HomeMy WebLinkAboutDEQ-CFW_00068286•
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North Carolina Department of Environment and Natural Resources
Division of Air Quality
Beverly Eaves Perdue, Governor
January 15, 2009
Ms. Karen B. Wrigley
Plant Manager
— E.I. du Pont de Nemours and Company
DBA, DuPont Company — Fayetteville Works
22828 NC Highway 87 West
Duart Township, North Carolina 28306-7332
Dear Ms. Wrigley
SUBJECT: Air Quality Permit No. 03 73 5T34
Facility ID: 0900009
E.I. du Pont de Nemours and Company
DBA, DuPont Company — Fayetteville Works
Duart Township
Bladen County
Fee Class: Title V
SIEVE VOZZO
FAYETTEVILLE
Dee Freeman, Secretary
B. Keith Overcash, P.E., Director
In accordance with your completed Air Quality Permit Application for a "l"-Part" significant modification
of a Title V permit pursuant to 15A NCAC 2Q .0501(c)(2) received December 9, 2008, we are forwarding
herewith Air Quality Permit No. 03735T34 to E.I. du Pont de Nemours and Company, Duart Township, 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 2Q .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.
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q
.0504 for the air emission source (ID No. FS-C) on or before 12 months after commencing operation.
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q
.0504 for the air emission sources (ID Nos. PS-C, NS-N, NS-O, and NS-P) on or before 12 months after
commencing operation.
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
Permitting Section
1641 Mail Service Center, Raleigh, North Carolina 27699-1641
2728 Capital Blvd., Raleigh, North Carolina 27604
Phone: 919-715-6235 / FAX 919-733-5317 / Internet: www.ncair.org
None
rthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00068286
Ms. Karen B. Wrigley
January 15, 2009
Page 2
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) 15013-23, and filed with both the Office of Administrative Hearings,
6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division of Air Quality, Permitting
Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Please note that
this permit will be stayed in its entirety upon receipt of the request for a hearing Unless a request for a hearing
is made pursuant to NCGS 15013-23, this Air Quality Permit shall be final and binding 30 days after issuance.
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or
issues for which the modification is sought. Please note that this Air Quality Permit will become final and binding
regardless of a request for informal modification unless a request for a hearing is also made under NCGS 15013-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction. Failure to do so is a violation of GS 143-215.108 and may subject the Permiee to civil or
criminal penalties as described in GS 143-215.114A and 143-215.114B.
This Air Quality Permit shall be effective from January 15, 2009 until January 31, 2009, 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 in, , piexse�contact Ms. Fern Paterson, P.E. at (919)
715-6242.
Chief
Enclosure
cc: JFayetteville Regional Office
Central Files
R. van der Vaart, Ph.D., P.E.
DEQ-CFW 00068287
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ATTACHMENT I:
C.—..— +n Urn<,in«c Pnrmil- (Nn (1272GT221
v uaaauasaa
—
Pa e s
Section
Descri Lion of Change(s)
N/A
Insignificant
Revise the description of the insignificant Abrasive Blasting Building (ID No. I-10)
Activity List
to indicate that the building may.also house occasional equipment aintin .
Global
Global
[Testing Requirement Citations] Change all references to 15A NCAC 2D .0501(c) to
15A NCAC 2D .2601 to be consistent with a recent rule change.
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
3-5
Section 1, Table
- Add natural gas firing capabilities to existing boilers (ID Nos. PS-1, PS-2, and
PS -Temp).
- Add new boiler (ID No. PS-Q.
- Add decontamination sources (ID Nos. NS-N, NS-O, and NS-P).
- Remove "Plus" from the SentryGlas® manufacturing operation (ID No. SBS-A).
- Add table footnote with modification procedural information.
6-10
Section 2. LA.
- Source Listing: Add natural gas firing capabilities to existing boilers (ID Nos. PS-
1, PS-2, and PS -Temp). Add new boiler (ID No. PS-Q.
- Table: Add 2D .0503 (PM) standard and NSPS De requirements (S02, visible
emissions) for new boiler. Add new boiler to the existing PSD avoidance
condition for S02.
- Section 2. LA. Lb - Add 2D .0503 (PM) standard for new boiler.
- Section 2.1.A.4. Add NSPS Dc requirements (S02, visible emissions) for new
boiler.
14-18
Section 2.1.C.
- Source Listing: Add decontamination sources (ID Nos. NS-N, NS-O, and NS-P).
- Table: Add a PSD Avoidance Condition (VOC) for HFPO decontamination
source (ID No. NS-N).
- Section 2.1.C.6. Add a PSD Avoidance Condition (VOC) for HFPO
decontamination source ID No. NS-N .
22
Section 2.1.G.
- Source Listing: Add natural gas firing capabilities to the boiler (ID No. PS -
Temp).
- Table: Add new boiler (ID No. PS-C) to the existing PSD avoidance condition for
Sol.
25
Section 2.1.H.
Source Listing: Remove "Plus" from the SentryGlas® manufacturing operation (ID
No. SBS-A).
27
Section 2.1.I.4.a.
Correct source ID No. from FL-C to FS-C.
28-29
Section 2.2.A.1
Revise existing PSD avoidance condition to include S02 emissions from the new
boiler and natural as combustion in the existing boilers.
DEQ-CFW 00068288
ATTACHMENT U:
Insignificant Activities Pursuant to 15A NCAC 20.0503(8)
Emission Source
ID No.
Emission Source Description
I-1
Polyvinyl fluoride vacuuming system for housekeeping purposes
1-2
Waste DMSO Storage Tank
I-3
Fugitive Emissions of Methylene Chloride
I-4
Chlorination of Riverwater to control mussel growth in equipment
I-5
Sitewide Laboratory Emissions
1-6
Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension
I-7
Paint shop
I-8
Self-contained abrasive blasting cabinets
I-9
Paint spray booths
I-10
Abrasive blasting and painting building
I-Bl
PVA Unloading System and Storage Silos
I-B2
PVA Dissolver Tank System
I-B7
Plasticizer storage tank
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 21) .1100, "Control of Toxic Air
Pollutants", or 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit".
DEQ-CFW 00068289
State of North Carolina,
Department of Environment, `
and Natural Resources��
Division of Air Quality NCDENR
AIR OUALITY PERMIT
Permit No.
I Replaces Permit No.
Effective Date
Expiration Date
03735T34
103735T33
January 15, 2009
January 31, 2009
Until such time as this permit expires or is modified or revoked, the below named Permittee is permitted to construct and
operate the emission source(s) and associated air pollution control device(s) specified herein, in accordance with the terms,
conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B of Chapter 143,
General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes (15A NCAC),
Subchapters 21) and 2Q, and other applicable Laws.
Pursuant to Title 15A.NCAC, Subchapter 2Q, 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: E.I. du Pont de Nemours & Co., LLC
DBA, DuPont Company - Fayetteville Works
Facility ID: 0900009
Facility Site Location: 22828 NC Highway 87 W
City, County, State, Zip: Duart Township, Bladen County, NC, 28306-7332
Mailing Address: 22828 NC Highway 87 W
City, State, Zip: Fayetteville, NC, 28306-7332
Application Number: 0900009.08AD
Complete Application Date: December 9, 2008
Primary SIC Code: 2821, 3081, 3083
Division of Air Quality, Fayetteville Regional Office
Regional Office Address: 225 Green Street, Suite 714
Fayetteville, NC 28301
Pe issued this theA5th day of January, 2009
onigi4er Vaart, Ph.D., P.E., CI'iief, Air Permits Section
n
y Authority of the Environmental Management Commission
DEQ-CFW 00068290
Table 0 Contents
SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1- Emission Source(s) Specific Limitations and Conditions (Including specific
requirements, testing, monitoring, recordkeeping, and reporting requirements)
2.2- Multiple Emission Source(s) Specific Limitations and Conditions (Including
specific requirements, testing, monitoring, recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
DEQ-CFW 00068291
Permit 03735T34
Page 3
The Division of Air Quality (DAQ), the United States Environmental Protection Agency (EPA), and citizens as defined under the
Federal Clean Air Act have the authority to enforce the terms, conditions, and limitations contained in this pen -nit unless otherwise
specified.
Under Title 15A NCAC 2Q, the operation of emission source(s) and associated air pollution control device(s) and appurtenances
listed in this permit is based on plans, specifications, operating parameters, and other information as submitted in the Air Quality
Permit Application.
SECTION I - PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICES) AND APPURTENANCES
'M fMl -,;na c„mm—, of A narmitterl emk6m snnrce.c and associated air pollution control devices:
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
PS-12
Natural Gas/No. 2 fuel oil/No. 6 fuel oil-
N/A
N/A
fired boiler (139.4 million Btu per hour
maximum heat input)
PS-22
Natural Gas/No. 2 fuel oil No. 6 fuel oil-
N/A
N/A
fired boiler (88.4 million Btu per hour
maximum heat input)
PS-C2
Natural Gas/No. 2 fuel oil -fired boiler (97
N/A
N/A
NSPS Dc
million Btu per hour maximum heat
input) equipped with a low-NOx burner
PS -Tempe
Natural Gas/No. 2 fuel oil -fired boiler
N/A
N/A
NSPS De
(greater than 30.0 and less than 100.0
million Btu per hour maximum heat
in ut
BS-A
Butyraldehyde storage tank
BCD -A
Brine -cooled condenser
BS-B 1.1
Butacite® polyvinyl butyral flake reactors
BCD-B 1
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B 1.4
injection rate averaged over a 3-hour
period) state -enforceable only)
BS-B2.1
Butacite polyvinyl butyral flake reactors
BCD-B2
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B2.4
injection rate averaged over a 3-hour
eriod state -enforceable only)
BS-C
Butacite polyvinyl butyral flake dryer
BCD-Cl
Cyclone separator
BCD-C2
Fabric filter (6,858 square feet of filter
area
BS-El
Butacite Line No. 3 Sheeting Extrusion
BCD -El
Water -Cooled Condenser (voluntary
Process including four 4 extruders
use only)
BS-E2
Butacite® Line No. 4 Sheeting Extrusion
BCD-E2
Water -Cooled Condenser (voluntary
Process includin four 4 extruders
use only)
BS-E3
Butacite® Line No. 3 Back -End
N/A
N/A
Processes, including a quencher,
dryer/relaxer, and wind-up area
BS-E4
Butacite® Line No. 4 Back -End
N/A
N/A
Processes, including a quencher,
dryer/relaxer, and wind-up area
DEQ-CFW 00068292
Permit 03735T34
Page 4
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
BS-D
Butacite Polyvinyl butyral sheeting
BCD-D1
Multi -stage horizontal spray scrubber (6
MACT KK
rotogravure printing operation
gallons per minute of water flow to each
nozzle averaged over a 3-hourperiod)
NS-A
Nafion® Hexfluoropropylene epoxide
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
process (HFPO)
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-B
Nafion® Vinyl Ethers North process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-C
Nafion® Vinyl Ethers South process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaized over a 3-hourperiod)
NS-D
Nafion® RSU Process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-E
Nafion® Liquid waste stabilization
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hour eriod
NS-F
Nafion® MMF process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
avera ed over a 3-hour period
NS-G
Nafion® Resins process
NCD-G
Venturi vacuum jet caustic scrubber
MACT FFFF
NS-H
Nafion® membrane process
N/A
N/A
MACT FFFF
DEQ-CFW 00068293
Permit 03735T34
Page 5
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
NS-I
Nafion® membrane coating
N/A
N/A
MACT FFFF
NS-J
Nafion® semiworks
N/A
N/A
MACT FFFF
NS-K
Nafion® E-2 Process
N/A
N/A
MACT FFFF
NS-L
Nafion® TFE/HCl separation unit
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-M
Nafion® TFE/CO2 separation process
N/A
N/A
NS-N2
HFPO product container decontamination
N/A
N/A
rocess
NS-02
Vinyl Ethers North product container
N/A
N/A
decontamination process
NS-P2
Vinyl Ethers South product container
N/A
N/A
decontamination process
SW-1
Semiworks polymerization operation
N/A
N/A
SW-2
Semiworks laboratory hood
N/A
N/A
FS-A
Fluoroproducts polymer manufacturing
FCD-Al
Wet scrubber (3 gallons per minute
development facility
water injection rate averaged over a 3-
hour period) (nominal injection rate)
Fabric filter (125 square feet of filter
FCD-A2
area
AS -A
APFO Manufacturing Facility
ACD-Al
Wet scrubber (30 gallons per minute
water injection rate averaged over a 3-
hour period) (state -enforceable only)
Wet scrubber installed on the building
ACD-A3
exhaust vent(voluntary use only)
WTS-A
Extended aeration biological wastewater
N/A
N/A.
treatment facility
WTS-B,
Two (2) Indirect steam -heated, rotary
WTCD-1
Impingement -type wet scrubber with
WTS-C
slud e drvers
mist eliminator state -enforceable only)
SGS-A
SentryGlas 0 Manufacturing
N/A
N/A
FS-B
Polyvinyl Fluoride Manufacturing
N/A
N/A
Facilitv No.I
FS-C'
Polyvinyl Fluoride Manufacturing
N/A
N/A
FacilitV No.2
This emission source (ID No. FS-C) is listed as a 15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality
Permit Application on or before 12 months after commencing operation in accordance with General Condition NN.1. The permit shield
described in General Condition R does not apply and compliance certification as described in General Condition P is not required.
These emission sources (ID Nos. PS-1, PS-2, PS-C, PS -Temp, NS-N, NS-O, and NS-P) are listed as a 15A NCAC 2Q .0501(c)(2)
modification. The Permittee shall file a Title V Air Quality Permit Application on or before 12 months after commencing operation in
accordance with General Condition NN.1. The permit shield described in General Condition R does not apply to the new and modified
conditions and compliance certification as described in General Condition P is not required.
DEQ-CFW 00068294
Permit 03735T34
Page 6
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 -Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s) and appurtenances listed below are subject to the
following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting
requirements as specified herein:
A. Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-1)2, 139.4 million Btu per hour
maximum heat input,
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-2)2, 88.4 million Btu per hour
maximum heat input, and
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-Q equipped with a low-NOx burner, 97
million Btu per hour maximum heat input.
•rn__ r_ii_ _Li_ _ .. a,.,. ,. ,.F 1:«,; r.. ,,„,] ..t....,7.,r.7� F .- rt,o 0 0l�1 .]o ,-;hA.i ohn
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Sources: PS-1, PS-2
15A NCAC 2D .0503
0.2667 pounds particulate per million Btu heat input
Affected Sources: PS-C
0.2268 pounds Diirticulate per million Btu heat in -put
Sulfur dioxide
Affected Sources: PS-1, PS-2
15A NCAC 2D .0516
2.3 pounds S02 per million Btu heat in -put, each
Sulfur dioxide
Affected Source: PS-C
15A NCAC 2D .0524
No. 2 fuel oil sulfur content shall not exceed 0.5% by weight.
40 CFR 60 Subpart DO
Visible emissions
Affected Source: PS-1
15A NCAC 2D .0521(c)
40 percent opacity
Affected Source: PS-2
15A NCAC 2D .0521(d)
20 Dercent opacity
Visible emissions
Affected Source: PS-C
15A NCAC 2D .0524
20 percent opacity
40 CFR 60 Subpart Dc
PM, PM-10, NO,,, and
Affected Source: PS-2
15A NCAC 2Q .0317
SO2
Particulate matter <25 tons per year.
(PSD Avoidance)
Particulate matter under 10 micron <15 tons per year.
Nitrogen oxide <40 tons per year.
Sulfur dioxide <40 tons per year.
Sulfur dioxide
Affected Sources: PS-1, PS-2, PS-C, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
(PSD Avoidance)
See Section 2.2. A.1. of this permit
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil/No. 6 fuel oil, that are discharged from the
affected boilers (ID Nos. PS-1 and PS-2) into the atmosphere shall not exceed 0.2667 pounds per million Btu heat
input.
b. Emissions of particulate matter from the combustion of 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 Btu heat input.
Testing [15A NCAC 213.2601]
c. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
DEQ-CFW 00068295
Permit 03735T34
Page 7
this test are above the limits given in Section 2.1 A.1.a. and/or b. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0503.
Monitoring/Recordkeelling/Reo}�rting [15A NCAC 2Q .0508(f)]
d. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 or No. 6 fuel oil
in these sources.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from the affected boilers (ID Nos. PS-1 and PS-2) 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.
T s in [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ found in Section 3. If the results of this test are above the limit given in Section 2.1 B. La. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeening [15A NCAC 2Q .0508(f) and 15A NCAC 2D .0501(c)(4)(A)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from No. 2 fuel oil burned in these sources.
d. The maximum sulfur content of any No. 6 fuel oil received and burned in the boiler shall not exceed 2.1 percent by
weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the fuel
oil exceeds this limit.
e. To assure compliance, the Permittee shall monitor the sulfur content of the No. 6 fuel oil by using fuel oil supplier
certification per shipment received. The results of the fuel oil supplier certifications shall be recorded in a logbook
(written or electronic format) on a quarterly basis and include the following information:
i. The name of the fuel oil supplier;
ii. The maximum sulfur content of the fuel oil received during the quarter;
iii. The method used to determine the maximum sulfur content of the fuel oil; and
iv. A certified statement signed by the responsible official that the records of fuel oil supplier certification submitted
represent all of the No. 6 fuel oil fired during the period.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the oil is not
monitored and recorded.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the fuel oil supplier certifications 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.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected boiler (ID No. PS-1) 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-2) 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.
DEQ-CFW 00068296
Permit 03735T34
Page 8
Testing [15A NCAC 2D .2601]
c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 A.3.a. or .b above; the Permittee shall
be deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
d. To assure compliance, each day that an affected source fires No. 6 fuel oil, the Permittee shall observe the emission
point of the affected source for any visible emissions above normal. The daily observation must be made for each
day of the calendar year period to ensure compliance with this requirement. The Permittee shall be allowed three (3)
days of absent observations per semi-annual period. If visible emissions from this source are observed to be above
normal, the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 A.3.a. or b. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
R .ecordkeening [15A NCAC 2Q .0508(f)]
The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Monitoring/Recordkeeping/Re on rting [15A NCAC 2Q .0508(f)]
No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas or No. 2 fuel
oil in these sources.
Reporting [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit a summary report of the observations 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.
4. 15A NCAC 2D .0524: New Source Performance Standards (40 CFR 60, Subpart Dc)
a. For the affected boiler (ID No. PS-C), 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 Subpart A, "General Provisions." [15A NCAC 02D .0524]
Emission Limitations [15A NCAC 2D .0524]
b. The maximum sulfur content of any fuel oil received and fired in the affected boiler (ID No. PS-C) shall not exceed
0.5 percent by weight. [40 CFR 60.42c(d)]
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, except for one six -minute period per hour of not more than 27 percent opacity. [40 CFR
60.43c(c)]
DEQ-CFW 00068297
Permit 03735T34
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Tes in¢ [15A NCAC 2D .2601]
d. Within 60 days after achieving the maximum firing rate at the affected boiler (ID No. PS-C), but not later than 180
days after initial startup, the Permittee shall conduct a Method 9 test (6-minute average of 24 observations) to
determine the opacity of stack emissions in accordance with 40 CFR 60.45c(a)(8) and 40 CFR 60.8. All testing
notifications and reports shall be submitted in accordance with General Condition JJ of this permit. If the Permittee
fails to conduct the opacity observation or if the results of the test are above the applicable limit, the Permittee shall
be deemed in noncompliance with 15A NCAC 2D .0524. [40 CFR 60.45c(a)(8)]
Monitoring/Recordkee in [15A NCAC 2Q .0508(f)]
e. The Permittee shall retain a record of the quantity of natural gas and No. 2 fuel oil fired at the affected boiler (ID No.
PS-C) each calendar month. The Permittee shall be deemed.in noncompliance with 15A NCAC 2D .0524 if this
record is not created and retained. [49 CFR 60.48c(g)]
f. The Permittee shall retain a copy of the fuel supplier certification for any No. 2 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 Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur content of the oil exceeds
the limit provided in Section 2.1.AA.b. of this permit or if fuel supplier certifications are not retained as described
above. [40 CFR 60.46c(e), 40 CFR 60.48c(flJ
Initial Notification [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit 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)(1)J
h. The Permittee shall submit an initial notification to the Regional Supervisor within 15 days of actual startup of the
affected boiler (ID No. PS-C). 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)J
Reporting [15A NCAC 2Q .0508(f)]
The Permittee shall submit a semiannual summary report, acceptable to the Regional Air Quality Supervisor, of the
sulfur content of the distillate fuel oil fired, by 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 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;
ii. A certified statement signed by the owner or operator 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; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068298
Permit 03735T34
Page 10
5. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the affected
boiler (ID No. PS-2 only) shall discharge into the atmosphere less than the following, per consecutive 12-month
period.
Pollutant
Emission Limitation
tons per vear
Particulate Matter
25
Particulate Matter under 10 microns
15
Nitrogen Oxide
40
Sulfur Dioxide
40
Testing [15A NCAC 2Q .2601]
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., the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly accounting records of the amount of fuel used and the sulfur content, including
certification of the fuel, in a logbook (written or in electronic format). The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the sulfur content of the fuel is not monitored.
Rerting [15A NCAC 2Q .0508(f)]
d. 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 particulate matter, particulate matter below 10 microns, nitrogen oxide, and sulfur dioxide
emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over
the previous 17 months;
ii. The monthly quantities of natural gas/No. 2 fuel oil/No. 6 fuel oil consumed for the previous 17 months;
iii. The average sulfur content for the fuel oil; and,
iv. All instances of deviations from the requirements of this permit must be clearly identified.
B. Butacite® Process Area consisting of one butyraldehyde storage tank (ID No. BS-A)
controlled by a brine cooled condenser (ID No. BCD -A),
Four Butacite® flake reactors (ID Nos. BS-B1.1 through BS-B1.4) controlled by a packed -
bed scrubber (ID No. BCD-B1),
Four Butacite® flake reactors (ID Nos. BS-B2.1 through BS-B2.4) controlled by a packed -
bed scrubber (ID No. BCD-B2),
One Butacite® flake dryer (ID No. BS-C) controlled by a cyclone (ID No. BCD-Cl) and
fabric filter (ID No. BCD-C2) and,
Butacite Line No. 3 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-El)
controlled by a water-cooled condenser (ID No. BCD -El) (voluntary use only)
Butacite° Line No. 4 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-E2)
DEQ-CFW 00068299
•
Permit 03735T34
Page 11
controlled by a water-cooled condenser (ID No. BCD-E2) (voluntary use only)
Butacite° Line No. 3 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area (ID No. BS-E3)
Butacite° Line No. 4 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area (ID No. BS-E4)
One polyvinyl butyral sheeting rotogravure printing operation (ID No. BS-D) controlled by
one multi -stage horizontal spray scrubber (ID No. BCD -DI).
IM,. 4;.11,... '__ r 1,10 ...-...,;A n, of lim;tc —A of—AnrAc fnr ilia gmiCCinn cnilr( ek) de.qCribed above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Source: BS-C, only
15A NCAC 2D .0515
for process rates less than 30 tons per hour -
E=4.10xP"'7
Where:
E = allowable emission rate in pounds per hour, and
P = the process weight rate in tons per hour
Visible emissions
Affected Source: BS-C, only
15A NCAC 2D .0521
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled.
Organic HAP
Affected Source: BS-D, only
15A NCAC 2D .I I I I
National Emission Standards for Hazardous Air
(40 CFR 63, Subpart KK)
Pollutants Printing and Publishing Industry
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. BS-C) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xP0.67
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 2D .2601]
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 B.1.a. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/RecnrdkeP inu [15A NCAC 2Q .0508(f)]
Particulate matter emissions from the Butacite flake dryer (ID No. BS-C) shall be controlled by the bagfilter (ID
No. BCD-C2) and cyclone separator (ID No. BCD-Cl). To assure 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 is 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 internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and bagfilters are not
inspected and maintained.
DEQ-CFW 00068300
Permit 03735T34
Page 12
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on -site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bagfrlters; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained.
Reor in [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfrlters within 30 days of a written
request by the DAQ.
f. The Pernittee shall submit a 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. BS-C) 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 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 B.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. If visible emissions from this source are observed to be above normal,
the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 13.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
RRecordkee in [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
DEQ-CFW 00068301
Permit 03735T34
Page 13
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.
STATE-FNFORCEABTY ONT,Y
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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. CONDENSER REQUIREMENTS - Odorous emissions from the butyraldehyde storage tank (ID No. BS-A) shall
be controlled by a condenser (ID No. BCD -A). To comply with the provisions of this Permit and ensure that
maximum control efficiency is maintained, the Permittee shall perform periodic inspections and maintenance as
recommended by the manufacturer. The results of the inspections and maintenance shall be recorded in a logbook
(either written or electronic).
c. SCRUBBER REQUIREMENTS -Gaseous emissions from the Butacite flake reactor line (ID Nos. BS-B1.1
through BS-B1.4) shall be controlled by packed column scrubber (ID No. BCD-B1). Gaseous emissions from the
Butacite® flake reactor line (ID Nos. BS-B2.1 through BS-B2.4) shall be controlled by packed column scrubber (ID
No. BCD-B2).
d. INSPECTION AND MAINTANENCE REQUIREMENTS - To comply with the provisions of this Permit and
ensure that maximum control efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the 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/calibration of all associated instrumentation.
e. MONITORING REQUIREMENTS - The Permittee shall ensure the proper performance of the Flake Reactor
Line's packed column scrubbers (ID Nos. BCD-B1 and BCD-B2) by monitoring the following operational
parameters:
i. Liquid flow rate (minimum of 8 gallons per minute averaged over a 3-hour period), and
ii. Differential pressure across the scrubber (maximum of 30 inches of water pressure averaged over a 3-hour
period), with a high differential pressure alarm.
f. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections 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. 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.
4. 15A NCAC 2T) 1111 • MAXIMUM AVAILABLE F CONTROI. TECHNOLOGY (40 CFR 63, Suhpart KK:
Printing and Publishing Industry)
For the polyvinyl butyral (Butacite ) sheeting rotogravure printing operation (ID No. BS-D), the Permittee shall comply
with all applicable provisions, including the notification, testing, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111 as promulgated in 40 CFR 63, Subpart KK,
including Subpart A "General Provisions" except as follows:
"Oxidizer" referenced in 40 CFR Part 63.820 through 63.831 shall refer to scrubber (ID No. BCD-Dl) and shall require
the operation and maintenance of devices to monitor water flow rate and air flow rate (used in dispersion of water in the
scrubber) for the scrubber (ID No. BCD -DI) in lieu of a temperature monitoring device for an oxidizer.
DEQ-CFW 00068302
•
Permit 03735T34
Page 14
Control Requirements [15A NCAC 2Q .0508(f)]
a. Emissions from the polyvinyl butyral sheeting rotogravure printing operation shall be controlled using a permanent
total enclosure for the process area and a multi -stage horizontal spray scrubber (ID No. BCD -DI) that achieves an
overall organic HAP control efficiency of at least 95 percent.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
b. The Permittee shall ensure the proper performance of the scrubber (ID No. BCD-Dl) by monitoring the following
operational parameters:
i. Water flow rate to each nozzle (minimum of 6 gallons per minute, averaged over a three-hour period).
ii. Air flow rate to each nozzle (minimum of 63 standard cubic feet per minute, averaged over a three-hour period).
iii. General area exhaust fan exit velocity (minimum of 3,950 feet per minute, averagdd over a three-hour period).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the required monitoring is not
conducted or if the monitored parameter exceeds the minimum value.
Record keeping/R r in [15A NCAC 2Q .0508(f)]
c. The Permittee shall comply with all applicable record keeping and reporting requirements specified in 40 CFR Parts
63.829 and 63.830, and in 40 CFR Part 63 Subpart A - General Provisions, including the following reporting
requirements:
i. As specified in 40 CFR Part 63.6(e)(3)(iv), if an action taken by the Pern e during a startup, shutdown, or
malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified
in the affected source's startup, shutdown, and malfunction plan, the Permittee shall record the actions taken for
that event and shall report such actions within 2 working days after commencing actions inconsistent with the
plan, followed by a letter within 7 working days after the end of the event, in accordance with 40 CFR Part
63.10(d)(5).
ii. The Permittee shall submit to the Regional Supervisor, DAQ, a semi-annual summary report as specified in 40
CFR Part 63.830, by January 30 of each calendar year for the preceding six-month period between July and
December, and by July 30 of each calendar year for the preceding six-month period between January and June.
iii. If the actions taken by the Permittee during start-up, shutdown, or malfunction (SSM) are not completely
consistent with the procedures specified in the SSM plan, then the Permittee shall submit an SSM report, as
specified in 40 CFR 63.830, to the Regional Supervisor, DAQ. However, separate SSM reports are not required
if the information is included in the semi-annual summary report specified above in Section 2.1. BA.c.i.
C. Nafion® Process Area consisting of one hexfluoropropylene epoxide process (ID No. NS-A)
controlled by one baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2),
Two vinyl ethers processes (ID Nos. NS-B and NS-C) EACH controlled by one of two available
baffle -plate scrubbers (ID No.-NCD-Hdrl or NCD-Hdr2),
One RSU process (ID No. NS-D) controlled by one baffle -plate scrubber (ID No. NCD-Hdrl or
NCD-Hdr2),
One liquid waste stabilization process (ID No. NS-E) controlled by one baffle -plate scrubber
(ID No. NCD-Hdrl or NCD-Hdr2),
One MMF process (ID No. NS-F) controlled by one baffle -plate scrubber (ID No. NCD-Hdrl
or NCD-Hdr2),
One resins fluorination process (ID No. NS-G) controlled by a venturi vacuum jet scrubber (ID
No. NCD-G),
One Nafion® membrane process (ID No. NS-H),
One Nafion® membrane coating process (ID No. NS-I),
Three Nafion° semiworks processes (ID Nos. SW-1, SW-2, and NS-J),
One E-2 Process (ID No. NS-K),
DEQ-CFW 00068303
Permit 03735T34
Page 15
One TFE/HCl separation unit (ID No. NS-L) controlled by one baffle -plate scrubber (ID No.
NCD-Hdrl or NCD-Hdr2), and
One uncontrolled TFE/CO2 separation unit (ID No. NS-M)
One HFPO product container decontamination process (ID No. NS-N)2
One Vinyl Ethers North product container decontamination process (ID No. NS-O)2
One Vinyl Ethers South product container decontamination process (ID No. NS-P)2
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Sources: ID No. NS-I, only
15A NCAC 2D .0515
For process rates less than 30 tons per hour -
E = 4.10 P0.67
where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons iper hour
Visible emissions.
Affected Sources: ID No. NS-I, only
15A NCAC 2D .0521
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
Toxic air pollutants
State -enforceable only
15A NCAC 2D .1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2. B.1. and B.2.
Volatile organic
Affected Sources: ID No. NS-B, only
15A NCAC 2Q .0317
compounds
VOC emissions <68.9 tons per consecutive 12-month
(PSD Avoidance)
period
Affected Sources: ID No. NS-G, only
VOC emissions <40 tons per consecutive 12-month
period
Affected Sources: ID No. NS-A, only
VOC emissions <85.3 tons per consecutive 12-month
period
Affected Sources: ID No. NS-N, only
VOC emissions <40 tons per consecutive 12-month
eriod
Hazardous air
Affected Sources: All, excluding ID No. NS-L
15A NCAC 2D .1111
pollutants
through NS-P
(40 CFR 63, Subpart FFFF)
Miscellaneous Organic NESHAP MON
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. NS-I) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xPO-"
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.
DEQ-CFW 00068304
Permit 03735T34
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Testing [ 15A NCAC 2D .2601 ]
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. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Mon itoring/Recordkeeping [15A NCAC 2Q .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 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515 if the production records are not maintained or the types of materials and finishes are not
monitored.
Re or in [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. NS-I) 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 [15ANCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and 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 2D .0521.
Monitoring�ecordk a ing/R . or inu [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATF,-ENFORC'F.ARTY ONI.V
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, 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.
Monitoring/Recordkee inu [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
DEQ-CFW 00068305
Permit 03735T34
Page 17
Monitoring [15A NCAC 2Q .0508(f)]
The Permittee shall ensure the proper performance of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-1 and NCD-Hdr-2) by monitoring the following operational parameters:
i. Injection liquid flow rate (minimum of 7,000 kilograms per hour, averaged over a three-hour period).
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The Permittee shall record the results of inspections in a scrubber logbook (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.
Reporting [I5A NCAC 2Q .0508(f)]
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 VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
5. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the resins process (ID No. NS-G) shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Monitoring/Recordkeening [15A NCAC 2Q .0508(f)]
Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic
format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed
this limit.
Reporting [I5A NCAC 2Q .0508(f)]
d. 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 VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
6. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the HFPO process (ID No. NS-A) shall discharge into the
atmosphere less than 85.3 tons of VOCs per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
DEQ-CFW 00068306
Permit 03735T34
Page 18
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. 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 VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
6. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, 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.
Monitoring/Record kee inn [15A NCAC 2Q .0508(f)]
b. To demonstrate compliance with the limit provided in Section 2.1 C.6.a., each calendar month the Permittee shall
create and retain records and estimate associated VOC emissions, 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 lbs).
ii. Calculate the VOC emissions from the process during the previous calendar month (in lb/month) by summing
the quantity of VOC released from each container decontaminated during the previous calendar month.
iii. Calculate the VOC emissions from the process during the previous consecutive 12-month period (in tons/12-
months) by summing the quantity of VOC released for the previous twelve (12) calendar months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made available to an
authorized representative upon request. The Perrriittee shall be deemed in noncompliance with 15A NCAC 2D .0530
if the above 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.6.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
c. 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 3.0 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 for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
7. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MALT),
40 CFR 63, Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing (MON)
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Standard 15A NCAC 2D .1111, "Maximum Achievable Control Technology" (MACT) as promulgated in 40 CFR Part
63, Subpart FFFF by May 10, 2008, or as provided in the rule. [40 CFR 63.2445(b)]
b. The Permittee shall submit a Notification of Compliance Status to the Fayetteville Regional in accordance with 40
CFR 63.2520(d) by October 7, 2008, or as provided in the rule.
DEQ-CFW 00068307
9
Permit 03735T34
Page 19
D. Fluoroproducts polymer manufacturing development facility (ID No. FS-A) controlled by a
wet scrubber (ID No. FCD-Al) and fabric filter (ID No. FCD-A2)
r.,k.lo .. .,;A o of limitc nnrl ctnnrlarrlc fnr the RmicSinn snnrcek) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
For process rates less than 30 tons per hour
15A NCAC 213.0515
E = 4.10 P0.67
Where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons j2er hour
Visible emissions
20% visible opacity emissions
15A NCAC 2D .0521
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
Volatile organic
Less than 40 tons per consecutive 12-month period
15A NCAC 2Q .0317
compounds
(PSD Avoidance
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. FS-A) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xP""
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 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JL If the results
of this test are above the limit given in Section 2.1 D. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkeening [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the Fluoroproducts polymer manufacturing facility (ID No. FS-A) shall be
controlled by the bagfilter (ID No. FCD-A2). To assure 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 is 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 internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and bagfilters are not
inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on -site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bagfilters; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained.
DEQ-CFW 00068308
Permit 03735T34
Page 20
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 days of a written
request by the DAQ.
f. The Permittee shall submit a 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID Nos. FS-A) 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 2D .2601]
If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 E.l.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reon rting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATE. ENFORCEABLE, ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the fluoroproducts polymer manufacturing development facility (ID
No. FS-A) shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. 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 VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
DEQ-CFW 00068309
Permit 03735T34
Page 21
E. APFO manufacturing facility (ID No. AS -A) controlled by a wet scrubber (ID No. ACD-Al)
and a building exhaust vent wet scrubber (ID No. ACD-A3) (voluntary use only)
The followin table rovides a summary of limits and standards for the emission sources described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
15A NCAC 2D .1806
odorous emissions must be controlled
Toxic air pollutants
State -enforceable only
15A NCAC 2D .1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2.A and B.
STATE -ENFORCEABLE ONLY
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
STATE-ENFORCEABIX ONLY
2. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. SCRUBBER REQUIREMENTS - Gaseous and mist emissions from the APFO process area 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
ii. 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.
b. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (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.
F. 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)
-N.- r nn.,.;_ +mot iP r .,;Av o ry of 1;mite an`l ctnn(larflC fnr the P.MiRRiOn Rnur( elR) (le.Rerlbed above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
odorous emissions must be controlled
15A NCAC 2D .1806
STATE, ENFORCEABLE ONT,V
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
DEQ-CFW 00068310
Permit03735T34
Page 22
b. SCRUBBER REQUIREMENTS - 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).
c. INSPECTION AND MAINTANENCE REQUIREMENTS - To comply with the provisions of this Permit and
ensure that maximum control efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the 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/calibration of all associated instrumentation.
d. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections 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. 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.
G. Temporary Boiler (ID No. PS -Temp), Natural Gas/No. 2 fuel oil -fired (greater than 30.0 and
less than 100.0 million Btu per hour maximum heat input)
The fnllnwinu table nrnvides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulations
Particulate Matter
0.2426 pounds of particulate per million Btu
15A NCAC 2D .0503(c)
Sulfur Dioxide
0.5 percent sulfur content fuel
15A NCAC 2D .0524
NSPS 40 CFR 60 Sub art DO
Visible Emissions
20 percent opacity
15A NCAC 2D .0524
NSPS 40 CFR 60 Sub art Dc
Sulfur Dioxide
Less than 40 tons per consecutive twelve-month period.
15A NCAC 2Q .0317
PSD Avoidance
Sulfur Dioxide
Affected Sources: PS-1, PS-2, PS-C, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
(PSD Avoidance)
See Section 2.2. A.1. of this permit
1. 15A NCAC 2D .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 at the
temporary boiler (ID No. PS -Temp) shall not exceed 0.2426 pounds per million Btu heat input.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
this test are above the limit given in Section 2.1 G.l.a. above, the Permittee shall be deemed in noncompliance with
15A NCAC 2D .0503.
Monitoring/Recordkeeping/Re on rting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 fuel oil in this
source for this regulation.
2. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART De
a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and
DEQ-CFW 00068311
0
•
Permit 03735T34
Page 23
monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524
"New Source Performance Standards (NSPS) as promulgated in 40 CFR Part 60 Subpart Dc, including Subpart A
"General Provisions."
Emission Limitations [15A NCAC 2D .0524]
b. The maximum sulfur content of any fuel oil received and burned in the boiler (ID No. PS -Temp) shall not exceed
0.5 percent by weight.
c. Visible emissions shall not exceed 20 percent opacity (6 minute average) except for one six -minute period per hour
but not more than 27 percent opacity when firing fuel oil.
T .s in¢ [15A NCAC 2D .0524]
d. Within 60 days of installing any temporary boiler, the Permittee shall conduct a Method 9 test (6-minute average of
24 observations) to determine the opacity of stack emissions in accordance with 40 CFR 60.8, 40 CFR 60.45c(a)(8),
and General Condition JJ found in Section 3 of this permit. If the Permittee fails to conduct the opacity observation
or if the results of the test are above the applicable limit, the Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0524.
Monitorin /Recordkeeping [15A NCAC 2Q .0508(f)]
e. The Permittee shall retain a record of the quantity of natural gas and No. 2 fuel oil fired at the affected boiler each
calendar month. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if this record is not
created and retained. [49 CFR 60.48c(g)]
f. The Permittee shall retain a copy of the fuel supplier certification for any No. 2 fuel oil fired at the affected boiler.
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 Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur content of the oil exceeds
the limit provided in Section 2.1 G.2.b. of this permit or if fuel supplier certifications are not retained as described
above. [40 CFR 60.46c(d), 40 CFR 60.48c6q]
Notifications and Re or iag [15A NCAC 2Q .0508(f)]
The Permittee shall submit the following written notifications to the Regional:
i. An initial notification of the date of actual initial startup of the boiler within 15 days of such date [40 CFR
60.7(a)(1)];
ii. An opacity observation notification indicate the anticipated date that the Permittee will be conducting the
Method 9 opacity observation, as required in Section 2.1 G.2.d. of this permit, at least 30 days prior to such date
[40 CFR 60.7(a)(6), 40 CFR 60.8(d)]; and,
iii. Performance test results with the results of the Method 9 opacity observation, as required in Section 2.1 G.2.d.
of this permit, shall be submitted within 30 days of the test.
h. Semiannual Report. In addition to any other reporting required by 40 CFR 60.48c or notification requirements to
the EPA, the Permittee is required to provide a semiannual summary report, acceptable to the Regional Air Quality
Supervisor, of the sulfur content of the distillate fuel oil fired, by 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 summary report shall include the following information:
i. Fuel supplier certification(s) for distillate fuel oil, as provided in Section 2.1 G.2.d. of this permit;
ii. A certified statement signed by the owner or operator that the records of fuel supplier certification(s) submitted
represents all of the fuel fired at the affected boiler during the semiannual period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068312
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Permit 03735T34
Page 24
3. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the temporary
boiler (ID No. PS -Temp) shall discharge into the atmosphere less 40 tons of sulfur dioxide per consecutive twelve-
month period.
T s ins [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A General Condition JJ. If the
results of this test are above the limits given in Section 2.1 G.3.a. (ID No. PS -Temp) above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordk in [15A NCAC 2Q .0508(f)]
The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in 1,000 gal) of No. 2 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 2D .0530 if records of the fuel usage and No.
fuel oil sulfur content are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling S02 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 S02 emissions from the previous calendar month using the following equation:
E S02 = 142 * S * Qfo2
Where, Es02 = S02 emissions (in lbs) during the previous calendar month,
S = Sulfur content in the No. 2 fuel oil (in percent by weight), and
Qfo2 = Quantity of No. 2 fuel oil fired at the temporary boiler during the
previous calendar month (in 1,000 gal)
ii. Sum the S02 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 2D .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 G.3.a. of this permit.
Reor inn [15A NCAC 2Q .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 boiler for the previous 17 months;
ii. The total S02 emissions from the boiler for each 12-month period ending during the six month reporting period;
and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068313
Permit 03735T34
Page 25
H. SentryGlas® Manufacturing (ID No. SGS-A)
r�t,tP .. .,;tips o aw of limits anti ctanrl%rrlc fnr the P.mi z6on 'Zourcek) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Visible emissions
20% visible opacity emissions
15A NCAC 213.0521
Odors
State -enforceable only
Odorous emissions must be controlled
15A NCAC 2D. 1806
1. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from this source (ID No. SGS-A) 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 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .260land General
Condition JJ. If the results of this test are above the limit given in Section 2.1 H. La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Moni oring/Recordkeepingfe on rting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATE-F,NFORCEABLF ONT,Y
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
I. Polyvinyl Fluoride Polymer Manufacturing Facility No. 1 (ID No. FS-B)
Polyvinyl Fluoride Polymer Manufacturing Facility No. 2 (ID No. FS-Q
The following table provides a summary of limits_ and standards for the emission sources)
Regulated Pollutant
Limits/Standards
Particulate matter
Affected Source: Product Collection Systems
(Vents FEP-B4 & FEP-C4)
for process rates less than 30 tons per hour -
E = 4.10 P0.67
Where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons per hour
Visible emissions
Affected Source: Product Collection Systems
(Vents FEP-B4 & FEP-C4)
20% visible opacity emissions
Odors
State -enforceable only
Odorous emissions must be controlled
Volatile organic
Less than 40 tons per consecutive 12-month period
compounds
15A NCAC 2D .0515
15A NCAC 213.0521
15A NCAC 2D. 1806
15A NCAC 2Q .0317
(PSD Avoidance)
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the Product Collection Systems at the polyvinyl fluoride manufacturing facilities
DEQ-CFW 00068314
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(Vent Nos. FEP-B4 & FEP-C4) shall not exceed an allowable emission rate as calculated by the following equation:
E=4.10Xp1.61
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 2D .2601]
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 I.La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordke }tom [15A NCAC 2Q .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 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515 if the production records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a 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. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the Product Collection Systems at the polyvinyl fluoride manufacturing facilities (Vent Nos.
FEP-B4 & FEP-C4) 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.
T stintr [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 I.2.a. above, the Pennittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitories [15A NCAC 2Q .0508(f)]
To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. The Permittee shall establish "normal" for the PVF Manufacturing
Facility No. 2 (ID No. FS-C, Vent No. FEP-C4) within 30 days of initial start-up. If visible emissions from this
source are observed to be above normal, the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 I.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
DEQ-CFW 00068315
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available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations 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.
STATF,-F.NFORCEARLE ONT,Y
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment 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.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the Polyvinyl Fluoride (PVF) Manufacturing Facility No. 1 and No.
2 (ID Nos. FS-B and FS-C) shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-
month period.
Testing [15A NCAC 2D .2601]
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 I.4.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeoi_g [15A NCAC 2Q .0508(f)]'
c. To demonstrate compliance with the limit provided in Section 2.1 I.4.a., each calendar month the Permittee shall
create and retain production records and estimate associated VOC emissions, as follows:
i. Record the vent flow rates from the Analytical Equipment (QFEP_B1 and QFEP_Cl) at the two affected facilities
(Vent Nos. FEP-B 1 and FEP-C1 respectively) during the previous calendar month (in lb/month);
ii. Calculate the VOC emissions (EFEP_BCl) from the Analytical Equipment at two affected facilities during the
previous calendar month (in lb/month) using the following equation:
EFEP-BCI - QFEP-Bl + QFEP-Cl
iii. Record the vent flow rates from the Maintenance Headers (QFEP_B2 and QFEP.c2) at the two affected facilities
(Vent Nos. FEP-132 and FEP-C2 respectively) during the previous calendar month (in lb/month);
iv. Calculate the VOC emissions (EFEP_BC2) from the Maintenance Header at two affected facilities during the
previous calendar month (in lb/month) using the following equation: l
EFEP-BC2 — 0.5\QFEP-B2 + `.EFEP-C2 1
v. At least once each hour, record the pressure (PFEP_B3 and PFEP_c3) in the Low Pressure Slurry Separators at the two
affected facilities (Vent Nos. FEP-133 and FEP-C3 respectively) during the previous calendar month (in psig);
vi. At least once each hour, record the vinyl fluoride flow rates (QFEP_B3 and QFEP_C3) to the PVF Reactors at the two
affected facilities (Vent Nos. FEP-133 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
DEQ-CFW 00068316
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vii. Using an emissions model based on vapor pressure equilibrium data and vinyl fluoride flow rates to the PVF
Reactors, determine the hourly VOC emissions (EFEP_B3 and EFEP-0) from the Flash Tank vents at the two
affected facilities (Vent Nos. FEP-133 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
viii. Calculate the sum of the hourly VOC emissions (EFEP-BC3) from the Flash Tanks at the two affected facilities
during the previous calendar month (in lb/month) using the following equation:
EFEP-BC3 - I (EFEP-B3 ) + I \EFEP-C3 /
ix. Calculate the VOC emissions (E) from the two affected facilities during the previous calendar month (in
lb/month) using the following equation:
E = EFEP-BCI + EFEP-BC2 + EFEP-BC3
x. Calculate the 12-month rolling VOC emissions from the two affected facilities by summing the monthly VOC
emissions (E), as calculated in x. above, for the previous consecutive 12-months.
The first required monthly compliance demonstration, as described in i. through x. above, shall be required during
the calendar month fallpwinv initial start-up of PVF Manufacturing Facility No. 2 (ID No. FS-C). 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 2D .0530 if the
above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in x. above
exceeds the limit in Section 2.1 I.4.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
d. 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 VOC emissions from two affected polyvinyl fluoride manufacturing operations 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 deviations from the requirements of this permit must be clearly identified.
2.2 -. Multiple Emission Source(s) Specific Limitations and Conditions
A. BOILERS:
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-12), 139.4 million Btu per hour
maximum heat input;
Natural Gas No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-22), 88.4 million Btu per hour
maximum heat input;
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-C2) equipped with a low-NOx burner, 97.0
million Btu per hour maximum heat input; and,
Temporary Boiler (ID No. PS-Temp2), Natural Gas/No. 2 fuel oil -fired (greater than 30.0 and
less than 100.0 million Btu per hour maximum heat input).
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the affected boilers (ID Nos. PS-1, PS-2, PS-C, and PS -Temp)
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shall discharge into the atmosphere less than 702.5 tons of SO2 per consecutive 12-month period.
T s ins [15A NCAC 2D .2601]
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 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .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 mmscf) of natural gas fired at the affected boilers;
ii. The total quantity (in 1,000 gal) of No. 2 and No. 6 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 2D .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 SO2 emissions from the affected boilers 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'S02=157*Sfo6 *Qfo6 +142*Sfo2 *Qfo2 +0.6*Q„g
Where, ES02 = SO2 emissions (in lbs) during the previous calendar month;
S fo6 = Sulfur content in the No. 6 fuel oil (in percent by weight);
Qfo6 = Quantity of No. 6 fuel oil fired during the previous calendar month (in
1,000 gal);
S fo2 = Sulfur content in the No. 2 fuel oil (in percent by weight);
Qfo2 = Quantity of No. 2 fuel oil fired during the previous calendar month (in
1,000 gal); and,
Qng = Quantity of natural gas fired during the previous calendar month (in 1,000
gal).
ii. Sum the SO2 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 2D .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.
BcuSrting [15A NCAC 2Q .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 SO2 emissions from two affected boilers for the previous 17 calendar months;
ii. The 12-month rolling SO2 emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068318
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B. FACILITY -WIDE
STATF-F.NFORCF.ARLE ONT.Y
1. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 2D .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
394.62 lb/hr
Acetic Acid
54.08 lb/hr
Acrolein
1.17 lb/hr
Acrylonitrile
240.06 lb/hr
Ammonia
39.46 lb/hr
Ammonium Chromate
0.54 lb/day
Ammonium Dichromate
0.541b/day
Aniline
14.62 lb/hr
Arsenic and Inorganic Arsenic Compounds
0.371b/yr
Aziridine
5.26 lb/day
Benzene
192.05 lb/yr
Benzidine and Salts
0.021b/yr
Benzo(a)pyrene
52.81 lb/yr
Benzyle Chloride
7.31 lb/yr
Beryllium
6.56 lb/yr
Beryllium Chloride
6.561b/yr
Beryllium Fluoride
6.561b/yr
Beryllium Nitrate
6.56 lb/yr
Bis-Chloromethyl Ether
0.59 lb/yr
Bromine
2.921b/hr
1,3-Butadiene
272.07 lb/yr
Cadmium
8.8 lb/yr
Cadmium Acetate
8.8 lb/yr
Cadmium Bromide
8.8 lb/yr
Calcium Chromate
0.13 lb/yr
DEQ-CFW 00068319
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Toxic Air Pollutant
Facility -Wide Emission Limit
Carbon Disulfide
163.11 lb/day
Carbon Tetrachloride
10,723 lb/yr
Chlorine
I115 lb/hr
32.88 lb/da
Chlorobenzene
1,929.23 lb/day
Chloroform
6,882 lb/yr
Chloroprene
51.15 lb/hr
385.85 lb/day
Chromic Acid
0.54 lb/day
Chromium (VI)
0.13 lb/yr
Cresol
32.15 lb/hr
p-Dichlorobenzene
964.62 lb/hr
Dichlorodifluoromethane
217,476.92 lb/day
Dichlorofluoromethane
438.46 lb/day
Di(2-ethylhexyle)phthalate
26.31 lb/day
Dimethyl Sulfate
2.63 lb/day
1,4-Dioxane
491.08lb/day
Epichlorohydrin
132,832 lb/yr
Ethyl Acetate
2,046.15 lb/hr
Ethylenediamine
36.54 lb/hr
263.08 lb/day
Ethylene Dibromide
640.2 lb/yr
Ethylene Dichloride
6,081 lb/yr
Ethylene Glycol Monoethyl Ether
27.77 lb/hr
105.23 lb/day
Ethylene Oxide
43.21 lb/yr
Ethyl Mercaptan
1.461b/hr
Fluorides
3.65 lb/hr
14.03 lb/day
Formaldehyde
2.19 lb/hr
Hexachlorocyclopentadiene
0.15 lb/hr
0.53 lb/da
Hexachlorodibenzo-p-dioxin
0.12 lb/yr
DEQ-CFW 00068320
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Toxic Air Pollutant
Facility -Wide Emission Limit
n-Hexane
964.62 lb/day
Hexane Isomers
5,261.54 lb/hr
Hydazine
0.53 lb/day
Hydrogen Chloride
10.23 lb/hr
Hydrogen Cyanide
16.08 lb/hr
122.77 lb/day
Hydrogen Sulfide
30.69 lb/hr
Maleic Anhydride
1.46 lb/hr
10.52 lb/day
Manganese & Compounds
27.18 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 lb/hr
Mercury, vapor
0.53 lb/hr
Methyl Chloroform
3,580.77 lb/hr
10 523.08 lb/day
Methylene Chloride
24.85 lb/hr
38,409 lb/yr
Methyl Ethyl Ketone
1,293.461b/hr
3 244.621b/da
Methyl Isobutyl Ketone
438.46 lb/hr
2,244.92 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 Subsulfide
3.36 lb/yr
Nitric Acid
14.62 lb/hr
Nitrobenzene
7.31 lb/hr
52.62 lb/day
n-Nitrosodimethlamine
80.02 lb/yr
Pentachlorophenol
0.37 lb/hr
2.63 lb/day
Perchloroethylene
304,073 lb/yr
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Toxic Air Pollutant
Facility -Wide Emission Limit
Phenol
13.88 lb/hr
Phosgene
2.19 lb/day
Phosphine
1.90 lb/hr
Polycholinated Biphenyls
132.83 lb/yr
Potassium Chromate
0.541b/day
Potassium Dichromate
0.54 lb/day
Sodium Chromate
0.541b/day
Sodium Dichromate
0.541b/day
Strontium Chromate
0.13 lb/yr
Styrene
154.92 lb/hr
Sulfuric Acid
1.46 lb/hr
10.52 lb/da
Tetrachlorodibenzo-p-dioxin
0.0048 lb/yr
1, 1, 1,2-Tetrachloro-2,2-Difluoroethane
45,6001b/day
1,1,2,2,-Tetrachloro-1,2-Difluoroethane
45,6001b/day
1, 1, 1,2-Tetrachloroethane
10,0821b/yr
Toluene
818.46 lb/hr
4,121.54 lb/day
Toluene-2,4-diisocyanate
0.22 lb/hr
0.44 lb/day
Trichloroethylene
94,423 lb/yr
Trichlorofluoromethane
491,076.92 lb/day
1,1,2-Trichloro-1,2,2-Trifluoroethane
13,885 lb/hr
Vinyl Chloride
608.1 lb/yr
Vinylidene Chloride
105.23 lb/day
Xylene
950 lb/hr
2,367.69 lb/ -ay
Zinc Chromate
0.13 lb/yr
RecordkeepLg
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.
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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 exceedences 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 pounds per hour emission rate.
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 pounds per day emission rate.
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 pounds per year emission rate.
STATF,-ENFORC'EARLE ONLY
2. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic compliance
demonstration_ the following permit limit shall not be exceeded:
Emission Source
Toxic Air Pollutant
Emission Limit
High dispersion stacks
Hydrogen Fluoride
7.28 lb/hr
(ID Nos. NEP-Hdr-1, NEP-
52.45 lb/day
Hdr-2, AEP-Al, and FEP-
Al
All other sources
Hydrogen Fluoride
2.7 lb/hr
19.4 lb/da
Monitoring
b. The Permittee shall ensure the proper performance of the Nafion Baffle Plate -Type Tower Scrubbers (ID 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 three-hour period).
Recordkeeping
c. The Permittee shall record the results of inspections of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-i 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. 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.
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. 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 exceedences 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 pounds per hour emission rate.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
DEQ-CFW 00068323
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all applicable toxic air pollutants which have a listed pounds per day emission rate.
STATE -ENFORCEABLE ONLY
3. 15A NCAC 2D .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
2D .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.
b. All abrasive blasting operations shall be conducted within a building, except as provided in i. or ii. 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 blasting 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.
Any abrasive blasting operation conducted outside a building, as provided in Section 2.2. B.3. b.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. Hydroblasting;
iv. Vacuum blasting;
v. Shrouded blasting; or
vi. Shrouded hydroblasting.
4. 40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK MANAGEMENT
PROGRAMS UNDER THE CLEAN AIR ACT, SECTION 112(r)" - The Permittee shall comply with all
applicable requirements in accordance with 40 CFR Part 68 including submitting a Risk Management plan to EPA
pursuant to 40 CFR Part 68.150 prior to June 21, 1999 or as specified in 40 CFR Part 68.10.
DEQ-CFW 00068324
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SECTION 3 - GENERAL CONDITIONS (v2.22.1)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this pemut are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or criminal penalties. Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the
facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal or plant
life, or property caused by the construction or operation of this permitted facility, or from penalties therefore, nor does it
allow the Permittee to cause pollution in contravention of state laws or rules, unless specifically authorized by an order
from the North Carolina Environmental Management Commission.
5. Except as identified as state -only requirements in this permit, all terms and conditions contained herein shall be
enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the appropriate and valid
permits issued by the DAQ, unless the source is exempted by rule. The DAQ may issue a pen -nit 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 2Q .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 Environment and Natural Resources
upon request.
C. Severability C',laiise [15A NCAC 2Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid, the
provisions in this permit are severable so that all requirements contained in the permit, except those held to be invalid, shall
remain valid and must be complied with.
D. Submissions [15A NCAC 2Q .0507(e) and 2Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, notifications, request
for renewal, and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer to
the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems (CEMS) reports,
continuous opacity monitoring systems (COMS) reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM
certification reports, and NOx budget CEM certification reports, one copy shall be sent to the appropriate Regional Office
and one copy shall be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
E. Duty to Comply [15A NCAC 2Q .0508(i)(2)]
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
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the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement action, for permit
termination, revocation and reissuanee, or modification, or for denial of a permit renewal application.
F. Circumvention STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of
its associated air pollution control device(s) and appurtenances.
G. Permit Modifications
1. Administrative Perniit Amendments [15A NCAC 2Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 2Q
.0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q .0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 2Q.0524 and 2Q
.0505.
3. Minor Permit Modifications [15A NCAC 2Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q .0515.
4. Significant Permit Modifications [15A NCAC 2Q .05161
The Pernttee shall submit an application for a significant permit modification in accordance with 15A NCAC 2Q .0516.
5. Reopening for Cause [15A NCAC 2Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q .0517.
H. Changes Not Requiring Permit Modifications
1. Section 502(b)(10) Changes [15A NCAC 2Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition. Such changes do
not include changes that would violate applicable requirements or contravene federally enforceable permit terms
and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification
requirements.
b. The Permittee may make Section 502(b)(10) changes without having the permit revised if:
i. The changes are not a modification under Title I of the Federal Clean Air Act;
ii. The changes do not cause the allowable emissions under the permit to be exceeded;
iii. The Permittee notifies the Director and EPA with written notification at least seven days before the change is
made; and
iv. The Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. A description of the change;
ii. The date on which the change will occur;
iii. Any change in emissions; and
iv. Any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or renewed,
whichever comes first.
2. Off Permit Changes [15A NCAC 2Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit i£
a. The change affects only insignificant activities and the activities remain insignificant after the change; or
b. The change is not covered under any applicable requirement.
3. Emissions Trading [15A NCAC 2Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently adopted maximum
achievable control technology standards, emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 2Q .0523(c).
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I.A. Reporting Requirements for Excess Emissions and Permit Deviatidus
[15A NCAC 2D .0535(f) and 2Q .0508(f)(2)]
"Excess Emissions" - means an emission rate that exceeds any applicable emission limitation or standard allowed by any rule
in Sections .0500, .0900, .1200, or .1400 of Subchapter 2D; or by a permit condition; or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q .0700. (Note: Definitions of excess emissions under 2D. I I10 and 2D
.1411 shall apply where defined by rule)
"Deviation-" - 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 2D .0524), NESHAPS (15A NCAC 2D
.1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of excess emissions, reporting
shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .1111), or these rules
do NOT define "excess emissions," the Pemuttee shall report excess emissions in accordance with 15A NCAC 2D .0535
as follows:
a. Pursuant to 15A NCAC 2D .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 2D
.0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 2Q .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 2D .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 Requirements under 15A NCAC 2D .0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535, including 15A NCAC
2D .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 2D .0535(c)(1) through (7).
2. 15A NCAC 2D .0535(g). Excess emissions during start-up and shut -down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
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facility, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the facility to exceed a technology -based emission limitation under the permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by
improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology -based
emission limitations if the conditions specified in 3. below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s) of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Pern ittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the permit; and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency, steps
taken to mitigate emissions, and corrective actions taken.
4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of
proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal [15A NCAC 2Q .0508(e) and 2Q .0513(b)]
This permit is issued for a fixed term of five years for facilities subject to Title IV requirements and for a term not to exceed
five years in the case of all other facilities. This permit shall expire at the end of its term. Permit expiration terminates the
facility's right to operate unless a complete renewal application is submitted at least nine months before the date of permit
expiration. If the Permittee or applicant has complied with 15A NCAC 2Q .0512(b)(1), this permit shall not expire until the
renewal permit has been issued or denied. All terms and conditions of this permit shall remain in effect until the renewal
permit has been issued or denied.
L. Ned to Halt or Reduce Activity Not a Defense [15A NCAC 2Q .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. Duly to Provide information (submittal of information) [15A NCAC 2Q .0508(i)(9)]
1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the Director may request in
writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the pernut 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. Dulyto Supplement [15A NCAC 2Q .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 pernut application was submitted but prior to the release of the draft permit.
0. Retention of Records [15A NCAC 2Q .0508(f) and 2Q .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
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available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 2Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61 Forsyth
Street, Atlanta, GA 30303) postmarked on or before March 1 a compliance certification (for the preceding calendar year) by
a responsible official with all federally -enforceable terms and conditions in the permit, including emissions limitations,
standards, or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the
entire year regardless of who owned the facility during the year. The compliance certification
shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal Clean Air
Act. The compliance certification shall specify:
1. The identification of each term or condition of the permit that is the basis of the certification;
2. The compliance status (with the terms and conditions of the permit for the period covered by the certification);
3. Whether compliance was continuous or intermittent; and
4. The method(s) used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 2Q .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 2Q .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 2Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515.
Termination, Modification, and Revocation of the Permit [15A NCAC 2Q .0519]
The Director may terminate, modify, or revoke and reissue this permit if-
1 . the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions.contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or
5. the Director finds that termination, modification, or revocation and reissuance of the permit is necessary to carry out the
purpose of NCGS Chapter 143, Article 21B.
T. Insignificant Activities [15A NCAC 2Q .0503]
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.
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U. Property Riights [15A NCAC 2Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry [15A NCAC 2Q .0508(1) and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law, the Permittee shall allow the DAQ, or
an authorized representative, to perform the following:
a. Enter the Permittee's premises where the permitted facility is located or emissions -related activity is conducted, or
where records are kept under the conditions of the permit;
b. Have access to and copy, at reasonable times, any records that are required to be kept under the conditions of the
permit;
c. Inspect at reasonable times and using reasonable safety practices any source, equipment (including monitoring and
air pollution control equipment), practices, or operations regulated or required under the permit; and
d. Sample or monitor substances or parameters, using reasonable safety practices, for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under Section
114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Paym n [15A NCAC 2Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C. Department of Environment and Natural
Resources. 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 2Q .0519.
X. Ann jal Emission Inventory Requirement [15A NCAC 2Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q
.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 2Q .0107 and 2Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107, the Permittee
may also submit a copy of all such information and claim directly to the EPA upon request. All requests for confidentiality
must be in accordance with 15A NCAC 2Q .0107.
Z. Construction and Operation Permits [15A NCAC 2Q .0100 and .0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or emission
source which is not exempted from having a pernut prior to the beginning of construction or modification, in accordance with
all applicable provisions of 15A NCAC 2Q .0100 and .0300.
AA. Standard Application Form and Required information [15A NCAC 2Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 2Q .0505
and .0507.
$B. Financial Responsibility and Compliance History [15A NCAC 2Q .0507(d)(3)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
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CC. Refrigerant Requirements (Stratospheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which use Class I or II
ozone -depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR
Part 82 Subpart A Appendices A and B, the Permittee shall service, repair, and maintain such equipment according to
the work practices, personnel certification requirements, and certified recycling and recovery equipment specified in 40
CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the environment during the
repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports shall be
submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases - Section 112(r) [15A NCAC 2Q .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 Pennittee is required to register this plan in accordance with 40 CFR Part 68.
EE. Prevention of Accidental Releases General Duty Clause - Section 112(r) 11 -
FEDERALLY -ENFORCEABLE ONLY
Although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of
a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental
release of such substance and to minimize the consequences of any release.
FF. Title TV Allowances [15A NCAC 2Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee, but the Permittee may not use allowances
as a defense to noncompliance with any other applicable requirement. The Pemuttee's emissions may not exceed any
allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG. Air Pollution F,mergency Episode 'sode [15A NCAC 2D .0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be required to operate in
accordance with the Pemvttee's previously approved Emission Reduction Plan or, in the absence of an approved plan, with
the appropriate requirements specified in 15A NCAC 2D .0300.
HH. Registration of Air Pollution Sources [15A NCAC 2D .0200]
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 2D
.0202(b).
H. Ambient Air Quality Standards [15A NCAC 2D .0501(e)]
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 2D .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 Fmissions Testing and Reporting Ren lir .ments [15A NCAC 2Q .0508(i)(16)]
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 the procedures outlined below:
1. The Permittee shall submit a completed Protocol Submittal Form to the DAQ Regional Supervisor at least 45 days prior
to the scheduled test date. A copy of the Protocol Submittal Form may be obtained from the Regional Supervisor.
2. The Permittee shall notify the Regional Supervisor of the specific test dates at least 15 days prior to testing in order to
afford the DAQ the opportunity to have an observer on -site during the sampling program.
3. During all sampling periods, the Perrriittee shall operate the emission source(s) under maximum normal operating
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conditions or alternative operating conditions as deemed appropriate by the Regional Supervisor or his delegate.
4. The Perrttee shall submit two copies of the test report to the DAQ. The test report shall contain at a minimum the
following information:
a. A description of the training and air testing experience of the person directing the test;
b. A certification of the test results by sampling team leader and facility representative;
c. A summary of emissions results and text detailing the objectives of the testing program, the applicable state and
federal regulations, and conclusions about the testing and compliance status of the emission source(s);
d. A detailed description of the tested emission source(s) and sampling location(s) process flow diagrams, engineering
drawings, and sampling location schematics should be included as necessary;
e. All field, analytical, and calibration data necessary to verify that the testing was performed as specified in the
applicable test methods;
f. Example calculations for at least one test run using equations in the applicable test methods and all test results
including intermediate parameter calculations; and
g. Documentation of facility operating conditions during all testing periods and an explanation relating these operating
conditions to maximum normal operation. If necessary, provide historical process data to verify maximum normal
operation.
5. The testing requirement(s) shall be considered satisfied only upon written approval of the test results by the DAQ.
6. The DAQ will review emission test results with respect exclusively to the specified testing objectives as proposed by the
Permittee and approved by the DAQ.
KK. Reopening for Cause [15A NCAC 2Q .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 fmds 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 2Q .0513(c).
3. Except for the state -enforceable only portion of the permit, the procedures set out in 15A NCAC 2Q .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 2Q .0300 shall be followed. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened, except in
cases of imminent threat to public health or safety the notification period may be less than 60 days.
5. Within 90 days, or 180 days if the EPA -extends the response period, after receiving notification from the EPA that a
permit needs to be terminated, modified, or revoked and reissued, the Director shall send to the EPA a proposed
determination of termination, modification, or revocation and reissuance, as appropriate.
LL. Reporting Requirements for Non-OperatingEqui men [15A NCAC 2Q .0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from and
placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the
permit shall be implemented within the monitoring period.
M.M. Fugitive Duct Control Requirement [15A NCAC 2D .0540] -STATE ENFORCEABLE ONLY
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
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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 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.1. For modifications made pursuant to 15A NCAC 2Q .0501(c)(2), the Pernuttee shall file a Title V Air Quality Permit
Application for the air emission source(s) and associated air pollution control device(s) on or before 12 months after
commencing operation.
2. For modifications made pursuant to 15A NCAC 2Q .0501(d)(2), the Permittee shall not begin operation of the air
emission source(s) and associated air pollution control device(s) until a Title V Air Quality Permit Application is filed
and a construction and operation permit following the procedures of Section .0500 (except for Rule .0504 of this
Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 2Q .0523(a)(1)(C), the Permittee shall
notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth St., Atlanta, GA 30303) in siting at least seven
days before the change is made. The written notification shall include:
a. A description of the change at the facility;
b. The date on which the change will occur;
c. Any change in emissions; and
d. Any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit renewal, the
Permittee shall submit a page "E5" of the application forms signed by the responsible official verifying that the
application for the 502(b)(10) change/modification, is true, accurate, and complete. Further note that modifications
made pursuant to 502(b)(10) do not relieve the Permittee from satisfying pre -construction requirements.
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ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CAA Clean Air Act
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
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
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS 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
SIC Standard Industrial Classification
SIP State Implementation Plan
SOz Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound
DEQ-CFW 00068334
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NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: January 15, 2009
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
SIC: 3081 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Michael Johnson
Environmental Manager
(910)678-1155
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Authorized Contact
Karen Wrigley
Plant Manager
(910)678-1546
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Technical Contact
Michael Johnson
Environmental Manager
(910)678-1155
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Christy Richardson
Date of Last Inspection: 04/16/2008
Compliance Code: 3/In Compliance - Inspectio
Permit Applicability (this application only)
SIP:
NSPS: 60-Subpart Dc
NESHAP:
PSD:
PSD Avoidance: VOC
NC Toxics:
112(r):
Other:
Application Data
Application Number: 0900009.08D
Date Received: 12/09/2008
Application Type: Modification
Application Schedule: TV-Sign-501(c)(2)
Existing Permit Data
Existing Permit Number: 03735/T33
Existing Permit Issue Date: 08/04/2008
Existing Permit Expiration Date: 01/31/2009
Review Engineer: Fern Paterson Comments / Recommendations:
Issue 03735/T34
Review Engineer's Signature: Date: Permit Issue Date: 01/15/2009
ist Permit Expiration Date: 01/31/2009
I. Purpose of Application
The North Carolina Division of Air Quality (DAQ) received Application No. 0900009.08D from E.I. du Pont de
Nemours & Co., LLC (DuPont) on December 9, 2008. The application is for the following permit modifications:
(1) Construct and operate a new natural gas/No. 2 fuel oil fired boiler (ID No. PS-C) with a low NOx-burner and a
maximum heat input of 97 million Btu per hour (MMBtu/hr);
(2) Allow natural gas firing at the existing boilers (ID Nos. PS-1, PS-2, and PS -Temp);
(3) Permit the existing hexfluoropropylene epoxide (HFPO) product container decontamination process (ID No.
NS-N);
(4) Permit the existing Vinyl Ethers North product container decontamination process (ID No. NS-O);
(5) Permit the existing a new Vinyl Ethers North product container decontamination process (ID No. NS-P);
(6) Revise the description of the existing SentryGlas® Plus Manufacturing Facility (ID No. SGS-A) to the
SentryGlasOR Manufacturing Facility;
(7) Revise the description of the insignificant Abrasive Blasting Building (ID No.1-10) to indicate that the building
may also house occasional equipment painting.
(8) Correct misc. typographical errors.
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II. Permit Modifications/Changes
The following table describes the modifications to the current permit
Page(s)
Section
Description of Change(s)
N/A
Insignificant
Revise the description of the insignificant Abrasive Blasting Building {ID
Activity List
No. I-10) to indicate that the building may also house occasional equipment
painting.
Global
Global
[Testing Requirement Citations] Change all references to 15A NCAC 2D
.0501(c) to 15A NCAC 2D .2601 to be consistent with a recent rule change.
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
3-5
Section 1, Table
- Add natural gas firing capabilities to existing boilers (ID Nos. PS-1, PS-2,
and PS -Temp).
- Add new boiler (ID No. PS-C).
- Add decontamination sources (ID Nos. NS-N, NS-O, and NS-P).
- Remove "Plus" from the SentryGlas® manufacturing operation (ID No. SBS-A).
- Add table footnote with modification procedural information.
6-10
Section 2. LA.
- Source Listing: Add natural gas firing capabilities to existing boilers (ID
Nos. PS-1, PS-2, and PS -Temp). Add new boiler (ID No. PS-C).
- Table: Add 2D .0503 (PM) standard and NSPS Dc requirements (S02,
visible emissions) for new boiler. Add new boiler to the existing PSD
avoidance condition for SO2.
- Section 2.].A. I.b - Add 2D .0503 (PM) standard for new boiler.
- Section 2. LA.4. Add NSPS Dc requirements (S02, visible emissions) for
new boiler.
14-18
Section 2.1.C.
- Source Listing: Add decontamination sources (ID Nos. NS-N, NS-O, and NS-
P).
- Table: Add a PSD Avoidance Condition (VOC) for HFPO
decontamination source (ID No. NS-N).
- Section 2.1.C.6. Add a PSD Avoidance Condition (VOC) for HFPO
decontamination source (ID No. NS-N).
22
Section 2.1.G.
- Source Listing: Add natural gas firing capabilities to the boiler (ID No. PS -
Temp).
- Table: Add new boiler (ID No. PS-C) to the existing PSD avoidance
condition for S02.
25
Section 2.1.1-1.
Source Listing: Remove "Plus" from the SentryGlas® manufacturing operation
(ID No. SBS-A).
27
Section 2.114.a.
j Correct source ID No. from FL-C to FS-C.
28-29
Section 2.2.A.1
Revise existing PSD avoidance condition to include S02 emissions from the
new boiler and natural gas combustion in the existing boilers.
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On April 16, 2008, Ms. Christy Richardson and Mr.
Tien Nguyen (FRO) conducted a site inspection of the facility. At this time, the facility appeared to be operating in
compliance with all applicable requirements as provided in the air quality permit.
On January 6, 2009, the facility was issued a Notice of Recommendation for Enforcement (NRE) for operating the
decontamination sources (ID Nos. NS-N, NS-O, and NS-P) without a permit. DuPont is seeking to permit these
sources as part of this application.
In November 2007, the facility was issued a Notice of Violation (NOV) for failure to submit a Part II significant
modification application in a timely manner. Note that the required application was submitted and received by NC
DAQ on October 11, 2007, and a revised permit was issued on January 24, 2008.
DEQ-CFW 00068336
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IV. Regulatory Review
A. Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-1), 139.4 million Btu per hour maximum
heat input,
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-2), 88.4 million Btu per hour maximum
heat input, and
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-C) equipped with a low-NOx burner, 97 million Btu per
hour maximum heat input.
Description of Process/Modification
Existing boilers (ID Nos. PS-1 and PS-2) are not NSPS-affected boilers based on their construction dates.
As part of this modification, DuPont proposes to add natural gas firing capabilities to the boilers. The
boilers are currently permitted to fire No. 2 and No. 6 fuel oil. The existing boilers are currently capable of
accommodating natural gas fuel firing, but DuPont will have to install a natural gas supply line to the
facility. Per 40 CFR 60.14(e)(14), the addition of anew fuel source is NOT an NSPS modification,
provided the existing facility was designed to accommodate the additional fuel. This modification will not
trigger any additional requirements, and continued compliance with all applicable rules (15A NCAC 2D
.0521, 15A NCAC 2D .516, and 15A NCAC 2D .0503) is anticipated.
DuPont is also proposing to install and operate a new natural gas/No. 2 fuel oil fired package boiler with a
maximum heat input of 97 MMBtu/hr.
2. 15A NCAC 2D 0503 — Particulates from Fuel Burning Indirect Heat Exchangers
This regulation limits particulate matter (PM) emissions from the firing of fuel in indirect heat exchangers
(in lb/mml3tu) based on the facility -wide heat input. The PM limit for the new boiler (ID No. PS-C) is
determined by summing the heat input of the existing boilers with the maximum allowable heat input rate
of the new boiler. The PM limit for the temporary boiler shall be 0.2268 lb/mmBtu, as demonstrated
below:
Boiler ID No.
Heat Input Rate
ID No. PS-1
139.4 immBtu/hr
ID No. PS-2
88.4 mmBtu/hr
ID No. PS -Temp
100.0 MMBtu/hr
ID No. PS-C
97.0 MMBtu/hr
Total Heat Input
424.8 mmBtu/hr
PMLimit as calculated pursuant to 15A NCAC 2D .0503(c)
E = 1.090(Q)1.211
Where: E = Allowable emission limit for PM (in lb/mmBtu); and,
Q = Maximum heat input in MMBtu/hr
E = 1.090(424.8)-""'
E = 0.2268
PM emissions from the worst -case fuel (No. 2 fuel oil) are estimated to be less than 0.03 lb/mmBtu using
AP-42 emission factors, as follows:
2 WM filterable + 1.3
lbPMcondensable
1,000gal 1,000gal WMtotal
= 0.024
140 mmBtu mmBtu
1,000gal
DEQ-CFW 00068337
Because worst -case PM emission rates are estimated to be less than the allowable PM emission rate, no
monitoring, recordkeeping, or reporting shall be required to demonstrate compliance with this limitation.
3. 15A NCAC 2D .0524 — 40 CFR 60, Subpart Dc, NSPS for Small Industrial -Commercial -Institutional
Steam Generating Units — This regulation is applicable to boilers that commenced construction,
reconstruction, or modification after June 9, 1989 AND that have a maximum heat input capacity equal to
or greater than 10 million Btu per hour and less than or equal to 100 million Btu per hour (i.e., 10
mmBtu/hr < Q < 100 mmBtu/hr). The new boiler (ID No. PS-C) will be affected by this NSPS.
Pursuant to 40 CFR 60.7(a)(3), the Permittee is required to submit a written notification of the actual date
of initial startup of the NSPS-affected boiler. This notification shall be submitted the to the Regional
Supervisor.
The affected boiler will also be affected by the following emission standards:
— Sulfur Dioxide. The maximum sulfur content of any fuel oil received and fired in the Subpart Dc-
affected boiler shall not exceed 0.5 percent by weight. To demonstrate compliance with this standard,
the Permittee is required to retain copies of each fuel supplier certification, including the sulfur content
of the oil (in percent by weight). The Permittee is also required to submit a semiannual report
summarizing the monitoring activities (January 30a' and July 30t).
— Visible Emissions. For any Subpart Dc-affected boiler with a maximum heat input capacity of greater
than or equal to 30 million Btu per hour, visible emissions 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. To demonstrate compliance with this standard, the Permittee is required to conduct a
Method 9 opacity observation within 60 days of installing the unit. There are notification and test
reporting requirements associated with this observation.
In addition, affected boiler will be required to keep a monthly record of the quantity of each fuel fired
pursuant to 40 CFR 60.48c(g)(2), as follows:
"As an alternative to meeting the requirements of paragraph (g)(1) of this section, the .
owner or operator of an affected facility that combusts only natural gas, wood, fuels
using fuel certification in §60.48c6g to demonstrate compliance with the SO, standard,
fuels not subject to an emissions standard (excluding opacity), or a mixture of these fuels
may elect to record and maintain records of the amount of each fuel combusted during
each calendar month. "
4. 15A NCAC 20.0317 — Avoidance Conditions for 15A NCAC 2D .0530, Prevention of Significant
Deterioration — DuPont is located in Bladen County, which is a designated attainment/unclassified area for
all pollutants regulated by the New Source Review (NSR) permitting program. Therefore, emissions
increases associated with proposed construction activities must be evaluated to determine whether the
Prevention of Significant Deterioration (PSD) program applies as provided in 15A NCAC 2D .0530.
DuPont, which is a chemical processing plant with a 100-tpy major source threshold, is an existing major
source under the PSD program.
In August 2008 (Permit No. 03735T33), the Permittee limited allowable SO2 emissions from the three
existing boilers (ID Nos. PS-1, PS-2, and PS -Temp) to no greater than 702.5 tpy in order to avoid PSD
permitting for the proposed addition of a new Polyvinyl Fluoride (PVT) Manufacturing Line (ID No. FS-
Q. Because the new boiler will have the potential to provide steam to the new PVF line, SO2 emissions
from the proposed, new boiler (ID No. PS-C) must be added to SO2 emissions from the existing boilers to
demonstrate compliance with the existing PSD avoidance condition. Section 2.2.A.1. of the draft permit
has been modified to include the new boiler in the monthly compliance demonstration for the existing PSD
avoidance condition.
DEQ-CFW 00068338
Emissions increases resulting from the installation of the new boiler and use of natural gas at the existing
boilers are less than the significant emission rates for all PSD regulated pollutants, as shown in the table
provided below. The new boiler is being proposed to increase the reliability of steam supply for the site,
and will not debottleneck any process at the plant. Therefore, no PSI} permitting is required for the
proposed boiler, nor will the new boiler be restricted by any new PSD avoidance limitations.
Tnhle_ gnmmary of Potential Emissions Increases
NOTES:
I . All emissions estimated using AP-42 emission factors and assuming natural gas has a heat content of 1,020 Btu/scf.
2. No increased steam demand is anticipated as part of this proposed project. Therefore, to determine the worst -case emission increase
resulting from this proposed modification, NC DAQ determined the existing -potential emission rate (from fuel oil firing) and
compared it to the future -potential emission rate (from natural gas firing). The temporary, back-up boiler (ID No. PS -Temp) is only
brought on -site when there is a need (e.g., when other boilers have maintenance problems) and has never operated for more than 2,000
hours in a calendar year (CY2004). Actual emissions increases for this boiler assume only 4,380 hours operation per year. No
emissions increases are estimated for PM-10, S02, or NOx because the emission factor (in lb/MMBtu) for these pollutants is lower for
natural gas than currently permitted fuel oils.
3. NOx emissions for the new boiler (ID No. PS-C) are calculated using the emission factor for low-NOx burners.
B. One HFPO product container decontamination process (ID No. NS-N)
Description of Process/Modification
The HFPO Product Container Decontamination Process is an existing process at the facility in which
product containers that are returned from customers are decontaminated by venting residual product to the
atmosphere.' The residual product (hexafluoropropylene oxide) is a regulated VOC. Potential emissions
from the decontamination process are estimated to be 100.3 tons VOC per year. The process does not emit
any federally -regulated hazardous air pollutants (HAPs) or state -regulated toxic air pollutants (TAPS).
2. 15A NCAC 2Q 0317 — Avoidance Conditions for 15A NCAC 2D .0530; Prevention of Significant
Deterioration — Potential emissions from the HFPO Product Container Decontamination Process exceed 40
tpy of VOC. To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an
enforceable 40 tpy VOC emission limitation on the decontamination process pursuant to 15A NCAC 2Q
.0317.
3. 15A NCAC 2D 1806• Control and Prohibition of Odorous Emissions (State -Enforceable Only) — This
standard forbids the Permittee from operating the process 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. No new requirements
have been added to the draft permit to demonstrate compliance with 15A NCAC 2D .1806.
' The product is actually vented to a gaseous absorber (ID No. NCD-Hdrl), but because HFPO is not water soluble, it is assumed that no
emission reduction occurs, and all vented HFPO is released to the atmosphere.
DEQ-CFW 00068339
C. One Vinyl Ethers North product container decontamination process (ID No. NS-O)
One Vinyl Ethers South product container decontamination process (ID No. NS-P)
Description of Process/Modification
The Vinyl Ethers Product Container Decontamination Processes are existing processes at the facility in
which product containers that are returned from customers are decontaminated by venting residual products
to the atmosphere.' The residual products (perfluoropropyl vinyl ether, ester vinyl ether, and perfluorinated
sulfonyl vinyl ether) are regulated VOCs. Potential emissions from the decontamination processes
(combined) are estimated to be 31.3 tons VOC per year.
2. 15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions (State -Enforceable Ong) — This
standard forbids the Permittee from operating the process 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. No new requirements
have been added to the draft permit to demonstrate compliance with 15A NCAC 2D .1806.
V. Permit History:
The following list provides a very brief summary of permit revisions for this facility:
Permit No. Issuance Date
Description of Revision
03735T23 July 2003
Initial Title V Permit
03735T24 January 2004
Administrative amendment to the permit related to the permit effective
date.
03735T25 February 2004
Modification to add a temporary No. 2 fueI oil -fired boiler (ID No. PS -
Temp).
03735T26 May 2004
Administrative amendment to the permit related to modify permit
organization, thereby improving permit clarity.
03735T27 December 2004
Modification to add a SentryGlas® Plus manufacturing process (ID No.
SGS-A), change the description of the existing wastewater treatment plant,
and revise various monitoring requirements for existing scrubbers.
03735T28 January 2006
Administrative amendment to the change the required annual compliance
certification due date from January 30 to March 1.
03735T29 June 2006
Modification to add a polyvinyl fluoride polymer manufacturing facility
(ID No. FS-B) and an insignificant polyvinyl fluoride vacuuming system
for housekeeping purposes (ID No. I-1).
03735T30 September 2006
Replace an existing internal scrubber at the hexfluoropropylene epoxide
(HFPO) process (ID No. NS-A) in the Naflori Process Area
(debottlenecking).
03735T31 October 2007
Modification to authorize (1) the installation of a wet scrubber (ID No.
ACD-A3) on the building exhaust vent at the ammonium perfluoro-
octanoate (APFO) manufacturing facility (ID No. AS -A) and (2) add a
tetrafluoroethylene (TFE) / carbon dioxide (COZ) separation process (ID
No. NS-M).
03735T32 January 2008
"Part 2" Sgnificant modification for the temporary rental boiler (ID No.
PS -Temp) and the hexafluoropropylene oxide (HFPO) manufacturing
facility (ID No. NS-A). Also authorize changes at the existing Butacite®
Extruder Lines (ID Nos. BS-El and BS-E2).
03735T33 August 2008
"Part 1" significant modification to construct and operate Polyvinyl
Fluoride (PVF) Manufacturing No. 2 (ID No. FS-C) and various
insignificant activities.
2 The products are actually vented to gaseous absorbers (ID Nos. NCD-Hdrl and NCD-Hdr2), but because they are not water soluble, it is
assumed that no emission reduction occurs, and all vented VOC is released to the atmosphere.
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VI. Draft/Proposed Permit Review Summary
• Ms. Christie Richardson (FRO) was provided a copy of the draft permit for review on January 12, 2009
<ENTER DATE AND SUMMARY>.
• Mr. Michael Johnson (DuPont) was provided a draft permit for review on January 12, 2009. In an email to
Ms. Paterson dated January 13, 2009, Mr. Johnson provided several comments with editorial corrections and
changes. All recommended changes were incorporated into the final permit.
• Public notice is NOT required for this application.
• U.S. EPA review is NOT required for this application.
VII.Other Regulatory Considerations
• The application fee of $867.00 was received on December 9, 2008.
• The Reduction and Recycling Form was received on December 9, 2008.
• A Professional Engineers Seal is NOT required for this application.
• A zoning consistency determination was received by the DAQ on December 9, 2008.
VIII. Recommendations
The permit modification application for E.I. du Pont de Nemours & Co., LLC, located in Duart Township, Bladen
County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and
requirements. NC DAQ has determined that this facility appears to be complying with all applicable requirements.
Issue Permit No. 03735T34
DEQ-CFW 00068341
General Information:
Pen -nit code:
Application type:
Engineer/Rev. location
Regional Contact:
Facility location:
Facility classification:
Clock is ON
Status is :
Comprehensive Application Report for 0900009.081)
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Pennit/Latest Revision: 03735/ T34
TV -Sign-501(c)(2)
Modification
Fern Paterson/RCO
James Moser
Fayetteville Regional Office
Title V
Application is COMPLETE
Issued
Contact Information
ype Name
uthorized Karen B Wrigley, Plant Manager
echnical/Permit Michael E Johnson, Environmental Manager
Acceptance Criteria
eceived? Acceptance Criteria Description
es Application fee
es Appropriate number of apps submitted
es Zoning Addressed
es Source recycling/reduction form
es Authorized signature
/A PE Seal
0
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01 / 16/2009
Ammlication Dates
Received Completeness Due Clock Start Calculated Issue Due
12/09/200801 /23/2009 12/09/2008 03/11/2009
Fee Information
Initial amount: Date receiveFlmount Due Add. Amt Rcv'd: Date Rcv'd:
$867.00 12/ 10/2008
Fund type: Deposit Slip #: Location rec'd: Location deposited:
2333
Address
22828 NC Highway 87 West
22828 NC Highway 87 West
City State ZIP Telephone
Fayetteville, NC 28306-7332 (910) 678-1546
Fayetteville, NC 28306-7332 (910) 678-1155
Completeness Criteria
Received? Complete Item Description
•
Comprehensive Application Report for 0900009.08D
DuPont Company - Fayetteville Works - Fayetteville (0900009)
01 / 16/2009
Bladen County
Application Events
ent Start Due Complete Comments
- Acknowledgment/Complete 12/09/2008 12/19/2008, 12/10/2008
aft permit to region 01/12/2009 01/19/2009
aft permit to applicant 01/12/2009 01/19/2009 01/13/2009
aft permit to 1st line supervisor 01/14/2009 01/14/2009
rmit issued 01/15/2009 01/15/2009
Staff
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fapaterson
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Comprehensive Application Report for 0900009.08D
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
01 / 16/2009
Outcome Information
lass before: Title V
Class after: Title V
Permit/Revision: 03735/T34
.071 l: No 2D .1100:
No
Revision Issue Date: 01/15/2009
SPS: Yes NESHAPS/MACT:
No PSD/NSR:
No
Accumulated process days (includes public notice periods): 35
SD/NSR Avoid: Yes
Prohibitory Small:
No
Public notice/hearing/add info after 80 days:
SD/NSR Status After: Major
General permit:
No
Manager's discretion: Appealed? No
lulti-site permit: No
Multi. permits at facility:
No
Current Permit Information:
,uarry permit: No
HAP Major (10/25 tpy):
Major
Issue Effective . Expiration Revision #
Q .0705 Last MACT/Toxics:
NO
NESHAPS/GACT:
NO
01/15/2009 01/15/2009 01/31/2009 T34
ew Source RACT/LAER:
NO
Existing Source RACT:
NO
ACT/LAER Added Fee:
NO
Regulations Pertaining to this Permit
Reference Rule
2D
.1806
2Q
.0317
2D
.0503
2D
.0515
2D
.0516
2D
.0521
2D
.0524
2D
.1100
2D
.1111
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Regulation Description
Control And Prohibition of Odorous Emissions
Avoidance Conditions
Particulates Fuel Burning Indirect Heat Exchangers
Particulates Miscellaneous Industrial Processes
Sulfur Dioxide Emissions Combustion Sources
Control of Visible Emissions
New Source Permance Standards
Control of Toxic Air Pollutants
Maximum Achievable Control Technology
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Comprehensive Application Report for 0900009.08D 01/16/2009
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Audit Information Pertaining to this Application
Column Name Date Changed Old Value New Value Editor
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