DEQ-CFW_00065337

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MDR
North Carolina Department of Environment and
Pat McCrory
Governor
August 26, 2014
Mr. Ross Crews
Site Manager
Kuraray America, Inc. - Fayetteville
22824 NC Hwy 87 West
Fayetteville, NC 28306
Subject: Air Permit No. 10396R00
Kuraray America, Inc. - Fayetteville
Fayetteville, Bladen County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 0900091
Dear Mr. Crews:
0
Natural Resources
John E. Skvarla, III
Secretary
In accordance with your completed application received August 18, 2014, we are forwarding
herewith Permit No. 10396R00 to Kuraray America, Inc. - Fayetteville, Fayetteville, Bladen
County, North Carolina for the construction and operation of air emissions sources or air cleaning
devices and appurtenances. Additionally, any emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the
records retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts, requirements, or limitations contained in this 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. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
Fayetteville Regional Office - Division of Air Quality
Systel Building, 225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5094
Phone: [phone] / FAX: [phone]
Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer -Made in part by recycled paper
DEQ-CFW 00065337

Ross Crews •
August 26, 2014
Page 2
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 150B-23.
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S.143-215.114A and 143-
215.114B.
This permit shall be effective from August 22, 2014 until July 31, 2022, is nontransferable
to future owners and operators, and shall be subject to the conditions and limitations as specified
therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations
and restrictions set forth in this permit. 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. Should you have any questions concerning this matter,
please contact Gregory Reeves at 910-433-3300.
Sincerely,
r '
Steven F. Vozzo, Regio al Supervisor
Division of Air Quality, NCDENR
GWR
Enclosures
c: Fayetteville Regional Office
DEQ-CFW 00065338

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NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
Issue Date: August 26, 2014
Expiration Date: July 31, 2022
DIVISION OF AIR QUALITY
AIR PERMIT NO.10396R00
Effective Date: August 26, 2014
Replaces Permit: (new)
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Kuraray America, Inc. - Fayetteville
22824 NC Hwy 87 West
Fayetteville, Bladen County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 0900091
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
BS-A
Butyraldehyde Storage Tank
(NESHAP)
BS-B.1.1
Butacite® Polyvinyl Butyral flake reactor
(NESHAP)
BS-B.1.2
FButaciteg Polyvinyl Butyral flake reactor
(NESHAP)
_
BS-B.1.3
Butacite® Polyvinyl Butyral flake reactor
(NESHAP)
BS-B.1.4
Butacite® Polyvinyl Butyral flake reactor
(NESHAP)
BS-B.2.1
FButacite(SD Polyvinyl Butyral flake reactor
(NESHAP)
BS-B.2.2
B.utacite® Polyvinyl Butyral flake reactor
(NESHAP)
_ _.__.. __.
BS-B.2.3 Butacite® Polyvinyl Butyral flake reactor
NESHAP)
BS-B.2.4 Butacite..@ Polyvinyl Butyral flake reactor
NF.CNAPI
BCD -A Brine -Cooled Condenser
BCD-B1 Packed -Bed Column Scrubber
with Mist Eliminator
BCD-B2 Packed -Bed Column Scrubber
with Mist Eliminator
DEQ-CFW 00065339

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Permit No. 10396R00
Page 2
BS-C
Butacite® Polyvinyl Butyral flake dryer
BCD-C
Fabric Filter
(NESHAP)
€
6 245 square feet filter area
BS-El Butacite® Line No. 3 Sheeting Extrusion
BCD -El Water -Cooled Condenser
(NESHAP) Process, including four (4) extruders --
BS-E2
Butacite® Line No. 4 Sheeting Extrusion
(NESHAP)
Process, including four (4) extruders
BCD-E2
Water -Cooled Condenser j
BS-E3 IButacite® Line No. 3 Back -End Process,
(NESHAP) including a quencher, dryer/relaxer, and N/A
wind-up area
BS-E4 Butacite® Line No. 4 Back -End Process,
(NESHAP) including a quencher, dryer/relaxer, and N/A
wind-up area
BS-F
(NESHAP)
Butacite® PVA Unloading System and
Storage Silos
N/A
BS-G
(NESHAP)
Butacite® PVA Dissolver Tank System N/A N/A
SGS-A SentryGlas® Process N/A N/A ,
in accordance with the completed application 0900091.14A received August 18, 2014 including any
plans, specifications, previous applications, and other supporting data, all of which are filed with the
Department of Environment and Natural Resources, Division of Air Quality (DAQ) and are
incorporated as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
l . Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
21) .0202, 2D .0515, 2D .0521, 2D .0535, 2D .0540, 2D .0611, 2D .1111, 2D .1806, 2Q
.0315 and 2Q .0317 (Avoidance).
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit (without
a modification request). The renewal request (with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2021 calendar year.
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Permit No. 10396R0O
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3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the emission sources shall not exceed allowable emission rates. The allowable emission rates
are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be
determined by the following equation(s), where P is the process throughput rate in tons per
hour (tons/hr) and E is the allowable emission rate in pounds per hour (lbs/hr).
E = 4.10 * (P) 0.67 for P <= 30 tons/hr, or
E = 55 * (P)1.11.40 for P >30 tons/hr
4. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six -minute period, except that six -minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with 15A NCAC 21) .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
5. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee 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
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
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Permit No. 10396R00
Page 4
6. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .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 2D .0540(f).
"Fugitive dust emissions means particulate matter 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).
7. CONDENSER REQUIREMENTS -As required by 15A NCAC 2D .0611, the
Butyraldehyde Storage Tank (ID BS-A) and Butacite® Sheeting Extrusion Lines (ID BS-El
and BS-E2) odorous emissions shall be controlled as described in the permitted equipment
list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform periodic inspections and maintenance (I&M) as recommended by the
manufacturer. In addition, the Permittee shall perform an annual (for each 12 month
period following the initial inspection) inspection of each condenser system.
As a minimum, the I&M program and each annual inspection should include the
following:
i. inspection and maintenance of the structural integrity of each condenser,
including inspection for leakage of coolant and, if the system is under
positive gauge pressure, leakage of the contaminated gas stream. To
determine leakage of the coolant, the condensate shall be inspected for the
presence of coolant.
ii. inspection and maintenance of the structural integrity of duct work and piping
leading to and coming from each condenser.
b. Recordkeeping_Requirements - The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit (when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook.
The logbook (in written or electronic format) shall be kept on -site and made
available to DAQ personnel upon request.
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Permit No. 10396R00
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8. FABRIC FILTER REQUIREMENTS including cartridge filters baghouses, and other dry
filter particulate collection devices - As required by 15A NCAC 2D .0611, particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform, at a minimum, an annual (for each 12 month period following the
initial inspection) internal inspection of each bagfilter system. In addition, the
Permittee shall perform periodic inspections and maintenance as recommended by
the equipment manufacturer.
b. Recordkeoing Requirements - The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit (when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook.
The logbook (in written or electronic format) shall be kept on -site and made
available to DAQ personnel upon request.
9. SCRUBBER REQUIREMENTS -As required by 15A NCAC 2D .0611, the Butacite®
Flake Reactor (ID Nos. BS-13.1.1 through BS-13.1.4 and BS-8.2.1 through BS-B.2.4)
gaseous emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform periodic inspections and maintenance (I&M) as recommended by the
manufacturer. In addition, the Permittee shall perform an annual (for each 12 month
period following the initial inspection) internal inspection of each scrubber system.
As a minimum, the I&M program and each annual inspection should include the
following:
i. inspection of spray nozzles, packing material, chemical feed system (if so
equipped), and the cleaning/calibration of all associated instrumentation
annually.
b. Monitoring_ Requirements - The Permittee shall ensure the proper performance of
each scrubber by monitoring the following operational parameters:
i. The Permittee shall record the recycle liquid flow rate (range = minimum 8
gallons per minute averaged over a 3-hour period) ;
ii. The Permittee shall record the pressure drop across each scrubber (range =
maximum 30 inches of water averaged over a 3-hour period, with a high
differential pressure alarm) ;
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Permit No. 10396R00
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c. Recordkeeping Requirements - The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit (when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook.
The logbook (in written or electronic format) shall be kept on -site and made
available to DAQ personnel upon request.
10. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(MACT) 40 CFR 63 Subpart FFFF• NESHAP for Miscellaneous Organic Chemical
Manufacturing (MON). The Permittee shall comply with all applicable provisions,
including the notification, testing, recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111, "Maximum
Achievable Control Technology" as promulgated in 40 CFR 63, Subpart FFFF, including
Subpart A, "General Provisions".
a. Recordkeeping Requirements
i. For each affected MPCU with a Group 2 Process Vent, including the
Butacite® PVA Unloading System and Storage Silos (ID No. BS-F), the
Butacite® PVA Dissolving System (ID Nos. BS-G), the Butacite® Flake
Reactor System (ID Nos. BS-BI.l through BS-BIA and BS-B2.1 through
BS-B2.4), and the Butacite® Flake Dryer (ID No. BS-C), the Permittee shall
retain the following records:
A. A record of the day each batch was completed;
B. A record of whether each batch operated was considered a standard
batch;
C. The estimated uncontrolled and controlled emissions for each batch
that is considered to be a non-standard batch; and,
D. Records of the daily 365-day rolling summations of emissions, or
alternative records that correlate to the emissions (e.g., number of
batches), calculated no less frequently than monthly.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the
records listed above are not retained, or if the total HAP emissions from either
MCPU are 10,000 lbs or greater on a rolling 12-month basis. [40 CFR 63.2525(e)(4)]
ii. For each affected Group 2 wastewater stream, the Permittee shall retain the
following records:
A. MPCU identification and description;
B. Stream identification code;
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Permit No. 10396R00
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C. 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,
D. Stream flow rate (in L/min).
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the
records listed above are not retained. [40 CFR 63.2585(a), 40 CFR 63.147(b)(8)]
11. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" 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.
12. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee, facility -wide
emissions shall be less than the following:
u
N
�Iva,s a S ZYr'E8 °
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. As required by 15A NCAC 2D .0611, particulate matter emissions shall be
controlled as described in the permitted equipment list.
ii. The Permittee shall perform periodic inspections and maintenance of the
fabric filter per the requirements of the 15A NCAC 2D .0611 "Fabric Filter
Requirements" permit condition.
b. Recordkeeping Requirements
i. The Permittee shall record monthly and total annually the following:
A. The Permittee shall keep records of all maintenance and inspection
for the fabric filter per the requirements of the 15A NCAC 2D .0611
"Fabric Filter Requirements" permit condition.
c. Reporting Requirements - Within 30 days after each calendar year, regardless of the
actual emissions, the Permittee shall submit the following:
i. summary of all control device monitoring and recordkeeping activities
described above for the previous 12 months
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Permit No. 10396R00
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13. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - In accordance with 15A NCAC 2Q .0317, to comply with this permit
and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant
Deterioration," as requested by the Permittee, emissions shall be limited as follows:
Facility Wide PM10 100
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. Compliance with the Operations Restrictions, Recordkeeping Requirements,
and Reporting Requirements required under the 15A NCAC 2Q .0315
"Synthetic Minor Facilities" permit condition shall satisfy the requirements
under the 15A NCAC 2Q .0317 PSD Avoidance permit condition.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS TEST DATA MONITORING DATA NOTIFICATIONS, REQUESTS FOR
RENEWAL AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Fayetteville Regional Office
Systel Building
225 Green Street, Suite 714
Fayetteville, NC 28301-5094
910-433-3300
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203 (a), the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION -In accordance with 15A NCAC 2Q .0301, anew air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
DEQ-CFW 00065346

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Permit No. 10396R00
Page 9
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT -In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing. permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), 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 cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to, process weight rates, firing rates, hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
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Permit No. 10396R00
Page 10
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct, hamper, or interfere with any such 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.
13. In accordance with G.S. 143-215.108(c)(1), the Permittee must comply with any applicable
Federal, State, or Local requirements governing the handling, disposal, or incineration of
hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act
(RCRA) administered by the Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request, the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the _Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases - Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces, processes, handles, or stores any amount of a listed
hazardous substance, the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally -enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance, the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification, report submittal, and test
results approval.
Permit issued this the 26t' of August, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Steven F. Vozzo (i
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 10396R00
DEQ-CFW 00065348

ATTACHMENT to Permit No. 10396R00, August 26, 2014
IES-1
Plasticizer Storage Tank
68.000 -aallon capacity
Insignificant / Exempt Activities
1
2Q .0102 (c)(1)(L)(xii) No Yes
1. Because an activity is exempted from being required to have a permit or permit modification
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 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."
DEQ-CFW 00065349