the seal flush is operating at design pressure and temperature.
I First attempt at repair for valves includes,but is not limited to,tightening the bonnet bolts,and/or replacing the
bonnet bolts,and/or tightening the packing gland nuts,and/or injecting lubricant into the lubricated packing.
cc. Delay of repair. Delay of repair is allowed for any of the conditions listed below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and,where appropriate,why the repair was technically infeasible
without a process unit shutdown.
i. Delay of repair is allowed if repair within 15 days after a leak is detected is teehnically infeasible without a
process unit or affected facility shutdown. Repair of this equipment shall occur as soon as practical,but no later
than the end of the next process unit or affected facility shutdown,except as provided in Section 2.1 C.10.cc.v,
below.
ii. Delay of repair is allowed for equipment that is isolated from the process and that does not remain in regulated
material service.
iii. Delay of repair for valves,connectors,and agitators is also allowed where:
(A) The Permittee determines that emissions of purged material resulting from immediate repair would be
greater than the fugitive emissions likely to result from delay of repair,and
(B) When repair procedures are affected,the purged material is collected and destroyed,collected and routed to
a fuel gas system or process,or recovered in a control device.
iv. Delay of repair for pumps is also allowed where:
(A) Repair requires replacing the existing seal design with a new system that the Permittee has determined
through a Quality Improvement Plan will provide better performance or one of the following:
(1) A dual mechanical seal system will be installed;
(2) A pump that meets the requirements of 40 CFR 63.1026(e)(2)will be installed;or
(3) A system that routes emissions to a process or a fuel gas system or a closed vent system and control
device will be installed;and
(B) Repair is completed as soon as practical,but not later than 6 months after the leak was detected.
v. Delay of repair beyond a process unit or affected facility shutdown will be allowed for a valve if valve assembly
replacement is necessary during the process unit or affected facility shutdown,and valve assembly supplies
have been depleted,and valve assembly supplies had been sufficiently stocked before the supplies were
depleted. Delay of repair beyond the second process unit or afTected facility shutdown will not be allowed
unless the third process unit or affected facility shutdown occurs sooner than 6 months after the fast process
unit or affected facility shutdown.
dd. [reserved]
Permit No.03735T44
Page 34
Egui rnent Leak Recordkeeping[40 CFR 63.2480(a),40 CFR 53,Subpart UU]
ee. For each leak detected,the following information shall be recorded and maintained:
i. The date of first attempt to repair the leak.
ii. The date of successful repair of the leak.
iii. Maximum instrument reading measured by Method 21 of 40 CFR Part 50,Appendix A at the time the leak is
successfully repaired or determined to he non-repairable.
iv. "Repair delayed"and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of
the leak as specified below:
(A) The Permittee may develop a written procedure that identifies the conditions that justify a delay of repair.
In such cases,reasons for delay of repair may be documented by citing the relevant sections of the written
procedure.
(B) If delay of repair was caused by depletion of stocked parts,there must be documentation that the spare parts
were sufficiently stocked on-site before depletion and the reason for depletion.
v. Dates of process unit or affected facility shutdowns that occur while the equipment is unrepaired.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the records listed above are not
created and retained. [40 CFR 63.1023(e)(2), 40 CFR 63.1024(f),40 CFR 63. 1038(b)]
ff. The Permittee shall create and retain the following general records:
L General and specific equipment identification if the equipment is not physically tagged and the Permittee is
electing to identify the affected equipment through written documentation such as a log or other designation;
ii. Written plans for any equipment that is designated as unsafe-or difficult-to-monitor;and,
iii. A record of the identity and justification of any equipment that is designated as unsafe-to-repair.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the records listed above are not
created and retained. [40 CFR 63. 1038(b)]
Heat Exchanger Requirements[15A NCAC 02Q.0508(f)]
gg. The Permittee shall prepare and implement a monitoring plan that documents the procedures that will be used to
detect leaks of process fluids into cooling water.
i. The plan shall require monitoring of one or more surrogate indicators(e.g.,pH,conductivity,etc.)or
monitoring of one or more process parameters or other conditions that indicate a leak. The plan shall include
the following:
(A) A description of the parameter or condition to be monitored and an explanation of how the selected
parameter or condition will reliably indicate the presence of a leak;
(B) The parameter level(s)or conditions(s)that shall constitute a leak This shall be documented by data or
calculations showing that the selected levels or conditions will reliably identify leaks. The monitoring must
be sufficiently sensitive to determine the range of parameter levels or conditions when the system is not
leaking. When the selected parameter level or condition is outside that range,a leak is indicated;
(C) The monitoring frequency which shall be no less frequent than monthly for the first 5 months and quarterly
thereafter to detect leaks;
(D) The records that will be maintained to document compliance with the requirements of the monitoring plan.
ii. If a substantial leak is identified by methods other than those described in the monitoring plan and the
method(s)specified in the plan could not detect the leak,the Permittee shall revise the plan and document the
basis for the changes no later than 180 days after discovery of the leak_
iii. The Permittee shall maintain a copy of the current monitoring plan on-site or other means that provides access
within two hours after a request. If the monitoring plan is superseded,the Permittee shall retain the most recent
superseded plan at least until 5 years from the date of its creation.The Permittee shall retain the superseded plan
on-site for accessible from a central location by computer or other means that provides access within two hours
after a request)for at least 6 months after its creation.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if it does not meet the above
requirements. [40 CFR 63.2490, 40 CFR 63.104(c)]
hh. Except as allowed by the delay of repair requirements in Section 2.1 C.IO.ii,below,if a leak is detected in any heat
exchanger system,the Permittee shall be repair the leak as soon as practical but not later than 45 calendar days after
the Permittee receives results of monitoring tests indicating a leak,unless the Permittee demonstrates that the results
are due to a condition other than a leak. Once the leak has been repaired,the owner or operator shall confirm that
the heat exchange system has been repaired within 7 calendar days of the repair or startup,whichever is later. The
Permit No.03735T44
Page 35
Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if leaks are not repaired as required above.
140 CFR 63,2490, 40 CFR 63,104(d)]
ii. Delay of repair of heat exchange systems is allowed if the equipment is isolated from the process. Delay of repair is
also allowed if repair is technically infeasible without a shutdown and any one of the conditions listed in 40 CFR
63.104(e)(1)through(e)(2)is met. [40 CFR 63,2490, 40 CFR 63.104(e)]The Pemoittee shall be deemed in
noncompliance with 15A NCAC 02D.1111 if the delay of repair provisions are not met.
J. For each affected heat exchanger system, the Permittee shall retain the following records:
i. Monitoring data indicating a leak,the date when the leak was detected,and if demonstrated not to be a leak,the
basis for that determination;
ii. Records of any leaks detected by procedures other than those provided in the written plan according to Section
2.1 C.IO,gg,above,including the date the leak was discovered;
iii. The dates of efforts to repair leaks;and,
iv. The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permitree shall be deemed in noncompliance with 15A NCAC 02D.111 i if the records listed above are not
retained. [40 CFR 63.2490, 40 CFR 63.10401
Additional Recordkee in [15A NCAC 02Q.0508(f)]
kk. The Permittee shall create and retain the following records on each affected MCPU:[40 CFR 63.2525(b)]
i. A description of the process and the type of process equipment used;
ii. An identification of related process vents(including associated emissions episodes),wastewater points of
determination(PODs),and storage tanks;
iii. The applicable control requirements pursuant to 40 CFR 63,Subpart FFFF,including the level of required
control,and for vents,the level of control for each vent;
iv. The control device or treatment process used,as applicable,including a description of operating and/or testing
conditions for any associated control device;
v. The process vents,wastewater POD,and storage tanks(including those from other processes)that are
simultaneously routed to the control device or treatment process;
vi. The applicable monitoring requirements of this subpart and any parametric level that assures compliance for all
emissions routed to the control device or treatment process;and,
vii. Calculations and engineering analyses required to demonstrate compliance.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the above records are not retained.
11. Create and retain a record of each time a safety device is opened to avoid unsafe conditions. [40 CFR 63.2525{fJ]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if this record is not retained.
mm. For each affected Group 2 wastewater stream,the Permittee shall retain the following records:[Table 7 of 40 CFR
Part 63,Subpart F and 40 CFR 63.147(b)(8)]
i, MCPU identification and description;
ii. Stream identification code;
iii. Concentration of compounds listed in Table 8 and Table 9 of 40 CFR 63,Subpart FFFF(in ppmw),including
documentation of the methodology used to determine concentration;and,
iv. Stream flow rate(in Umin),
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the records listed above are not
retained. [40 CFR 63.2585(a), 40 CFR 63.147(b)(8)]
Process Changes [15ANCAC 02Q.0508(f)] .
nn. If a Group 2 emission point becomes a Group 1 emission point,the Permittee must be in compliance with the Group
1 requirements beginning on the date the switch occurs.An initial compliance demonstration as specified in 40 CFR
Part 63, Subpart FFFF must be conducted within 150 days after the switch occurs. The Permittee shall he deemed in
noncompliance with 15A NCAC 02D.1111 if it does not meet these requirements. [40 CFR 63.2445(d)]
Permit No,03735T44
Page 36
Relaorrmig[15A NCAC 02Q.0508(f)]
oo. The Permittee shall submit a semi-annual compliance report of monitoring and recordkeeping activities postmarked
on or before January 30 of each calendar year for the preceding six-month period between July and December,and
July 30 of each calendar year for the preceding six-month period between January and June. The report shall
contain the following:f40 CFR 63.2520(a), (6)and(e)]
i. Company name and address;
ii. Statement by a responsible official with that official's name,title,and signature,certifying the accuracy of the
content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no periods of noncompliance from any emission limit,operating limit or work practice standard
specified in Section 2.1 C.10,include a statement that there were no periods of noncompliance from the
emission limits,operating limits,or work practice standards during the reporting period;
v. For each period of noncompliance from an emission limit,operating limit,and work practice standard,include
the following information:
(A) The total operating time of the affected source during the reporting period;and,
(B) Information on the numher,duration,and cause of noncompliance(including unknown cause,if
applicable),as applicable,and the corrective action taken.
vi. Identify each new operating scenario which has been operated since the time period covered by the last
compliance report and has not been submitted in the previous compliance report. For each new operating
scenario,the Permittee shall provide verification that the operating conditions for any associated control or
treatment device have not been exceeded and that any required calculations and engineering analyses have been
performed.A revised operating scenario for an existing process is considered to be a new operating scenario;
vii. For the equipment listed below,report in a summary format by equipment type,the number of components for
which leaks were detected and for valves,pumps and connectors show the percent leakers,and the total number
of components monitored. Also include the number of leaking components that were not repaired as required
according to Section 2.1 C.l0.bb through C.10.dd,above,and for valves and connectors,identify the number of
components that are determined to be non-repairable as described in 40 CFR 63.1025(c)(3).
(A) Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service;and,
(D) Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized,report that delay of repair has occurred and report the number of
instances of delay of repair under Section 2.1 C.10.cc,above.
ix. For pressure relief devices,report the results of all leak monitoring to show compliance conducted within the
semiannual reporting period.
x. Report,if applicable,the initiation of a monthly leak monitoring program for valves and pumps.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair,include the
following information:[40 CFR 63.2490 and 65.104(0(2)]
(A) the presence of the leak and the date that the leak was detected
(B) whether or not the leak has been repaired
(C) the reason(s)for delay of repair and any supporting emission estimates.
(D) If the leak is repaired,the owner or operator shall report the date the leak was successfully repaired.
(E) If the leak remains unrepaired,the expected date of repair.
ALTERNATIVE OPERATING SCENARIO
State-Onl) Requirement
11. 15A NCAC 02Q.0519(a)('7)and CONSENT ORDER
a. To carry out the purposes of N.C.G.S. §143 Article 2113 and to ensure that air emissions do not contribute to
groundwater violations,and pursuant to the Consent Order,'the Permittee shall reduce emissions of all PFAS,
including GenX Compounds,from the following sources:HFPO Process,Vinyl Ethers North Process,Vinyl Ethers
South Process,RSU Process,FPS Liquid Waste Stabilization Process,MMF Process,E-2 Process,TFEICO2
Separation Process,HFPO Product Container Decontamination Process,VEN Product Decontamination Process,
`"Consent Order"means the Consent Order entered on February 25,2019,in State of North Carolina,ex rel.,Michael S.Regan,Secretary,North Carolina
Department of Enviramuental Quality v.The Chemours Company FC,LLC,17 CVS 580(Bladen County).
Permit No.03735T44
Page 37
and VIES Product Container Decontamination Process(ID Nos.NS-A,NS-S,NS-C,NS-D,NS-E,NS-F,NS-G-1,
NS-K,NS-M,NS-N,NS-O,and NS-P)as follows:
i. No later than December 31,2019,the Permitter shall install and begin normal operation of a Thermal Oxidizer
in series with a 4-Stage Scrubber System(ID Nos.NCD-Ql and NCD-Q2).
ii. The Thermal Oxidizer and 4-Stage Scrubber System shall reduce emissions of all PFAS,including GenX
Compounds,by at least 99.99 percent.
Test[15ANCAC 02Q.0508(f)]
b. The Permittee shall conduct an initial performance test of the Thermal Oxidizer and 4-Stage Scruhher System(ID
Nos.NCD-Ql and NCD-Q2).The Permitter shall test for all PFAS emissions,including GenX Compounds,at the
inlet Thermal Oxidizer and the outlet of the 4-Stage Scrubber.The Permittee shall install sampling ports in
compliance with 15A NCAC 02D.2600.Emissions testing shall be performed in accordance with General
Condition JJ and in accordance with a testing protocol approved by NC DAQ.The Permitter shall submit the testing
protocol for approval at least 45 days prior to conducting the performance test.The testing protocol shall address
how the Permitter will ensure that the Thermal Oxidizer and 4-Stage Scrubber System will achieve the emission
reduction specified in Section 2.1 C.I La,above,including the use of a surrogate for all PFAS,such as
hexafluoropropylene oxide(HFPO).
c. Within 90 days of installation of the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-Ql and NCD-
Q2),the Permitter shall submit a report demonstrating initial compliance with the limits specified in Section 2.1
C.1 La,above,using the results of the initial performance test conducted as specified in Section 2.1 C.1 Lb,above.
The report shall specify the emissions measured at the inlet of the Thermal Oxidizer and the outlet of the 4-Stage
Scrubber.
d. After the initial performance test is conducted,the Permittee shall conduct periodic performance tests to demonstrate
compliance with the emission limits in Section 2.1 C.1 La,above,as follows:
i. The Permitter shall conduct the periodic performance tests using the procedures specified in Section 2..1 C.1 Lb
and C.l Lc,above.
ii. The Permitter shall conduct periodic performance tests on an annual basis.After the initial performance test
conducted as specified in Section 2.1 C.1 Lb,above,the Permitter shall conduct all periodic performance tests
within a 13-month time period after the date of the previous performance test.
iii. The Permitter,shall conduct a performance test within 90 days whenever permanent changes are made in
production capacity,process feedstock type,or whenever there is a replacement,removal,or addition of an
emission source or control device.Following this performance test,the Permittee shall resume annual
performance testing in accordance with the schedule specified in paragraph d.ii,above.
e. During performance tests conducted according to Section 2.1 C.1 Lb,above,the Permitter shall establish or confirm
the operating parameters specified in Section 2.1 C.1 l.h and C.1 Li,below.if the results of any performance test
require changes to the operating parameters specified in Section 2.1.C.1 Lh and i,below,to demonstrate compliance
with the limits in Section 2.1 C.1 La,above,the Permitter shall submit a permit application for a minor modification
to the permit under 15A NCAC 02Q.0515 to revise these parameters.Any previously established continuous
compliance monitoring parameters shall not apply during any required subsequent performance testing.
Monitoring[15ANCAC 02Q.0508(f)]
f. Emissions of all PFAS,including GenX Compounds,from the HFPO Process,VEN Process,VIES Process,RSU
Process,Liquid Waste Stabilization Process,MMF Process,E-2 Process,TFEICO2 Separation Process,HFPO
Product Container Decontamination Process,VEN Product Decontamination Process,and VES Product Container
Decontamination Process(ID Nos.NS-A,NS-S,NS-C,NS-D,NS-E,NS-F,NS-G-1,NS-K,NS-M,NS-N,NS-O,
and NS-P)shall be controlled by a Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-Ql and NCD-
Q2). To ensure compliance,the Permitter 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.hall include:
i. hourly visual or positive detection by flame scanner checks of the Thermal Oxidizer flame and burner while in
operation and annual inspections of the burner assemblies,blowers,fans,dampers,refractory lining,oxidizer
shell,Fuel lines,and ductwork;
ii. annual inspection of scrubber spray nozzles to detect clogging or corrosion damage of nozzles and perform
maintenance and repair when necessary to ensure proper operation of the scrubber;
Permit No.03735T44
Page 38
iii. annual inspection of scrubber packing material to ensure proper packing depth and to check for clogging;and
iv. annual inspection,cleaning,and calibration of all associated instrumentation.
v. In addition to annual inspections,the Permittee shall also conduct the inspections required in paragraphs i.
through iv.,above,whenever the processes routed to the control devices andlor the Thermal Oxidizer or the 4-
Stage Scrubber System are nonoperational for a minimum of 72 hours.
g. The Permittee shall develop,and submit to NC DAQ for approval,a site-specific monitoring plan that addresses
design,data collection,and quality assurance/quality control elements for operating each CMS installed according to
Section 2.1 C.1 Lh and C:l Li,below.The monitoring plan shall,at a minimum,address the following:
i. Initial and any subsequent calibration of the CMS;
ii. Determination and adjustment of the calibration drift of the CMS;
iii. Preventive maintenance of the CMS,including spare parts inventory;
iv. Data recording,calculations,and reporting;
v. Accuracy audit procedures,including sampling and analysis methods;
vi. Program of corrective action for a malfunctioning CMS;
vii. Ongoing operation and maintenance procedures;and
viii.Ongoing data quality assurance procedures.
h. The Permittee shall install,calibrate,maintain,and operate CMS for the Thermal Oxidizer(ID No.NCD-Ql).The
CMS shall include a continuous recorder capable of taking a measurement at least once every 15 minutes.The
Permittee shall operate the CMS according to the approved site-specific monitoring plan specified in Section 2.1
C.1 Lg,shove,to ensure the following operational parameters are maintained.
i. A minimum combustion chamber temperature of 1800 degrees Fahrenheit(3-hour rolling average).
(A) The temperature monitor shall record continuously the operating temperature to within 1 percent(relative
to degrees Celsius)or+0.50C(±0.90F),whichever is greater.
(B) The temperature monitoring device shall be installed in the firebox of the Thermal Oxidizer or in the
ductwork downstream from the firebox and hefore any substantial heat exchange for the Thermal Oxidizer.
ii. A maximum Thermal Oxidizer inlet gas feed rate 2,200 pounds per hour(3-hour rolling average).The
monitoring device used for continuous measurement of the Thermal Oxidizer inlet gas feed rate must be
certified by the manufacturer to be accurate within±5 percent of the Thermal Oxidizer inlet gas feed rate.
iii. Failure to operate the temperature monitor or inlet feed gas monitoring device identified, above,for at least
97 percent of the total operational time per quarterly reporting period shall constitute noncompliance with the
emission limits in Section 2.1 C.1 La,above.
i. The Permittee shall install,calibrate,maintain,and operate CMS for the 4-Stage Scrubber System(ID No.
NCD-Q2).The CMS shall include a continuous recorder capable of taking a measurement at least once every
15 minutes.The Permittee shall operate the CMS according to the approved site-specific monitoring plan specified
in Section 2.1 C.1 l.g,above,to ensure the following operational parameters are maintained.
i. The scrubber liquor flow shall be a minimum of 40 gallons per minute for the fourth caustic scrubber stage.The
monitoring device used for continuous measurement of the scrubber liquor flow rate must be certified by the
manufacturer to be accurate within f5 percent of the scrubber liquid flow rate.
ii. A minimum scrubber liquor pH,no less than 7.1 (3-hour rolling average)for the fourth scrubber stage.
iii. Failure to operate the scrubber liquor flow meter or pH meter,identified in i.and ii.,above,for at least 97
percent of the total operational time per quarterly reporting period shall constitute noncompliance with the
emission limits in Section 2.1 C.I La,above.
Shutdown and Malfunction[15A NCAC 02Q.0508(f)]
j. Except as specified in Section 2.1 C.111,below,the Permittee shall operate the Thermal Oxidizer and 4-Stage
Scrubber System(ID Nos.NCD-Q1 and NCD-Q2)at all times when the HFPO Process,VEN Process,VES
Process,RSU Process,Liquid Waste Stabilization Process,MMF Process,IXM Resins Process,E-2 Process,
TFElCO2 Separation Process,BFPO Product Container Decontamination Process,VEN Product Decontamination
Process,and VES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-D,NS-F,,NS-F,
NS-Gl,NS-K,NS-M,NS-N,NS-D,and NS-P)are operating.
k. Prior to operation of the Thermal.Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-Ql AND NCD-Q2),the
Permittee shall develop,and submit to NC DAQ for approval,a detailed shutdown and malfunction plan for the
Thermal Oxidizer and 4-Stage Scrubber System that contains specific procedures for initiating the shutdown of
process emission sources during periods of control device shutdown and malfunction,and a program of corrective
Permit No.03735T44
Page 39
action for malfunctioning processes,and control systems used to comply with the limits in Section 2.1 C.I La,
above.The Permittee shall keep a copy of the approved plan onsite.
i. To ensure that the control devices are well maintained to minimize malfunctions,the plan shall include a
maintenance schedule for the Thermal Oxidizer and 4-Stage Scrubber System that is consistent with.,but not
limited to the manufacturer's instructions and recommendations for routine and long-term maintenance,as
specified in Section 2.1 C.1 Lh and C.1 U,above.
ii. An inspection schedule for each CMS installed on the Thermal Oxidizer and 4-Stage Scrubber System to
ensure,at least once in each 24-bour period,that each CMS is properly functioning.
iii. At no time shall the emissions from the HFPO Process,VEN Process,VES Process,RSU Process,Liquid
Waste Stabilization Process,MMF Process,IXM Resins Process,E-2 Process,TFEICO2 Separation Process,
HFPO Product Container Decontamination Process,VEN Product Decontamination Process,and VES Product
Container Decontamination Process(rD Nos.NS-A,NS-B,NS-C,NS-D,NS-E,NS-F,NS-G-1,NS-K,NS-M,
NS-N,NS-O,and NS-P)be allowed to vent to the atmosphere without being controlled in the Thermal
Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-01 and NCD-Q2).
RecordkeeninulReporting[15ANCAC 02Q.0508(f)]
1. The Permittee shall record the following information monthly in a logbook(written or electronic format)that shall
be maintained on-site and made available to NC DAQ,upon request.
i. Records of the continuous and 3-hour rolling average operating parameters specified in Section 2.1 C.1 Lh and
C.1 Li,above,for the Thermal Oxidizer and 4-Stage Scrubber System(113 Nos.NCD-Ql and NCD-Q2).
ii. If the emission sources are not operating,a record of this fact along with the corresponding date and time.
iii. Records of all inspections and maintenance conducted for the Thermal Oxidizer and 4-Stage Scrubber System
(ID Nos.NCD-Q1 and NCD-Q2),as specified in Section 2.1 C.11.£,above.
iv. Records associated with the site-specific monitoring plan specified in Section 2.1 C.1 Lg,above.
m. The Permittee shall retain all results of performance testing conducted in accordance with Section 2.1 C.1 Lb and c,
above,including development of the operating parameters,as specified in Section 2.1 C.1 l.h and i,above,and the
calculation of the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-01 and NCD-Q2)control
efficiency with respect to the control of all PFAS,including GenX Compounds,emissions froin the HFPO Process,
VEN Process,VES Process,RSU Process,Liquid Waste Stabilization Process,MMF Process,IXM Resins Process,
E-2 Process,TFEICO2 Separation Process,HFPO Product Container Decontamination Process,VEN Product
Decontamination Process,and VES Product Container Decontamination Process(ID Nos.NS-A,NS-B,NS-C,NS-
D,NS-E,NS-F,NS-G1,NS-K,NS-M,NS-N,NS-O,and NS-P).
n. The Permittee shall keep all records on file for a minimum of five years.
o. The Permittee shall submit a quarterly summary report,acceptable to the Regional Air Quality Supervisor,of
monitoring and recordkeeping activities specified in Section 2.1 C.1 Lf through n,above,postmarked on or before
January 30 of each calendar year for the preceding three-month period between October and December;April 30 of
each calendar year for the preceding three-month period between January and March;July 30 of each calendar year
for the preceding three-month period between April and June;and October 30 of each calendar year for the
preceding three-month period between July and September. All instances of deviations from the requirements of
this permit must be clearly identified.
Permit No.03735T44
Page 40
D. Polymer Processing Aid Process(ID No.AS-A)controlled by a wet scrubber(ID No.ACD-Al)in series
with a Carbon Adsorber(ID No.ACD-A2)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Odors State-enforceable only 15A NCAC 02D.1806
See Section 2.2 B.5
Toxic Air Pollutants State-enforceable only 15A NCAC 02D.1100
Toxic air pollutant limits shall not be exceeded. See
Sections 2.2 B.I and 2.2 B.2
GenX Compoundss State-enforceable only 15A NCAC 02Q.0519 and
See Section 2.2 D Consent Order
STATE-ENFORCEABLE ONLY
1. 15A NCAC 02D.1140:CONTROL OF TOXIC AIR POLLUTANTS
a. Gaseous and mist emissions from the Polymer Processing Aid process area(lD No.AS-A)shall be controlled by a
wet scrubber(ID No.ACD-Al).The Permittee shall ensure the proper performance of the scrubber by monitoring
the following operational parameters:
i. Liquid flow rate through the packed bed section(minimum of 30 gallons per minute averaged over a 3-hour
period),and
I Differential pressure across the packed bed section of the scrubber(maximum of 12 inches of water pressure
averaged over a 3-hour period),with a high differential pressure alarm.
Recordkee inR
b. The Permittee shall record the results of inspections in a scrubber log(written or electronic records),which shall be
kept on site and made available to Division of Air Quality personnel upon request.Any variance from the
manufacturer's recommendations or the permit monitoring requirements,or the failure of the air pollution control
equipment to operate in a normal and usual manner,shall be investigated with corrections made and dates of action
recorded in the log book.The inspection and maintenance activities,as well as required monitoring for scrubbing
liquid flow rates,and scrubber pressure drops,if appropriate,shall be recorded.
s 'GenX Compounds"means HFPO 17imcr Acid,also known as C3 Diner Acid(CAS No. 13252-13-6);HFP0 Diener Acid Flumide,also known as C3
Diner Acid Fluoride(CAS No.2062-98-8);and H"O Diener Acid Ammonium Salt,also known as C3 Dimer Arid Ammonium Salt(CAS No.62037-80-
3).
Permit No.03735T44
Page 41
E. Wastewater Treatment Area consisting of an extended aeration biological wastewater treatment facility
(ID No.WTS-A)and two indirect steam-heated rotary sludge dryers(ID Nos.WTS-B and WTS-C)
controlled by a wet scrubber with mist eliminator(ID No.WTCD-1)
The following table provides a summai■ of limits and standards for the emission sours s described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Odors State-enforceable only 15A NCAC 02D.1806
Odorous emissions must be controlled
STATE ENFORCEABLE ONLY
1. 15A NCAC 02D.1805:CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the wastewater treatment area(ID Nos.WTS-A,WTS-B AND WTS-C) 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. Odorous emissions from the wastewater treatment sludge dryers(ID Nos.WTS-B and WTS-C)shall be controlled
by an impingement-type scrubber with caustic injection(ID No.WTCD-1).
Monitorin !Recordkee in«
c. To comply with the provisions of this Permit and ensure that maximum control efficiency of the scrubber(ID No.
WTCD-1)is maintained,the Permittee shall perform periodic inspections and maintenance as recommended by the
scrubber manufacturer. As a minimum,the inspection and maintenance program shall include inspection of spray
nozzles,packing material,chemical feed system(if so equipped),and the cleaning/calibratioo of all associated
instrumentation.
d. The Permittee shall record the results of inspections in a scrubber logbook(written or electronic format)that shall be
kept on site and made available to NC DAQ personnel upon request. Any variance from the manufacwrer's
recommendations or the permit monitoring requirements,or the failure of the air pollution control equipment to
operate in a normal and usual manner,shall be investigated with corrections made and dates of actions taken
recorded in the log book.The inspection and maintenance activities,as well as required monitoring for scrubbing
liquid flow rates and scrubber pressure drops,if appropriate,shall be recorded.
Permit No.03735T44
Page 42
F. Natural gas/No.2 fuel oil-fired temporary boiler(less than 100.0 million Btu per hour maximum
heat input,ID No.PS-Temp)
The following table provides a summary of limits and standards for the emission sources i described above:
Regulated Pollutant Limits/Standards Applicable Regulations
Particulate Matter 0.2426 pounds of particulate per million Btu 15A NCAC 02D.0503
Sulfur Dioxide 2.3 pounds SO2 per million Btu heat input 15A NCAC 02D.0516
Visible Emissions 20 percent opacity 15A NCAC 02D.0521(d)
Sulfur Dioxide and Visible On site less than 180 days per consecutive twelve 15A NCAC 02Q.0317
Emissions month period and use of fuels emitting no more (15A NCAC 02D.0524 [NSPS]
than 0.06 pounds of sulfur dioxide per million Btu Avoidance)
heat input.
Sulfur Dioxide Less than 40 tons per consecutive 12-month period 15A NCAC 02Q,0317
(15A NCAC 02Q.0530 [PSD]
Avoidance
Sulfur Dioxide Boilers(PS-A,PS-B,PS-C,and PS-Temp) 15A NCAC 02Q.0317
Less than 702.5 tons per consecutive 12-month (PSD Avoidance)
period;
See Section 2.2 A.1.of thisPermit.
Hazardous Air Pollutants On site less than 180 days per consecutive twelve 15A NCAC 02Q.0317
month period. (15A NCAC 02D.11091.1111
[MACT]Avoidance)
1. ISA NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter discharged into the atmosphere from the combustion of No. 2 fuel oil in the
temporary boiler(ID No.PS-Temp)shall not exceed 0.2426 pounds per million Btu heat input.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall he performed in accordance General Condition JJ.If the results of
this test are above the limit given in Section 2.1 F.l.a above,the Permittee shall be deemed in noncompliance with
15A NCAC 02D.0503.
Monitoring/Recordkeepin?JReportiny [15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of fuel oil in this source
for this regulation.
2. 15A NCAC 02D.0515:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from the temporary boiler(ID No.PS-Temp)shall not exceed 2.3 pounds per million
Bm heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall
he included when determining compliance with this standard.
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 F.2.a above,the Perm.ittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
MonitorinpJRecordkeeping/Recordkeeping[15A NCAC 02Q .0508(f)]
c. No monitoringlrecordkeeping is required for sulfur dioxide emissions from the firing of natural gas or fuel oil in this
source.
3. 15A NCAC 021i1.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the temporary boiler(ID No.PS-Temp)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
Permit No.03735T44
Page 43
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.
Te_stine[15A NCAC 02Q.0508(f)]
b. If emission 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 F.3.a above,the Permittee shall be deemed in noncompliance
with 15A NCAC 02D.0521.
Monitorin;fRecordkeepinp-Reporting[15A NCAC 02Q.0508(f)]
c. No monitoringlrecordkeepinglreporting is required for visible emissions from the firing of natural gas or fuel oil in
this source.
4. 15A NCAC 02Q.4317.AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications, the
temporary boiler(ID No.PS-Temp)shall discharge into the atmosphere less than 40 tons of sulfur dioxide per
consecutive twelve-month period.
Te_stine[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 limits given in Section 2.1 F.4.a above,the Permittee shall he deemed in
noncompliance with 15A NCAC 02D.0530.
Monitorin ./Recordkee ing [15ANCAC 02Q .0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a log(written or in electronic format),as follows:
i. The total quantity(in 1,000 gal)of fuel oil fired at the boiler;and,
ii. The fuel oil supplier certification for any fuel oil fired at the boiler,including the sulfur content of the oil(in
percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the fuel usage and fuel
oil sulfur content are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling SO2 emissions from the temporary boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook(written or electronic format),
according to the following formulas:
i. Calculate SO2 emissions from the previous calendar month using the following equation:
E so,=142*S*Qf�2
Where, Eso2 = SO2 emissions(in lbs)during the previous calendar month,
S = Sulfur content in the fuel oil(in percent by weight),and
QR,2 = Quantity of fuel oil fired at the temporary boiler during the previous
calendar month(in 1,000 gal)
ii. Sum the SO2 emissions from the boiler for the previous 12-month period to determine the 12-month rolling
emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.1 F.4.a of this permit.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall suhniit a semi-annual summary report,acceptable to the Regional Air Quality Supervisor,of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December,and July 30 of each calendar year for the preceding six-month period
between January and dune. The report shall contain the following:
i. The monthly SO2 emissions from the boiler for the previous 17 months;
ii. The total SO2 emissions from the boiler for each 12-month period ending during the six month reporting period;
and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
Permit No.03735T44
Page 44
5. 15A NCAC 02Q.0317:AVOIDANCE CONDITION
for 15A NCAC 02D.1109.CAA§112(j);Case-by-Case MACT for Boilers&Process Heaters NCAC 02D
a. Prior to May 20,2019,in order to avoid the applicability of 15A NCAC 02D.1109NCAC 02D, the temporary boiler
(ID No.PS-Temp)shall not remain on site for more than 180 consecutive days. The Pemnittee shall retain records
of the number of consecutive days the boiler is onsite.
b. 1f this boiler remains on site for longer than 180 consecutive days,the Permittee shall notify the Regional Office in
writing within ten days of exceeding the 180-day period.
c. The Permittee shall submit a startup notification to the Fayetteville Regional Office within 15 days of startup of the
temporary boiler(ID No.PS-Temp).
Permit No.03735T44
Page 45
G. Lime Silo (ID No.NS-R1) equipped with a pulse jet baghouse (ID No.NCD-RI)
Lime Slaker (ID No.NS-R2) equipped with a Wet Particulate Scrubber(11D No.NCD-R2)
The following table provides a summan of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulations
Particulate matter E=4.10 P 1.67
15A NCAC 02D.0515
where:
E=allowable particulate emission rate in pounds
per hour
P=process weight rate in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D.0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the Lime Silo and Lime Slaker(ID Nos.NS-RI and NS-R2)shall not exceed
an allowable emission rate as calculated by the following equation:
E=4.10 x P 0.61 Where: E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Testin [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 G.La,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0515.
Monitorinp-/Recordkeeuina [15A NCAC 02Q.0508(f)]
c. Particulate matter emissions from the Lime Slaker(ID No.NS-R2)shall be controlled by the Wet Particulate
Scrubber(ID No.NCD-R2).The Permittee shall install,operate,and maintain a wet scrubbing liquid flowmeter on
each scrubber. To ensure compliance and the effective operation of the scrubbers,the Permittee shall monitor and
record,once per day,scrubbing liquid flow rate. The Permittee shall be allowed three(3)days of absent
observations per semi-annual period,If the emission source(s)is not operating,a record of this fact along with the
corresponding date and time shall substitute for the daily observation.To ensure quality,the flow rate meters shall
be calibrated annually.The scrubber shall be operated to ensure the scrubbing liquid flow rate is greater than
2.9 gallons per minute, The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the
scrubber liquid flow rate is not maintained above the above prescribed limit or if these records are not maintained.
d. If the scrubber liquid flow rate readings recorded as required,are observed to be below the minimum rate specified
in Section 2.1 G.1.c,above,the Permittee shall inspect the scrubber(s)for malfunctions and clean or repair,as
necessary.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the inspections,
cleaning,and repairs are not performed.
e. Particulate matter emissions from the Lime Silo(ID Nos.NS-RI)shall be controlled by the bagfilter(ID Nos.NSD-
R1). 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 system ductwork and material collection unit for leaks;and
ii. an annual(for each 12-month period following the initial inspection)internal inspection of the bagfilter's
structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and bagfilters are not
inspected and maintained.
Permit No, 03735T44
Page 46
f. The results of inspection and maintenance activities in Section 2.1 G.l.c through e,above,shall be maintained in a
logbook(written or electronic format)on-site and made available to an authorized representative of DAQ 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 causes for any variance from the prescribed operating range for the scrubber(s);and
iv, corrective actions taken.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these records are not maintained.
Reportine[15A NCAC 02Q.0508(f)]
g. The Permittee shall suhmit the results of any maintenance performed on any control device within 30 days of a
written request by the DAQ.
h, The Permittee shall submit a summary report of the monitoring and recordkeeping activities specified in Section 2.1
G.Lc through f,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 pen-nit must be clearly identified.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visihle emissions from the Lime Silo and Lime Slaker(ID Nos.NS-R1 and NS-R2)shall not he 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-bour 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 B. If the
results of this test are above the limit given in 2.1 G.2.a,above, the Permittee shall be deemed in noncompliance
with 15 A NCAC 02D .0521.
Monitoring [15A NCAC 02Q.0508(f)]
c. To ensure compliance,once a week the Permittee shall observe the emission points of the Lime Silo and Lime
Slaker(ID Nos.NS-Rl and NS-R2)for any visible emissions above normal. The weekly observation must be
made for each week of the calendar year period to ensure compliance with this requirement.The Permittee shall
establish`normal"for the Lime Slaker in the first 30 days following the beginning operation.
i. If visible emissions from the Lime Silo and Lime Slaker are observed to be above normal,the Permittee shall
either:
(A) 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
(B) demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 0213.26 10(Method 9)for 12 minutes is below the limit given in Section 2.1 G.2.a,above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521 if;
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;
(C) the weekly observations are not conducted per c above;or
(D) "normal"is not established for the Lime Silo and Lime Slaker in the first 30 days following the beginning
of operation per c above.
Recordkee in [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 above
normal 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.
Permit No.03735T44
Page 47
Reporting[15ANCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of the monitoring activities specified in Section 2.1 G.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 No.03735T44
Page 48
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. BOILERS:
Three natural gas/No.2 fuel oil-fired boilers(ID Nos.PS-A,PS-B,and PS-C)
Temporary boiler(ID No.PS-Temp),natural gas/No.2 fuel oil-fired(greater than 30.0 and less than
100.0 million Stu per hour maximum heat input).
1. 15A NCAC 02Q.0317: AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D.0530(g)for major sources and major modifications,the affected
boilers(1D Nos.PS-A,PS-B,PS-C,and PS-Temp)shall discharge into the atmosphere less than 702.5 tons of SO2
per consecutive 12-month period.
Testing[I5ANCAC 02Q.0508(f)]
b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.2 A.La,above,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
Monitorin ecordkee in [I5ANCAC 02Q.0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a log(written or in electronic format),as follows:
i. The total quantity(in million standard cubic feet)of natural gas fired at the affected boilers;
ii. The total quantity(in 1,000 gal)of fuel oil fired at the affected boilers;and,
iii. The fuel oil supplier certification for any fuel oil fired at the affected boilers,including the sulfur content of the
oil(in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the fuel usage and fuel
oil sulfur contents are not created and retained as required above.
d. The Pernuttee shall calculate monthly and 12-month rolling S02 emissions from the affected boilers within 30 days
after the end of each calendar month. Calculations shall be recorded in a log(written or electronic format),
according to the following formulas:
i. Calculate S02 emissions from the previous calendar month using the following equation:
E,02 = 142 *Sfo2 *Qf02 + 0.6* Qn9
Where, Eso2 = S02 emissions(in lb)during the previous calendar month;
S h2 = Sulfur content in the fuel oil(percent by weight);
Qh2 = Quantity of fuel oil fired during the previous calendar month(1,000 gal);
and,
Q„, = Quantity of natural gas fired during the previous calendar month(million
standard cubic feet).
ii. Sum the S02 emissions from the affected boilers for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.2 A.l.a of this permit.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality Supervisor,of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December,and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly S02 emissions from the two affected boilers for the previous 17 calendar months;
ii. The 12-month rolling S02 emissions for each 12-month period ending during the reporting period,and,
iii. All instances of noncompliance from the requirements of this permit must be clearly identified.
Permit No. 03735T44
Page 49
B. FACILITY-WIDE
STATE-ENFORCEABLE ONLY
1. 15A NCAC 02D.1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 02D.1100 and in accordance with the approved application for an air toxic compliance
demonstration,the following permit limit shall not be exceeded:
Toxic Air Pollutant Facility-Wide Emission Limit
Acetaldehyde 395 lb/hr
Acetic Acid 54.1 lb/hr
Acrolein 1.17 lb/hr
Acrylonitrile 240 lb1yr
Ammonia 39.5 lb/hr
Ammonium Chromate 0.54 lb/day
Ammonium Dichromate 0.54 lb/day
Aniline 14.6 lb/hr
Arsenic and Inorganic Arsenic Compounds 0.37 lb1yr
Aziridine 5.26 lb/day
Benzene 192 lblyr
Benzidine and Salts 0.02 lblyr
Benzo(a)pyrene 52.8 lblyr
Benzyl Chloride 7.31 lblyr
Beryllium 6.56 lblyr
Beryllium Chloride 6.56 lb1yr
Beryllium Fluoride 6.56 lb1yr
Beryllium Nitrate 6.56 lb1yr
Bis-Chloromethyl Ether 0.59 lblyr
Bromine 2.92 lb/hr
1,3-Butadiene 272 lblyr
Cadmium 8.8 lblyr
Cadmium Acetate 8.8 lblyr
Cadmium Bromide 8.9 lblyr
Calcium Chromate 0.13 lblyr
Carbon Disulfide 163 lb/day
Carbon'Tetrachloride 10,723 lblyr
Chlorine 13.1 lb/hr;32.9 lb/day
Chlorobenzene 1,929lb1day
Chloroform 6,882 lb1yr
Permit No.03735T44
Page 50
Toxic Air Pollutant Facility-Wide Emission Limit
Chloroprene 51.1 lblhr;386 lb/day
Chromic Acid 0.54 lb/day
Chromium(VI) 0.13 iblyr
Cresol 32.15 lb1hr
p-Dichlorobenzene 965lblhr
Dicblorodifluoromed=e 217,477 lb/day
Dichlorofluoromethane 438 lb/day
Di(2-ethylhexy1e)phthalate 26.3 lb/day
Dimethyl Sulfate 2.63 lb/day
1,4-Dioxane 491 lb/day
Epichlorohydrin 132,832 lb1yr
Ethyl Acetate 2,046 lb1hr
Ethylenediamine 36.5 lblhr;263 lb/day
Ethylene Dibromide 640 lblyr
Ethylene Dichloride 6,081 lblyr
Ethylene Glycol Monoethyl Ether 27.8 lb1hr; 1051b1day
Ethylene Oxide 43.21b1yr
Ethyl Mercaptan 1.46 lb1hr
Fluorides 3.65 lblhr; 14,03 lb/day
Formaldehyde 2.19 lb1hr
Hexachlorocyclopentadiene 0.15 lblhr;0.53 lb/day
Hexachlorodibenzo-p-dioxin 0.12 lblyr
n-Hexane 965 lb/day
Hexane Isomers 5,262 lblhr
Hydrazine 0.531blday
Hydrogen Chloride 10.2 lblhr
Hydrogen Cyanide 16.1 lb/hr; 123 lb/day
Hydrogen Sulfide 30.7 lb/hr
Maleic Anhydride 1.46 lblhr; 10,5 lb/day
Manganese 8t Compounds 27.2 lb/day
Manganese Cyclopentadienyl Tricarbonyl 0.53-lb/day
Manganese Tetroxide 5.44 lb/day
Mercury,Alkyl 0.05 lb/day
Mercury,Aryl&Inorganic 0.53 lblhr
Permit No.03735T44
Page 51
Toxic Air Pollutant Facility-Wide Emission Limit
Mercury,vapor 0.53 lb/hr
Methyl Chloroform 3,581 lb/hr; 10,523 lb/day
Methylene Chloride 24.85 lb/hr,38,409 lblyr
Methyl Ethyl Ketone 1,293 Whr;3,245lb1day
Methyl Isobutyl Ketone 438 lb/hr; 2,245 lb/day
Methyl Mercaptan 0.73 lb/hr
Nickel Carbonyl 0.53 lb/day
Nickel Metal 5.26 lb/day
Nickel, Soluble Compounds as Nickel 5.26 lb/day
Nickel Subsultide 3.36 lb1yr
Nitric Acid 14.61b1hr
Nitrobenzene 7.31 lb/hr;52.6 lb/day
n-Nitrosodimethlamine 80.0 lb1yr
Pentachlorophenol 0.37 lb/hr;2.63 lb/day
Perchloroethylene 304,073 lb1yr
Phenol 13.9 lb/hr
Phosgene 2.19 lb/day
Phosphine 1.90 lb/hr
Polycholinated Siphenyls 133 lblyr
Potassium Chromate 0.54 lb/day
Potassium Dichromate 0.54 lb/day
Sodium Chromate 0.54 lb/day
Sodium Dichromate 0.54 lb/day
Strontium Chromate 0.13 lblyr
Styrene 155 lb/hr
Sulfuric Acid 1.46 lb/hr; 10.5 lb/day
Tetrachlorodibenza-p-dioxin 0.0048 lblyr
1,1,1,2-Tetrachloro-2,2-Difluoroethane 45,600lb1day
1,1,2,2,-Tetrachloro-1,2-Difluoroethane 45,600lb1day
1,1,1,2-Tetrachloroethane 10,082 lblyr
Toluene 919 lb/hr;4,122 lb/day
Toluene-2,4-diisocyanate 0.22 lb/hr;0.44 lb/day
Trichloroethylene 94,423 lblyr
Trichlorofluoromethane 8,1851b1hr
Perniit No.03735T44
Page 52
Toidc Air Pollutant Facility-Wide Emission Limit
1,1,2-Trichloro-1,2,2-Trilluoroethane 13,885 lblhr
Vinyl Chloride 608 lblyr
Vinylidene Chloride 105 lb/day
Xylene 950 lbIhr;2,368 lb/day
Zinc Chromate 0.13 lhlyr
Recordkeepin�
b. For compliance purposes,the Permittee shall maintain records of production rates,throughput,material usage,
periods of excess emissions,failure of air pollution control equipment to operate in a normal and usual manner,
and other process operational information,that allows for evaluation for compliance with the toxic air pollutant
limits. These records shall be retained for a minimum of three years from the date of recording,and access to
these records shall be provided to the Division of Air Quality staff upon request.
Reporting
c. For compliance purposes,within thirty(30)days after each calendar year quarter the following shall be reported
to the Regional Supervisor,Division of Air Quality:
i, Any and all exceedances of applicable toxic air pollutant emission limits during the previous calendar year
quarter.
ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per hour.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants that have a listed emission rate in pounds per day.
iv. The yearly emission rate for the 12-month period ending with the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per year,
STATE-ENFORCEABLE ONLY
2. 15A NCAC 02D.1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 02D.1100 and in accordance with the approved application For an air toxic compliance
demonstration,the Following permit limits shall not he exceeded:
Hydrogen Fluoride
Emission Limits
Stack ID No. Emission Source lb/hr lb/day
Priman Operatin2 Scenario
NEP-Hdr-1 Baffle Plate Scrubber(ID No.NCD-Hdrl)stack controlling:HFPO,Vinyl Ethers North,RSU,FPS Liquid
Waste Stabilization,MMF,TFE-CO2 Separation,HFPO Container Decontamination,VEN Container
Decontamination,and VES Container Decontamination Processes(I)Nos.NS-A,NS-B,NS-D,NS-E,NS-
F,NS-:11,NS-N.NS-0.and NS-P 7.28 52.45
NEP-Hdr-2 Baffle Plate Scrubber(ID No.NCD-Hdr2)stack controlling: Vinyl Ethers South No.NS-C)
AEP-Al Polymer Processing Aid Stack including Polymer ProcessingAid(CD No.AS-A)
)process vents controlled
by Wet Scrubber(1D No.ACD-Al)and indoor fugitive emissions
Alternative O eratin Scenario
NEP-Hdr-t Carbon Adsorber¢D No.NCD-Hdr3)stack controlling VE-North Indoor Fugitive Emissions(T)No.NS-
B-1)
NEP-Q2 Thermal Oxidizer and 4-Stage Caustic Scrubber System(1D No&NCD-Q1 and NCD-Q2)stack
controlling:HFPO,Vinyl Ethers North,Vinyl Ethers South,RSU,FPS Liquid Waste Stabilization,MMF,
IXM Resins(except Fluorinator),E-2,7FEJCO2 Separation,HFPO Product Container Decontamination, 728 52.45
VEN Product Decontamination,and VES Product Container Decontamination Processes(ID Nos.NS-A,
NS-B,NS-C,NS-D NS-F,NS-F,NS-G-1,NS- NS-M,NS-N,NS-0 and NS-P)
AEP-Al Polymer Processing Aid Stack including Carbon Adsorber(ID No.ACD-A2)installed on Wet Scrubber(I)
No.ACD-Al)and heating and ventilation building othaust
Priman and Alternative Operating Scenarios
NIA 1. All sources not identified above 17 19A
Permit No. 03735T44
Page 53
Monitoring
b. To ensure compliance with the limits in Section 2.2 B.2.a,above,the Permittee shall:
i. POS:ensure the proper performance of the Baffle Plate-Type Tower Scrubbers(11)Nos.NCD-Hdr-1 and
NCD-Hdr-2)by monitoring the injection liquid flow rate(minimum of 7,000 kilograms per hour,averaged
over a 3-hour period).
ii. AOS: ensure the proper performance of the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.
NCD-Ql and NCD-Q2)by complying with the requirements specified in Section 2.1 C.11.
Recordkeeping
c. The Permittee shall:
i. POS:record the results of inspections of the Baffle Plate-Type Tower Scrubbers(ID Nos.NCD-Hdr-1 and
NCD-Hdr-2)in a scrubber logbook(written or electronic records)that shall be kept on site and made
available to Division of Air Quality personnel upon request.
ii. AOS:record the results of inspections of the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.
NCD-Ql and NCD-Q2)as specified in Section 2.1 CA 1,above.
iii. Any variance from the manufacturees recommendations or the permit monitoring requirements,or the
failure of the air pollution control equipment to operate in a normal and usual manner,shall be investigated
with corrections made and dates of action recorded in the log book The inspection and maintenance
activities,as well as required monitoring for scrubbing liquid flow rates,and scrubber pressure drops,if
appropriate,shall be recorded.
d. The Permittee shall maintain records of production rates,throughput,material usage,periods of excess
emissions,failure of air pollution control equipment to operate in a normal and usual manner,and other process
operational information,that allows for evaluation for compliance with the toxic air pollutant limits specified in
Section 2.2 B.2.a,above. These records shall be retained for a minimum of three years from the date of
recording,and access to these records shall be provided to the Division of Air Quality staff upon request.
Reporting
e. For compliance purposes,within thirty(30)days after each calendar year quarter the following shall be reported
to the Regional Supervisor,Division of Air Quality:
i. Any and all exceedances of applicable TAP emission limits during the previous calendar year quarter.
ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per hour.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants which have a listed emission rate in pounds per day.
3. 40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK MANAGEMENT
PROGRAMS UNDER THE CLEAN AIR ACT,SECTION 112(r)"
a. The Permittee is subject to Section 112(r)of the Clean Air Act and shall comply with all applicable
requirements in accordance with 40 CFR Part 68.
RecordkeepinglReporting[15ANCAC 02Q.0508(f)]
b. The Permittee submitted a Risk Management Plan(RMP)to EPA pursuant to 40 CFR Part 68.150 on August
18,2014.
c. The Permittee shall revise and update the RMP submitted under 40 CFR 68.150 by August 31,2019,and at
least once every five years after that date or most recent update required by 40 CFR 68.190(b)(2)through(b)(7),
whichever is later,
STATE-ENFORCEABLE ONLY
4. 15A NCAC 02D.0541: CONTROL OF EMISSIONS FROM ABRASIVE BLASTING
a. The Permittee shall ensure that any abrasive blasting operation conducted outside a building or conducted
indoors and vented to the atmosphere is performed in accordance with the requirements set forth in 15A NCAC
02D .0521,Control of Visible Emissions. Any visible emissions reading for abrasive blasting performed
outside a building shall be taken at a spot approximately one meter above the point of abrasive blasting with a
viewing distance of approximately five meters.
Permit No,03735T44
Page 54
b. All abrasive blasting operations shall be conducted within a building,except as provided below. The following
abrasive blasting operations need not be conducted within a building:
i. Abrasive blasting of an item that exceeds eight feet in any dimension;or,
ii. Abrasive blasring of a surface situated at its permanent location or not further away from its permanent
location than is necessary to allow the surface to be blasted.
c. Any abrasive blasting operation conducted outside a building,as provided in Section 2.2 13.3.1b.i or ii,above,
shall take appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting
operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being
conducted. Appropriate measures include the following:
i. . Addition of a suppressant to the abrasive blasting material;
ii. Wet abrasive blasting;
iii. Hydro-blasting;
iv. Vacuum blasting;
v. Shrouded blasting;or
vi. Shrouded hydra-blasting.
STATE-ENFORCEABLE ONLY
S. 15A NCAC 02D.1846: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.
Permit No.03735T44
Page 55
C. PERNIIT APPLICATION SUBMITTAL REQUIREMENT
1. 15A NCAC 02Q.0504: OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT
Permittin-= [15A NCAC 02Q,0504(d)]
a. As required under 15A NCAC 02Q.0501(b)(2), the Permittee shall have one year from the date of beginning normal
operation of the modified IXM Membrane Coating Process(ID No.NS-I),to file an amended application following
the procedures of Section 15A NCAC 02Q.0504.
Reporting[15ANCAC 02Q.0508(t)]
b. The Permittee shall notify the Regional Office,in writing,of the date of beginning normal operation of the modified
IXM Membrane Coating Operation(ID Nos.NS-I)postmarked no later than 30 days after such date.
2. 15A NCAC 02Q.0504: OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT
Permitting[15A NCAC 02Q.0504(d)]
a. As required under 15A NCAC 02Q.0501(b)(2), the Permittee shall have one year from the date of beginning normal
operation of the Thermal Oxidizer(ID No.NCD-Ql), the 4-Stage Caustic Scrubber(ID No.NCD-Q2),the Lime
Silo(ID No.NS-RI),or the Lime Slaker(ID No.NS-R2),whichever is first,to file an amended application
following the procedures of Section 15A NCAC 02Q.0504.
Reporting[15A NCAC 02Q.0508(f)]
b. The Permittee shall notify the Regional Office,in writing,of the date of beginning normal operation of the Thermal
Oxidizer(ID No.NCD-Ql),the 4-Stage Caustic Scrubber(ID No.NCD-Q2),the Lime Silo(ID No.NS-RI),or the
Lime Slaker(ID No.NS-R2),postmarked no later than 30 days after such date.
Permit No.03735T44
Page 56
D. FACILITY-WIDE
STATE-ENFORCEABLE ONLY
1. 15A NCAC 02Q.0519(a)(7)and CONSENT ORDER
a. To carry out the purposes ofN.C.G.S. §143 Article 21B and to ensure that air emissions do not contribute to
groundwater violations,and pursuant to the Consent Order,'the Permittee shall reduce facility-wide annual
emissions(including fugitive,maintenance,malfunction,or accidental emissions)of GenX Compounds'to less than
23.027 pounds per year,which constitutes a 99 percent reduction from the 2017 Total Reported Emissions of
2,302.7 pounds per year.The Section 2.2 D.1 requirements shall survive termination of the Consent Order'and any
part thereof,The requirements in this section shall be included in all subsequent air quality permits for the Cbemours
Company—Fayetteville Works Facility unless the Director determines that the requirements in this section are no
longer necessary to carry out the purposes of N.C.G.S. §143 Article 21H and any other applicable statutes and
regulations.The Permittee shall comply with the following requirements:
i. Permittee shall demonstrate compliance with the GenX Compounds emission limit of 23.027 pounds per year
by calculating annual emissions each calendar month for the previous 12 months.
ii. The Permittee shall reduce emissions of GenX Compounds by 99.99 percent from the HFPO Process,Vinyl
Ethers North Process,Vinyl Ethers South Process,RSU Process,FPS Liquid Waste Stabilization Process,MMF
Process,IXM Resins Process(except Fluorinator),E-2 Process,TFEICO2 Separation Process,HFPO Product
Container Decontamination Process,VEN Product Decontamination Process,and VES Product Container
Decontamination Process(ID Nos.,NS-A,NS-B,NS-C,NS-D,NS-E,NS-F,NS-Gl,NS-K,NS-M,NS-N,
NS-O,and NS-P)by installing,operating,and maintaining a Thermal Oxidizer and 4-Stage Scrubber System
(ID Nos.NCD-Ql and NCD-Q2),as required in Section 2.1 C.11,shove.
iii. The Permittee shall reduce emissions of GenX Compounds from the Polymer Processing Aid Process(ID No.
AS-A)and from VE-North Indoor Fugitives(ID No.NS-B-2)by installing,operating,and maintaining Carbon
Adsorbers(ID Nos.ACD-A2 and NCD-Q3)as required in Section 2.2 D.Lb through g,below.
iv. The Permittee shall reduce emissions of GenX Compounds from process equipment by complying with the
enhanced leak detection and repair program as specified in Section 2.2 D.Lh,below.
v. The Permittee shall comply with,the recordkeeping and reporting requirements specified in Section 2.2 D.Li
through in,below.
Testing—Carbon Adsorbers[15A NCAC 02Q.0508(f)]
b. The Permittee shall conduct performance tests for GenX Compounds emissions from the Polymers Processing Aid
Carbon Adsorber(ID No.ACD-A2)and the VE-North Indoor Fugitives Carbon Adsorber(ID No.NCD-Q3).The
Permittee shall conduct emissions testing in accordance with General Condition 7]and in accordance with a testing
protocol approved by NC DAQ at least 45 days prior to conducting the performance test.During each performance
test,the Permittee shall collect production data and hours of operation,
c. The Permittee shall conduct performance tests on a quarterly basis,beginning May 13,2019, to develop a carbon
replacement schedule for each Carbon Adsorber(ID No.ACD-A2 and NCD-Q3)based on hours of operation,
production rate,or another approved parameter,to be approved by NC DAQ.Once the carbon replacement schedule
has been approved,the Permittee shall conduct subsequent performance tests on an annual basis,The Permittee shall
conduct additional performance tests within 90 days whenever permanent changes are made in production capacity,
process feedstock type,or whenever there is a replacement,removal,or addition of an emission source or control
device.Following this performance test,the Permittee shall conduct quarterly performance tests for one year to
determine whether the process changes result in a different carbon replacement schedule.After the revised
replacement schedule is determined,the Permittee shall resume annual performance testing.
Inspections—Carbon Adsorbers[15A NCAC 02Q.0508(f)]
d. Emissions of GenX Compounds from Polymer Processing Aid Process(ID No.AS-A)and VIE-North Indoor
Fugitives(ID No.NS-B-2)shall be controlled by Carbon Adsorbers(ID Nos.ACD-A2 and NCD-Q3,
respectively). To ensure compliance,the Permittee shall perform annual inspections and maintenance as
recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance
'"Consent Order"means the Consent Order entered on February 25,2019,in State of North Carolina,ex rel.,Michael S.Regan,Secretary,North Carolina
Department of Environmental Quality v.The Chemours Company FC,LLC,17 CVS 580(Bladen County),
'"GenX Compounds"means HFPO Dimer Acid,also known as C3 Di mer Acid(CAS No. 13252-13-6);HFPO Dimer Acid Fluoride,also]mown as C3
Dimer Acid Fluoride(CAS No.2062-98-8);and HFPO Dimer Acid Ammonium Salt,also known as C3 Dimer Acid Ammonium Salt(CAS No.62037-80-
3).
Permit No.03735T44
Page 57
recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,
the annual inspection and maintenance shall include the following:
i. inspect and maintain the structural integrity of the carbon adsorber systems;and
ii. inspect and maintain the structural integrity of duct work and piping leading to the carbon adsorber.
Shutdown and Malfunction—Carhon Adsorhers[I5A NCAC 02Q.0508(f)]
e. Except as specified in Section 2.2 D.Lg,below,the Permittee shall operate the Carbon Adsorber(ID No.ACD-A2)
at all times when the Polymer Processing Aid Process is operating and the Carbon Adsorber(ID No.NCD-Q3)at
all times when the VE-North Process is operating.
f. The Polymers Processing Aid Carbon Adsorber(ID No.ACD-A2)system shall be equipped with a differential
pressure monitor on the primary blower and the scrubber blower.The VE-North Indoor Fugitives Carbon Adsorber
(ID No.NCD-Q3)system shall be equipped with a differential pressure monitor on the blower and the tower.Each
monitor shall trigger an alarm in the control room when the differential pressure indicates improper operation of the
carbon bed blower.The Permittee shall develop,and submit to NC DAQ for approval,a site-specific monitoring
plan that addresses design,data collection,and quality assurance/quality Control elements for operating each CMS
installed on the carbon adsorbers.The monitoring plan shall,at a minimum,address the following:
i. Initial and any subsequent calibration of the CMS;
ii. Determination and adjustment of the calibration drift of the CMS;
iii. Preventive maintenance of the CMS,including spare parts inventory;
iv. Data recording,calculations,and reporting;
v. Accuracy audit procedures,including sampling and analysis methods;
vi. Program of corrective action for a malfunctioning CMS;
vii. Ongoing operation and maintenance procedures;and
viii.Ongoing data quality assurance procedures.
g. No later than April 13,2019,the Permittee shall develop,and submit to DAQ for approval,a detailed shutdown and
malfunction plan for the Polymer Processing Aid Process and VE-North Indoor Fugitive Carbon Adsorhers
(ID Nos.ACD-A2 AND NCD-Q3),that contains specific procedures for initiating the shutdown of process
emission sources during periods of control device shutdown and malfunction,and a program of corrective action for
malfunctioning processes and control systems used to comply with the limits in Section 2.2 D.La,above.The
Permittee shall keep a copy of the approved plan onsite.At a minimum,the plan shall include:
i. To ensure that the control devices are well maintained to minimize malfunctions,a maintenance schedule for
the carbon adsorbers that is consistent with,but not limited to the manufacturer's instructions and
recommendations for routine and long-term maintenance,as specified in Section 2.2 D.Ld,above.
ii. An inspection schedule for each CMS installed on the carbon adsorbers to ensure,at least once in each 24-hour
period,that each CMS is properly functioning,
iii. A determination of the alarm set point for the differential pressure morritors installed on the carbon adsorber
systems specified in Section 2.2 D.1.f,above.
iv. At no time shall the emissions from the Polymer Processing Aid Process(ID No.AS-A)or the VE-North
Indoor Fugitives(ID No.NS-B-2)he allowed to vent to the atmosphere without being controlled in the
associated Carbon Adsorbers(ID Nos.ACD-A2 and NCD-Q3).
Inspections and Monitoring—Enhanced Leak Detection and Repair Program[15A NCAC 02Q.0508(f)]
h. No later than May 13,2019,the Permittee shall develop,and submit to NC DAQ for approval,an enhanced leak
detection and repair program. The Permittee shall conduct inspections and monitor to detect leaks from equipment
identified in the approved program.The program shall address the following.
i. Pressure testing for 30-minute intervals to detect a pressure drop rate up to 0.5 pounds per square inch(gauge)
for those process lines with the potential to include 1 percent by weight of GenX Compounds,or greater.
ii. Enhanced audial visual and olfactory(AYD)inspections,including,but not limited to:
(A) expanding the equipment subject to the inspection process;
(B) conducting daily AVO inspections of all outdoor equipment containing at least 1 percent by weight,or
greater,GenX Compounds;and
(C) completing a checklist of all equipment to be inspected along with information such as date and time of
inspection, the names of personnel conducting the inspection,and detailed descriptions of the areas or
equipment inspected.
iii. Routine Method 21 Instrument Monitoring for all outdoor equipment on process lines with the potential to
contain at least I percent GenX Compounds,
Permit No.03735T44
Page 58
iv. Enhanced area monitoring,including but not limited to,increasing the number of area monitoring sampling
locations,specifically those process streams with the potential to include 1 percent by weight of GenX
Compounds and upgrading the monitoring system.
v. Replacement or improvement program for valves and connectors,using leak detection and repair monitoring to
initiate replacement with low emission technology.The program shall address the following:
(A) the leak definition,not to exceed 500 ppm,as measured by instrument monitoring;
(B) the criteria for replacement of manual valves and gaskets and automated valves,including:
(1) the procedure for the normal means of repair for the first leak and,at a minimum,will include
tightening of flanges,packing,or bonnets;and
(2) once repaired,the program shall specify how the repaired equipment will be tested and how the
Permittee will treat equipment that is still leaking.
(C) how the Permittee will address equipment is found to be leaking above 500 ppm twice during a rolling 12-
month period,including a requirement to replace these components with low-emission technology during
the next shutdown.,regardless of whether a first attempt at repair succeeds in repairing a second leak.
vi. The maintenance and.calibration of any instrumentation and equipment used to implement the enhanced leak
detection and repair program in paragraphs i. through v.,above.
Compliance Demonstration[15ANCAC 02Q.0508(f)]
i. The Permittee shall demonstrate initial compliance with the emission limitation specified in Section 2.2 D.La,
above,by submitting a report to NC DAQ by February 28,2021.The report shall include the following information
for the 12-month period beginning December 31,2019:
i. Emissions of GenX Compounds,in pounds per year,shall be quantified for process vents,fugitive emissions,
maintenance emissions and accidental emissions.Emissions shall be calculated based on test data,or
established emission factors where test data are not available,hours of operation,and production data.
ii. A summary of control device operating parameters throughout the year.
j. After the initial compliance report specified in Section 2.2 D.Li,above,the Permittee shall demonstrate continuous
compliance with the emission limitation specified in Section 2.2 D.La,above,by submitting quarterly reports
summarizing the information specified in Section 2.2 D.l.i,above.The continuous compliance reports shall be
submitted in accordance with the schedule specified in Section 2.2 D.Lm,below,and the first report shall be
postmarked on or before April 30,2021.
Recordkee iin [15ANCAC 02Q.0508(f)]
k. The Permittee shall record the following information monthly in a logbook(written or electronic format)that shall
be maintained on-site and made available to NC DAQ,upon request.
i. Records of all production data and hours of operation collected during performance tests.
ii. Records of the calculations,and all supporting documentation,of annual GenX Compound emissions to
demonstrate compliance with the emissions limitation specified in Section 2.2 D.I.a,above.
iii. If the emission source is not operating,a record of this fact,along with the corresponding date and time.
iv. Records of all inspections and maintenance conducted for the Carbon Adsorbers(lD Nos.ACD-AZ and NCD-
Q3)as specified in Secdon 2.2 D.1.d,ahove.
v. Records of all instances of process shutdowns,including those triggered by the pressure differential alarms
associated with carbon adsorber systems.
vi. Records of all inspections and calibrations of monitoring equipment as required in Section 2.2 D.Lf and D.l.h,
above.
1. The Permittee must keep each entry in the log and all required records on file for a minimum of five years.In
addition to the records identified in Section 2.2 13.11,above,the Permittee shall also keep the following records.
i. A copy of each test report and compliance report submitted.to NC DAQ to comply with Section 2.2 D.1,
including all documentation supporting any compliance report.
ii. The most recent copy of the approved Carbon Adsorber shutdown and malfunction plan required in Section 2.2
D.Lg,above.Records of instances where the differential pressure monitors required in Section 2.2 D.Lf,above,
have resulted in process shutdowns.
iii. The most recent copy of the approved Enhanced Leak Detection and Repair Program required in Section 2.2
13.11,above,including the following:
(A) Pressure testing records,including,but not limited to,the date of inspection,results of the
inspection/pressure testing,repairs made to any equipment found to be leaking during pressure testing,and
follow-up pressure testing to verify successful repair;
Permit No.03735T44
Page 59
(13) AVO inspection records,including the completed checklist specified in Section 2.2 D.1.h.ii.C,above,and
inspection results including any leaks found and repair actions taken;
(C) Method 21 and enhanced area monitoring results;and
(D) Replacement program for valves and connectors logs of leakers and repair attempts.
"e ort [15A NCAC 02Q.0508(f)]
m. The Permittee shall submit a quarterly summary report,acceptable to the Regional Air Quality Supervisor,of
monitoring and recordkeeping activities specified in Section 2.2 D.1,above,postmarked on or before January 30 of
each calendar year for the preceding three-month period between October and December;April 30 of each calendar
year for the preceding three-month period between January and March;July 30 of each calendar year for the
preceding three-month period between April and June;and October 30 of each calendar year for the preceding three-
month period between July and September. All instances of deviations from the requirements of this permit must be
clearly identified.
i. The summary report shall include the information recorded as required in Section 2.2 D.l.k and 1,above.
ii. The Permittee shall include in the summary report any excess emissions that have occurred during the reporting
period.Excess emissions are defined as any calculated annual rolling average GenX Compound emissions rate,
calculated as required in Section 2.2 D.l.a,above,that exceeds the emission limit in Section 2.2 D.La,above.
n. The Permittee shall have an ongoing duty to disclose to NC DAQ:
i. any identified previously undisclosed HAS and emissions rates for those PFAS,and
ii. any new process or production that may lead to the addition of any previously undisclosed PFAS in the
Facility's air emissions.For any such PFAS,the Permittee shall provide DAQ with any available analytical test
methods and lab standards.The Permittee shall provide DAQ with all known test methods and lab standards For
PFAS in air emissions at the facility by December 31,2018.
Pertnit No. 03735T44
Page 60
2.3 Permit Shield for Nonapplicable Requirements
The Permittee is shielded from the following nonapplicable requirements[15A NCAC 02Q.0512(a)(1)(B)].
A. The NSPS for Small Industrial-Commercial-Institutional Steam Generating units(40 CFR Part 60,Subpart Dc)and
15A NCAC 02D.0524 are not applicable to the natural gas/No.2 fuel oil-fired temporary boiler(ID No.PS-Temp)
because the boiler is a temporary boiler,as defined in§60.41c,provided the following criteria are met:
1. The boiler only fires natural gas and distillate oil;
2. The potential SQa emissions are equal to or less than 0.060 lbI11 MBtu;
3. The boiler is designed to,and is capable of,being carried or moved from one location to another and is not
attached to a foundation;and
4. The boiler remains at the location for 180 consecutive days or fewer(any temporary boiler that replaces a
temporary boiler at a location and performs the same or similar function will be included in calculating the
consecutive time period).
B. The National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,Commercial,and
Institutional Boilers and Process Heaters(40 CFR Part 63,Subpart DDDDD)and 15A NCAC 02D.I 111 are not
applicable to the natural gas/No.2 fuel oil-fired temporary boiler(ID No.PS-Temp)because the boiler is a
temporary boiler,as defined in§63.7575,provided the criteria in Section 2.3 A.1 through AA are met.
C. The Pemuttee shall maintain the following records documenting that the natural gas/No.2 fuel oil-fired temporary
boiler(ID No.PS-Temp)meets the criteria for a temporary boiler.These records shall be maintained in a logbook
(written or electronic format)on-site and made available to an authorized representative upon request.
1. the first,last and total number of days the boiler remains at the location;
2. records of fuel usage in the boiler showing the type of fuel Fired;
3. records of fuel sulfur content of distillate oil fired in the boiler,and;
4. the function of the boiler for each consecutive time period.
D. The Pernuttee shall submit a startup notification to the Fayetteville Regional Office within 15 days of startup of the
temporary boiler(fD No.PS-Temp).
Permit No.03735T44
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SECTION 3 - GENERAL CONDITIONS (version 5.3, 08/21/201.8)
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 he operated,maintained,or modified without the appropriate and valid
permits issued by the DAQ,unless time 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 time permit,except those held to he invalid,shall
remain valid and must he 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,morritoring 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 he sent to time 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).
E. Duty to Comu.y[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.
Permit No.03735T44
Page 62
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 Modi fications[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 mission
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 1 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
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(h)(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
h. 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 he allowed without permit revision pursuant to 15A
NCAC 02Q.0523(c).
Permit No.43735T44
Page 63
I.A Re ortin Requirements for Excess Emissions and Permit Deviations[15A NCAC 02D.0535(f)and 02Q.0508(t)(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 0213;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.1110 and
02D.III I shall apply where defined by rude.)
"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 0213.0524),NESHAPS(15A NCAC 02D
.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of excess emissions,reporting
shall he performed as prescribed therein.
2. If the source is not subject to NSPS(15A NCAC 02D.0524),NESHAPS(I5A NCAC 02D.1110 or.I I11),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 0213.0535,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).
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.
I.B Other Re uirements 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.b(g)]
The Permittee shall he 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.
Permit No.03735T44
Page 64
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 hag 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[I 5A 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.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 Activih'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. Du_n to Provide Information isubmittal 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 rw itina to determine whether cause exists for modifying,revolting 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 Sunvlement[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.
0. 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
Permit No.03735T44
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comply with additional requirements as may he 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 hasis 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(q)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.
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.0519]
The Director may terminate,modify,or revoke and reissue this permit if:
l. 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[15A 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 En [15A NCAC 02Q.0508(1)and NCGS 143-215.3(a)(2)]
l. 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.
Permit No.03735T44
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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.
W. Annual Fee PR%-ment[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 Reg uirements[15A NCAC 02Q.0207]
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 Pernttee 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 direcdy to the EPA upon request. All requests for
confidentiality must be in accordance with 15A NCAC 02Q.0107.
Z. Construction and 0 wration Permits[15A NCAC 02Q.0100 and.0300]
A constriction 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 Re aired 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 115A 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 Re uirements(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 hydrochlorofluomcarboas 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.
EE. Prevention of Accidental Releases General Dut► Clause-Section 112 r 1 —FEDERALLY-ENFORCEABLE ONLY
Although a risk management plan may not be required,if the Perrittee 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.
Permit No.03735T44
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FF. Title 1Y Allowances[15ANCAC 02Q.0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Pemuttee 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.0300]
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. Reeistration 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 Ounhh,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 Tes ' and Reporting Requirements[I5A NCAC 02Q.0508(i)(I6)]
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.
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 Subcbapter 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.
Permit No.03735T44
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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 Re uirements for Non-Q eratin Equipment[15A NCAC 02Q.0508(i)(l6)]
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.
MM.Fugitive Dust Control Reguirement[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).
"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[15A 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 dMce(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)(I0),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 suhmit a page "E5"of the application forms signed by the responsible official verifying that the
Permit No.03735T44
Page 69
application for the 502(b)(10)changelmodification,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 w object is the end of EPA's decision-making process with respect w 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 No. 03735T44
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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 Imp]ementation Plan
SOx Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound