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HomeMy WebLinkAboutDEQ-CFW_00085941i i (SWU09 Qlly North Carolina Department of Environment and Natural Resources Division of Air Quality Title V Annual Compliance Certification Forms Facility Name: Vu.Pont Company — Fayetteville Works Facility Address: 22828 NC Highway 87 W Fayetteville, NC 28306-7332 Facility Location: 22828 NC Highway 87 W Duart Township, Bladen Count Facility ID Number: 0900009 Title V Permit Number: 03735T33 Start of Reporting Period: JanuM 1 2008 End of Reporting Period: December 312008 N Compliance Statement (Check only one of the following options) �. During the reporting period specified above, this facility was in compliarice11with all terms a conditions identified in the above referenced Title V Operating Permit. As such,; t}e deviations, excess emissions events, or other reportable incidents including thoso equipment malfunctions, breakdown, or upset conditions (please fill out the Compliance Summary Report). X During the reporting period specified above, this facility was in compliance with ALL terms and conditions identified in the above referenced Title V Operating Permit, EXCEPT for the deviations identified in the Deviation Summary Report (please fill out both the Compliance Summary Report and Deviation Summary Report). Does the above compliance statement differ from what is indicated on your most recent Title V Report (i.e. last Semi -Annual Monitoring Report, Annual Emissions Inventory, etc)? ❑ Yes 0 No Are you submitting this Annual Compliance Certification form to also fulfill a Title V Semi -Annual Monitoring reporting requirement? ❑ Yes 0 No Certification By Responsible Official Based on information and belief formed after reasonable inquiry, the undersigned certifies under penalty of law (federal rule 40 CFR 70.5(d)) that all information and statements provided in this form (inOmding w.y any attachments) are true, accurate, and complete." rn L� February 19, 2009 (Signature of Responsible ffici " (Date) Name: Karen B. Wrigley (Type or Print) Number of Attached Pages (not including Instructions Page) 60 DEQ-CFW 00085941 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 1 of 54 Terms and Conditions Records Was Emission Source or Deviation Maintained Deviation a. Method(s) of Permit Condition Source Control Device ID ? ? non- compliance Determining Compliance Comments Description No.(s) Condition Summary o (Yes / N) (Yes / No / issue? Status Number NA) (Yes / No) Emissions of particulate matter No. 2/No. 6 PS-1 and from the combustion of No. 2/No. fuel oil -fired PS-2 2.1(A)(1)(a) 6 fuel oil, that are discharged from No NA NA AP-42 boiler this source into the atmosphere calculation shall not exceed 0.2667 pounds per million Btu heat input. 2D .0503] If emissions testing is required, the No. 2/No. 6 PS-1 and testing shall be performed in fuel oil -fired PS-2 2.1(A)(1)(b) accordance General Condition JJ. No NA NA NA boiler [2D .2601] No monitoring/recordkeeping/ No. 2/No. 6 PS-1 and reporting is required for particulate fuel oil -fired PS-2 2.1(A)(l)(c) emissions from the firing of No. 2 No NA NA NA boiler or No. 6 fuel oil in these sources. [2Q .0508(f)] Emissions of sulfur dioxide from No. 2/No. 6 PS-1 and these sources shall not exceed 2.3 fuel oil -fired PS-2 2.1(A)(2)(a) pounds per million Btu heat input. No NA NA AP-42 boiler [2D .0516] calculation If emissions testing is required, the No. 2/No. 6 PS-1 and testing shall be performed in fuel oil -fired PS-2 2.1(A)(2)(b) accordance with 15A NCAC 2D No NA NA NA boiler .2601 and General Condition JJ found in Section 3. [2D .2601] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 2 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) � es / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) No monitoring/recordkeeping is No. 2/No. 6 PS-1 and required for sulfur dioxide fuel oil -fired PS-2 2.1(A)(2)(c) emissions from No. 2 fuel oil No NA NA NA boiler burned in these sources. [2Q .0508(f) and 2D .0501(c)(4)(A)] The maximum sulfur content of No. 2/No. 6 PS-1 and any No. 6 fuel oil received and Certificate of fuel oil -fired PS-2 2.1(A)(2)(d) burned in the boiler shall not No Yes NA Analysis from boiler exceed 2.1 percent by weight. [2D Oil Supplier .0516] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 3 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Y/ N es o ( ) (Yes / No / issue? Status Number NA) (Yes / No) To assure compliance, the No. 2/No. 6 PS-1 and Permittee shall monitor the sulfur fuel oil -fired PS-2 2.1(A)(2)(e) content of the No. 6 fuel oil by No Yes NA Certificate of boiler using fuel oil supplier certification Analysis from per shipment received. The results Oil Supplier of the fuel oil supplier certifications shall be recorded in a logbook on a quarterly basis and include the following information: i. Fuel oil supplier name; 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. [2D .0516] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 4 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a No. 2/No. 6 PS-1 and summary report of the fuel oil fuel oil -fired PS-2 2.1(A)(2)(f) supplier certifications postmarked No Yes NA Title V boiler on or before January 30 of each Semiannual calendar year for the preceding Summary six-month period between July and Report 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. 2D .0521 Visible emissions from the boiler No. 2/No. 6 (ID No. PS-1) shall not be more fuel oil -fired PS-1 2.1(A)(3)(a) than 40 percent opacity when No Yes NA Daily visible boiler averaged over a six -minute period. emissions However, six -minute averaging observations 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 o aci 2D .0521] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 5 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition compliance Compliance Comments Description No.(s) Condition Summary Yes / No ( ) Yes / No / issue? Status Number NA) (Yes / No) Visible emissions from the boiler No. 2/No. 6 (ID No. PS-2) shall not be more fuel oil -fired PS-2 2.1(A)(3)(b) than 20 percent opacity when No Yes NA Daily visible boiler averaged over a six -minute period. emissions However, six -minute averaging observations 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. [2D .0521] If emissions testing is required, the No. 2/No. 6 PS-1 and testing shall be performed in fuel oil -fired PS-2 2.1(A)(3)(c) accordance with 15A NCAC 2D No NA NA NA boiler .2601 and General Condition JJ. [2D .2601] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 6 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary �1' (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) To assure compliance, each day No. 2/No. 6 PS-1 and that an affected source fires No. 6 fuel oil -fired PS-2 2.1(A)(3)(d) fuel oil, the Permittee shall No Yes NA Review of boiler observe the emission point of the daily visible affected source for any visible emissions emissions above normal. The observation daily observation must be made records for each day 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, or ii. Demonstrate that the percent opacity from the emission points of the emission source is below the limit given in Section 2.1 A.3.a. orb. above. [2Q 0508(f ] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 7 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No.(s) Condition Summary �"y issue? Status Number NA) (Yes / No) The results of the monitoring shall No. 2/No. 6 PS-1 and be maintained in a logbook fuel oil -fired PS-2 2.1(A)(3)(e) (written or electronic format) on- No Yes NA Review of boiler site and made available to an daily visible authorized representative upon emissions request. The logbook shall record observation the following: records i. The date and time of each recorded action; I 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. [2 0508 f)] No monitoring/recordkeeping/ No. 2/No. 6 PS-1 and reporting is required for visible fuel oil -fired PS-2 2.1(A)(3)(f) emissions from the firing of No. 2 No NA NA NA boiler fuel oil in these sources. [2Q .0508 (f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 8 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No.(s) Condition Summary ry issue? Status Number NA) (Yes / No) The Permittee shall submit a No. 2/No. 6 PS-1 and summary report of the fuel oil -fired PS-2 2.1(A)(3)(g) observations postmarked on or No Yes NA Title V boiler before January 30 of each calendar Semiannual year for the preceding six-month Summary period between July and Report 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 .0508(f)] In order to avoid applicability of No. 2/No. 6 15A NCAC 2D .0530(g) for major fuel oil -fired PS-2 2.1(A)(4)(a) sources and major modifications, No Yes NA Emissions boiler the affected boiler (ID No. PS-2 determined only) shall discharge into the monthly using atmosphere less than 25 tons of AP-42 factors particulate matter per consecutive 12-month period. [2 .0317] In order to avoid applicability of No. 2/No. 6 15A NCAC 2D .0530(g) for major fuel oil -fired PS-2 2.1(A)(4)(a) sources and major modifications, No Yes NA Emissions boiler the affected boiler (ID No. PS-2 determined only) shall discharge into the monthly using atmosphere less than 15 tons of AP-42 factors particulate matter under 10 microns per consecutive 12-month period.. [2Q .0317] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 9 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) ? ( Yes / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) In order to avoid applicability of No. 2/No. 6 15A NCAC 2D .0530(g) for major fuel oil -fired PS-2 2.1(A)(4)(a) sources and major modifications, No Yes NA Emissions boiler the affected boiler (ID No. PS-2 determined only) shall discharge into the monthly using atmosphere less than 40 tons of AP-42 factors Nitrogen Oxide per consecutive 12-month period. 2 .0317] In order to avoid applicability of No. 2/No. 6 15A NCAC 2D .0530(g) for major fuel oil -fired PS-2 2.1(A)(4)(a) sources and major modifications, No Yes NA Emissions boiler the affected boiler (ID No. PS-2 determined only) shall discharge into the monthly using atmosphere less than 40 tons of AP-42 factors Sulfur Dioxide per consecutive 12- month period. [2Q .0317] If emissions testing is required, the No. 2/No. 6 Permittee shall perform such fuel oil -fired PS-2 2.1(A)(4)(b) testing in accordance with General No NA NA NA boiler Condition JJ. [2Q .2601] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 10 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary �' (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall keep monthly No. 2/No. 6 accounting records of the amount fuel oil -fired PS-2 2.1(A)(4)(c) of fuel used and the sulfur content, No Yes NA Fuel boiler including certification of the fuel, consumption in a logbook (written or in and sulfur electronic format). The Permittee content shall be deemed in noncompliance records with 15A NCAC 2D .0530 if the sulfur content of the fuel is not monitored. - - [2Q.0508(fl] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 11 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No.(s) Condition Summary ry NA) issue? Status Number (Yes / No) The Permittee shall submit a semi - No. 2/No. 6 annual summary report of fuel oil -fired PS-2 2.1(A)(4)(d) monitoring and recordkeeping No Yes NA Semi-annual boiler activities. The report shall contain reports to NC the following: Division of i. The monthly particulate Air Quality matter, particulate matter FRO 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 No. 2/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. [2 .0508(fl] Emissions of particulate matter from the affected source (ID No. Monthly Butacite® BS-C 2.1(B)(1)(a) BS-C) shall not exceed an No Yes NA visible flake dryer allowable emission rate. emissions [2D .0515) logbook Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 12 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) If emissions testing is required, the testing shall be performed in Butacite® BS-C 2.1(B)(1)(b) accordance with General No NA NA NA flake dryer Condition JJ. 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 .0515. [2D .2601] Particulate matter emissions from the Butacite® flaker dryer (ID No. Butacite® BS-C 2.1(13)(1)(c) BS-C) shall be controlled by the No Yes NA Butacite® flake dryer bagfilter (ID No. BCD-C2) and maintenance cyclone separator (ID No. BCD- records Cl). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. 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. 2 .0508 ] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 13 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- . Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary �'y (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) The results of inspection and maintenance shall be maintained in Butacite® BS-C 2.1(B)(1)(d) a logbook (written or electronic No Yes NA Butacite® flake dryer format) on -site and made available Bagfilter to an authorized representative Logbook 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. [2D .0515] The Permittee shall submit the results of any maintenance Butacite® BS-C 2.1(B)(1)(e) performed on the bagfilters within No Yes NA Butacite® flake dryer 30 days of a written request by the Bagfilter DAQ. Logbook [2 .0508( ] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 14 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No compliance Compliance Comments No.(s) Condition Summary NA) issue? Status Number (Yes / No) The Permittee shall submit a summary report of monitoring and Butacite® BS-C 2.1(B)(1)(f) recordkeeping activities No Yes NA Semi-annual flake dryer postmarked on or before January reports to NC 30 of each calendar year for the Division of preceding six-month period Air Quality between July and December and FRO 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. 2D .0515 Visible emissions from the affected source (ID No. BS-C) Butacite® BS-C 2.1(13)(2)(a) shall not be more than 20 percent No Yes NA Monthly flake dryer opacity when averaged over a six- visible minute period. However, six- emissions minute averaging periods may logbook 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 o acity.[2D.0521] If emissions testing is required, the testing shall be performed in Butacite® BS-C 2.1(13)(2)(b) accordance with 15A NCAC 2D No NA NA NA flake dryer .2601 and General Condition JJ. [2D .2601] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 15 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary �3' (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) To assure compliance, once a month the Permittee shall observe Butacite® BS-C 2.1(13)(2)(c) the emission point of the affected No Yes NA Monthly flake dryer source for any visible emissions visible above normal. The monthly emissions observation must be made for each logbook 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, or ii. Demonstrate that the percent opacity from the emission points of the emission source is below the limit given in Section 2.1 B.2.a. above. [2 .0508 f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 16 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary es / No (Yes ) (Yes / No J issue? Status Number NA) (Yes / No) The results of the monitoring shall Butacite® be maintained in a logbook flake dryer BS-C 2.1(B)(2)(d) (written or electronic format) on- No Yes NA Monthly site and made available to an visible authorized representative upon emissions request. The logbook shall record logbook 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. [2 .0508( Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 17 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary es o Y/ N ( ) (Yes / No / issue? Status Number . NA) (Yes / No) The Permittee shall submit a summary report of the Butacite® BS-C 2.1(13)(2)(e) observations postmarked on or No Yes NA Semi-annual flake dryer before January 30 of each calendar reports to NC year for the preceding six-month Division of period between July and Air Quality December and July 30 of each FRO 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. Emissions from the polyvinyl butyral sheeting rotogravure Butacite® BS-D 2.1(B)(4)(a) printing operation shall be No Yes NA 1999 sheeting controlled using a permanent total Stationary rotogravure enclosure for the process area and Source printing a multi -stage horizontal spray Sampling operation scrubber (ID No. BCD-D1) that Report achieves an overall organic HAP control efficiency of at least 95 percent. [2Q .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 18 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Yes / No ( ) (Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall ensure the proper performance of the Butacite® BS-D 2.1(B)(4)(b) scrubber (ID No. BCD-D1) by No Yes NA Butacite® sheeting monitoring the following IP21 rotogravure operational parameters: Data printing i. Water flow rate to each nozzle Historian operation (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, averaged over a three-hour period). [2D .1111] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 19 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall comply with all applicable record keeping and Butacite® BS-D 2.1(B)(4)(c) reporting requirements specified in No Yes NA Butacite® sheeting 40 CFR Part 63, including the IP21 rotogravure following: Data printing i. If an action taken by the Historian operation Permittee during a startup, shutdown, or malfunction is not consistent with the affected source's SSM plan, the Permittee shall record the actions taken and shall report such actions. ii. The Permittee shall submit to the Regional Supervisor, DAQ, a semi-annual summary report. iii. If the actions taken by the Permittee during start-up, shutdown, or malfunction (SSM) are not completely consistent with the SSM plan, then the Permittee shall submit an SSM report. [2D .1111 Nafion® Emissions of particulate matter Emission membrane from the affected source (ID No. AP-42 source NS-I coating NS-I 2.1(C)(1)(a) NS-I) shall not exceed an No NA NA calculation has no visible allowable emission rate. process [2D .0515] emissions o- Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 20 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No. s () Condition Summary issue? Status Number NA) (Yes / No) Nafion® If emissions testing is required, the membrane testing shall be performed in NS-I 2.1(C)(1)(b) accordance with General No NA NA NA coating Condition JJ. process [2D .2601] The Permittee shall maintain production records such that the Nafion® NS-I 2.1(C)(1)(c) process rates "P" in tons per hour, No Yes NA Nafion® membrane as specified by the formulas Production coating contained above (or the formulas Records process contained in 15A NCAC 2D .0515) can be derived, and shall make these records available to a DAQ authorized representative upon request. 2 .0508(f) The Permittee shall submit a summary report of monitoring and Nafion® NS-I 2.1(C)(1)(d) recordkeeping activities No Yes NA Semi-annual membrane postmarked on or before January reports to NC coating 30 of each calendar year for the Division of process preceding six-month period Air Quality between July and December and FRO 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. [2Q 0508(fl] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 21 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition compliance Compliance Comments Description No.(s) Condition Summary (Yes / No) (Yes / No ! issue? Status Number NA) (Yes / No) Visible emissions from the affected source (ID No. NS-I) Nafion® NS-I 2.1(C)(2)(a) shall not be more than 20 percent No NA NA NA Emission membrane opacity when averaged over a six- source NS-I coating minute period. However, six- has no visible process minute averaging periods may emissions 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 o aci . 2D .0521] If emissions testing is required, the testing shall be performed in Nafion® NS-I 2.1(C)(2)(b) accordance with 15A NCAC 2D No NA NA NA Emission membrane .2601 and General Condition JJ. source NS-I coating If the results of this test are above has no visible process the limit given in Section 2.1 emissions C.2.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. [2D .2601] No monitoring/recordkeeping/ reporting is required for visible Emission Nafion® NS-I 2.1(C)(2)(c) emissions from this source. [2Q No NA NA NA source NS-I membrane .0508(f)] has no visible coating emissions process Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 22 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) In order to avoid applicability of this regulation, the Vinyl Ethers Vinyl Ethers NS-B 2.1(C)(4)(a) North process (ID No. NS-B) shall No Yes NA Monthly North discharge into the atmosphere less Emissions process than 68.9 tons of VOCs per Report consecutive 12-month period. [2 .0317 Calculations of VOC emissions Vinyl Ethers per month shall be made within 30 Monthly North NS-B 2.1(C)(4)(b) days of the end of each month. No Yes NA Emissions process [2Q .0508(f)] Report The total amount of VOC Vinyl Ethers emissions shall be recorded Monthly North NS-B 2.1(C)(4)(c) monthly in a logbook (written or No Yes NA Emissions process electronic format). Report [2 .0317 The Permittee shall ensure the proper performance of the Nafion Vinyl Ethers NS-B 2.1(C)(4)(d) Baffle Plate -Type Tower No Yes NA Scrubber North Scrubbers (ID Nos. NCD-Hdr-I Circulation process and NCD-Hdr-2) by monitoring Flow Rate the following operational Logbook parameters: i. Injection liquid flow rate (minimum of 7,000 kilograms per hour, averaged over a three-hour period). Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 23 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary ry (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall record the results of inspections in a scrubber Vinyl Ethers NS-B 2.1(C)(4)(e) logbook (written or electronic No Yes NA Scrubber North records), which shall be kept on Circulation process site and made available to Division Flow Rate of Air Quality personnel upon Logbook and request. Any variance from the SAP manufacturer's recommendations Maintenance or the permit monitoring Historian 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. [2Q .0508(f) Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 24 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary es / No ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a semi- annual summary report, acceptable Vinyl Ethers NS-B 2.1(C)(4)(f) to the Regional Air Quality No Yes NA Semi-annual North Supervisor, of monitoring and reports to NC process recordkeeping activities. The Division of report shall contain the following: Air Quality i. The monthly VOC emissions FRO for the previous 17 months. The emissions shall be calculated for each of the 12- month periods over the previous 17 months. [2 .0508( In order to avoid applicability of this regulation, the resins process Monthly Resins NS-G 2.1(C)(5)(a) (ID No. NS-G) shall discharge into No Yes NA Emissions process the atmosphere less than 40 tons of Report VOCs per consecutive 12-month eriod. [2 .0317] Calculations of VOC emissions per month shall be made within 30 Monthly Resins NS-G 2.1(C)(5)(b) days of the end of each month. No Yes NA Emissions process [2Q .0508(f)] Report The total amount of VOC emissions shall be recorded Monthly Resins NS-G 2.1(C)(5)(c) monthly in a logbook (written or No Yes NA Emissions process electronic format). Report [2 .0317] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 25 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes ! No / compliance Compliance Comments No.(s) Condition Summary n' issue? Status Number NA) (Yes / No) The Permittee shall submit a semi- annual summary report, acceptable Resins NS-G 2.1(C)(5)(d) to the Regional Air Quality No Yes NA Semi-annual process Supervisor, of monitoring and reports to NC recordkeeping activities. The Division of report shall contain the following: Air Quality i. The monthly VOC emissions FRO for the previous 17 months. The emissions shall be calculated for each of the 12- month periods over the previous 17 months. [2 .0508( ] In order to avoid applicability of this regulation, the HFPO process HFPO NS-A 2.1(C)(6)(a) (ID No. NS-A) shall discharge into No Yes NA Monthly process the atmosphere less than 85.3 tons Emissions of VOCs per consecutive 12- Report month eriod. [2 .0317] Calculations of VOC emissions per month shall be made within 30 HFPO NS-A 2.1(C)(6)(b) days of the end of each month. No Yes NA Monthly process The Permittee shall be deemed in Emissions noncompliance with 15A NCAC Report 2D .0530 if the amounts of VOC containing materials or the VOC emissions are not monitored and recorded. Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 26 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No.(s) Condition Summary �Y issue? Status Number NA) (Yes / No) The total amount of VOC emissions shall be recorded Monthly HFPO NS-A 2.1(C)(6)(c) monthly in a logbook (written or No Yes NA Emissions process electronic format). Report [2 .0317] The Permittee shall submit a semi- annual summary report, acceptable HFPO NS-A 2.1(C)(6)(d) to the Regional Air Quality No Yes NA Semi-annual process Supervisor, of monitoring and reports to NC recordkeeping activities. The Division of report shall contain the following: Air Quality i. The monthly VOC emissions FRO for the previous 17 months. The emissions shall be calculated for each of the 12- month periods over the previous 17 months. 2 .0508( The Permittee shall comply with all applicable provisions contained in Nafion® NS-A 2.1(C)(7)(a) Environmental Management Yes Yes No Records See attached processes throughN Commission Standard 15A NCAC review deviation S-L 2D .1111, "Maximum Achievable notification Control Technology" (MACT) as dated promulgated in 40 CFR Part 63, 08/06/2008 Subpart FFFF by May 10, 2008, or as provided in the rule. [40 CFR 63.2445(b)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 27 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? compliance Compliance Comments Description No.(s) Condition Summary (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a Notification of Compliance Status Notification Nafion® NS-A 2.1(C)(7)(b) to the Fayetteville Regional in No Yes NA of processes throughN accordance with 40 CFR Compliance S-L 63.2520(d) by October 7, 2008, or Status Report as provided in the rule. submitted on [2D .1111] 10/01/2008 Fluoro- Emissions of particulate matter products from the affected source (ID No. polymer FS-A 2.1(D)(1)(a) FS-A) shall not exceed an No NA NA AP-42 manufact'g allowable emission rate. Calculation develop- [2D .0515] ment facility Fluoro- If emissions testing is required, the products testing shall be performed in polymer FS-A 2.1(D)(1)(b) accordance with General No NA NA NA manufact'g Condition JJ. develop- [2D .2601] ment facility Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 28 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary �1' (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) Fluoro- Particulate matter emissions from products the Fluoroproducts polymer polymer FS-A 2.1(D)(1)(c) manufacturing facility (ID No. No Yes NA Records manufact'g FS-A) shall be controlled by the Review develop- bagfrlter (ID No. FCD-A2). To ment facility assure compliance, the Permittee shall perform inspections and maintenance. 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 I An annual internal inspection of the bagfilter's structural integrity. [2 .0508 (f) Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 29 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) ? ( Yes / No / compliance Compliance Comments No.(s) Condition Summary N`4) issue? Status Number (Yes / No) Fluoro- The results of inspection and products maintenance shall be maintained in polymer FS-A 2.1(D)(1)(d) a logbook (written or electronic No Yes NA Records manufact'g format) on -site and made available Review develop- to an authorized representative ment facility 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. [2D .0515] Fluoro- The Permittee shall submit the products results of any maintenance polymer FS-A 2.1(D)(1)(e) performed on the bagfilters within No Yes NA Records manufact'g 30 days of a written request by the Review develop- DAQ. ment facility [2Q .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 30 of 54 Source or Terms and Conditions Records was Deviation a Method(s) of Emission Control Deviation Maintained non- min Detering Source Description Device ID Permit Condition Condition Summary ? Y/ No (es ) ( Yes / No / compliance Compliance Comments No.(s) NA) issue? Status Number (Yes / No) Fluoro- The Permittee shall submit a products summary report of monitoring and polymer FS-A 2.1(D)(1)(f) recordkeeping activities No Yes NA Semi-annual manufact'g postmarked on or before January reports to NC develop- 30 of each calendar year for the Division of ment facility preceding six-month period Air Quality between July and December and FRO 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. [2D .0515 Fluoro- Visible emissions from the products affected source (ID Nos. FS-A) Polymer FS-A 2.1(13)(2)(a) shall not be more than 20 percent No NA NA Emission manufact'g opacity when averaged over a 6- source FS-A develop- minute period. However, 6-minute has no visible ment facility averaging periods may exceed 20 emissions percent not more than once in any hour and not more than four times in any 24-hour period, and shall the 6-minute average exceed 87 percent op acity. 2D .0521 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 31 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes { No ( ) ? ( Yes { No I compliance Compliance Comments No.(s) Condition Summary NA) issue? Status Number (Yes / No) Fluoro- If emissions testing is required, the products testing shall be performed in polymer FS-A 2.1(D)(2)(b) accordance with 15A NCAC 2D No NA NA NA manufact'g .2601 and General Condition JJ. develop- [2D .2601] ment facility Fluoro- No monitoring/recordkeeping/ products reporting is required for visible polymer FS-A 2.1(D)(2)(c) emissions from this source. [2Q No NA NA NA manufact'g .0508(f)] develop- ment facility Fluoro- In order to avoid applicability of products this regulation, the fluoroproducts polymer FS-A 2.1(D)(4)(a) polymer manufacturing No Yes NA Monthly manufact'g development facility (ID No. FS- Emissions develop- A) shall discharge into the Report ment facility atmosphere less than 40 tons of VOCs per consecutive t2-month 12 .0317 Fluoro- _period. Calculations of VOC emissions products per month shall be made within 30 polymer FS-A 2.1(D)(4)(b) days of the end of each month. No Yes NA Monthly manufact'g [2Q .0508(f)] Emissions develop- Report ment facility Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 32 of 54 Emission Source or Terms and Conditions Records Was Deviation a Method(s) of Source Control Deviation Maintained non- Determining Description Device ID No.(s) Permit Condition Condition Summary ? Yes / No ( ) ? es / No / compliance Compliance Comments Number NA) issue? Status (Yes / No) Fluoro- The total amount of VOC products emissions shall be recorded polymer FS-A 2.1(1))(4)(c) monthly in a logbook (written or No Yes NA Monthly manufact'g electronic format). Emissions develop- [2Q .0317] Report ment facility Fluoro- The Permittee shall submit a semi - products annual summary report, acceptable polymer FS-A 2.1(1))(4)(d) to the Regional Air Quality No Yes NA Semi-annual manufact'g Supervisor, of monitoring and reports to NC develop- recordkeeping activities Division of ment facility postmarked on or before January Air Quality 30 of each calendar year for the FRO 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. 2 .0508( 0 0 0 w c w Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 33 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Detennining Source Description Device ID Permit Condition ? Y/ N es o ( ) ? (Yes / No / compliance Compliance Comments No. s () Condition Summary rY issue? Status Number NA) (Yes / No) Emissions of particulate matter discharged into the atmosphere No. 2 fuel PS -Temp 2.1(G)(1)(a) from the combustion of fuel oil at No NA NA AP-42 oil -fired the temporary boiler (ID No. PS- calculation temporary Temp) shall not exceed 0.2426 boiler pounds per million Btu heat input. 2D .0503] If emissions testing is required, the No. 2 fuel testing shall be performed in oil -fired PS -Temp 2.1(G)(l)(b) accordance General Condition 77. No NA NA NA temporary [2D .2601] boiler No monitoring/recordkeeping/ No. 2 fuel reporting is required for particulate oil -fired PS -Temp 2.1(G)(1)(b) emissions from the firing of No. 2 No NA NA NA temporary fuel oil in this source for this boiler regulation. [2 .0508(f) Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 34 of 54 Source or Terms and Conditions Records was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Y es / No ( ) ? ( Yes / No / compliance Compliance Comments No.(s) Condition Summary NA) issue? Status Number (Yes / No) The Permittee shall comply with all applicable provisions, including No. 2 fuel PS -Temp 2.1(G)(2)(a) the notification, testing, No NA NA NA oil -fired recordkeeping, and monitoring temporary requirements contained in boiler 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." [2D .0524 The maximum sulfur content of No. 2 fuel any fuel oil received and burned in Certificate of oil -fired PS -Temp 2.1(G)(2)(b) the boiler (ID No. PS -Temp) shall No Yes NA Analysis from temporary not exceed 0.5 percent by weight. Oil Supplier boiler [2D .0524] Visible emissions shall not exceed 20 percent opacity (6 minute No. 2 fuel PS -Temp 2.1(G)(2)(c) average) except for one six -minute No NA NA Voluntary oil -fired period per hour but not more than daily temporary 27 percent opacity when firing fuel observations boiler oil. [2D .0524] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 35 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Detern,;n * Source Description Device ID Permit Condition ? Yes / No ( ) ? ( Yes / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) Within 60 days of installing any temporary boiler, the Permittee No. 2 fuel PS -Temp 2.1(G)(2)(d) shall conduct a Method 9 test (6- No Yes NA Method 9 oil -fired minute average of 24 Performance temporary observations) to determine the Test Report boiler opacity of stack emissions in dated accordance with 40 CFR 60.8, 40 05/06/2008 CFR 60.45c(a)(8), and General Condition JJ found in Section 3 of this permit. [2D .0524 The Permittee shall retain a record No. 2 fuel of the quantity of No. 2 fuel oil Fuel Oil oil -fired PS -Temp 2.1(G)(2)(e) fired at the affected boiler each No Yes NA Consumption temporary calendar month. [49 CFR Report boiler 60.48c(g)] [2Q .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 36 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? was Deviation a non- compliance Method(s) of Determ ining Compliance Comments Permit Condition Description No.(s) Condition Summary (Yes ) es / No ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall retain a copy of the fuel supplier certification for No. 2 fuel PS -Temp 2.1(G)(2)(f) any No. 2 fuel oil fired at the No Yes NA Certificates of oil -fired affected boiler. The fuel supplier Analysis from temporary certification shall include the Oil Supplier boiler 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. F213.05241 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 37 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit the following written notifications to No. 2 fuel PS -Temp 2.1(G)(2)(g) the Regional: No Yes NA Initial oil -fired i. An initial notification of the notification temporary date of actual initial startup of submitted on boiler the boiler within 15 days of 03/13/2008; such date; ii. An opacity observation Opacity notification indicate the observation anticipated date that the notification Permittee will be conducting submitted on the Method 9 opacity 03/31/2008; observation at least 30 days prior to such date; and, Performance iii. Performance test results with Test Report the results of the Method 9 submitted on opacity observation, shall be 05/06/2008 submitted within 30 days of the test. CZQ.05 08(*]- Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 38 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ?) was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Y/ No (es Y/ No / (es issue? Status Number NA) (Yes / No) Semiannual Report. In addition to any other reporting required by 40 No. 2 fuel PS -Temp 2.1(G)(2)(h) CFR 60.48c or notification No Yes NA Semi-annual oil -fired requirements to the EPA, the reports to NC temporary Permittee is required to provide a Division of boiler semiannual summary report of the Air Quality sulfur content of the distillate fuel FRO oil fired, which includes: 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. [2D .0524 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 39 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) In order to avoid applicability of 15A NCAC 2D .0530(g) for major No. 2 fuel PS -Temp 2.1(G)(3)(a) sources and major modifications, No Yes NA Monthly oil -fired the temporary boiler (ID No. PS- Emissions temporary Temp) shall discharge into the Report boiler atmosphere less 40 tons of sulfur dioxide per consecutive twelve- month period. [2 .0317] If emissions testing is required, the No. 2 fuel testing shall be performed in oil -fired PS -Temp 2.1(G)(3)(b) accordance with 15A General No NA NA NA temporary Condition 77. boiler [2D .2601] The Permittee shall keep monthly records of fuel usage in a logbook No. 2 fuel PS -Temp 2.1(G)(3)(c) (written or in electronic format), as No Yes NA Monthly oil -fired follows: Emissions temporary i. The total quantity (in 1,000 Report and boiler gal) of No. 2 fuel oil fired at Certificates of the boiler; and, Analysis from ii. The fuel oil supplier Oil Supplier certification for any fuel oil fired at the boiler, including the sulfur content of the oil (in percent by weight). [2 .0508( ] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 40 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation � Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall calculate monthly and 12-month rolling S02 No. 2 fuel PS -Temp 2.1(G)(3)(d) emissions from the temporary No Yes NA Monthly oil -fired boiler within 30 days after the end Emissions temporary of each calendar month. Report boiler 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 given equation. I Sum the S02 emissions from the boiler for the previous 12- month period to determine the 12-month rolling emission total. [2 .0317 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 41 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation Records Maintained Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary ry (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a semi- annual summary report, acceptable No. 2 fuel PS -Temp 2.1(G)(3)(e) to the Regional Air Quality No Yes NA Semi-annual oil -fired Supervisor, of monitoring and reports to NC temporary recordkeeping activities Division of boiler postmarked on or before January Air Quality 30 of each calendar year for the FRO 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. [2 .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 42 of 54 Terms and Conditions Records Was Emission Source or Deviation Maintained Deviation a Method(s) of Source Control Device ID Permit Condition ? ? non- compliance Determining Compliance Comments Description No.(s) Condition Summary s / No (Yes ) ( Yes / No / issue? Status Number NA) (Yes / No) Visible emissions from this source Emission (ID No. SGS-A) shall not be more source SGS-A SentryGlas SGS-A 2.1(11)(1)(a) than 20 percent opacity when No NA NA NA has no visible Manufac- averaged over a six -minute period. turing However, six -minute averaging emissions 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. [2D .0521] If emissions testing is required, the testing shall be performed in SentryGlas SGS-A 2.1(11)(1)(b) accordance with 15A NCAC 2D No NA NA NA Manufac- .2601and General Condition 7I. If turing 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. [2D .2601] SentryGlas No monitoring/recordkeeping/ Manufac- reporting is required for visible taring SGS-A 2.1(H)(1)(c) emissions from this source. [2Q No NA NA NA .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 43 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) ? es / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) Emissions of particulate matter Polyvinyl from the Product Collection Fluoride FS-B and 2.1(I)(1)(a) Systems at the polyvinyl fluoride No NA NA AP-42 Polymer FS-C manufacturing facilities (Vent calculation Manufac- Nos. FEP-134 & FEP-C4) shall not taring exceed an allowable emission rate Facilities No. as calculated by the given 1 & 2 equation. [2D .0515] If emissions testing is required, the Polyvinyl testing shall be performed in Fluoride FS-B and 2.1(I)(1)(b) accordance with General No NA NA NA Polymer FS-C Condition JJ. Manufac- [2D .2601] turing Facilities No. 1&2 Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 44 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition Yes / No ( ) ( Yes / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) The Permittee shall maintain production records such that the Polyvinyl FS-B and 2.1(I)(1)(c) process rates "P" in tons per hour, No Yes NA PVF Fluoride FS-C as specified by the formulas Production Polymer contained above (or the formulas Records Manufac- contained in 15A NCAC 2D turing .0515) can be derived, and shall Facilities No. make these records available to a 1 & 2 DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the production records are not maintained.[2 .0508(f)] The Permittee shall submit a summary report of monitoring and Polyvinyl FS-B and 2.1(I)(1)(d) recordkeeping activities No Yes NA Semi-annual Fluoride FS-C postmarked on or before January reports to NC Polymer 30 of each calendar year for the Division of Manufac- preceding six-month period Air Quality turing between July and December and FRO Facilities No. July 30 of each calendar year for 1 & 2 the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. [2 oso8(t)I Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 45 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) ? ( Yes / No / compliance Compliance Comments No.(s) Condition Summary issue? Status Number NA) (Yes / No) Visible emissions from the Product Collection Systems at the Polyvinyl FS-B and 2.1(I)(2)(a) polyvinyl fluoride manufacturing No Yes NA Monthly Fluoride FS-C facilities (Vent Nos. FEP-B4 & visual Polymer FEP-C4) shall not be more than 20 observations Manufac- percent opacity when averaged turing over a six -minute period. Facilities No. However, six -minute averaging 1 & 2 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. [21) .0521] If emissions testing is required, the testing shall be performed in Polyvinyl FS-B and 2.1(1)(2)(b) accordance with 15A NCAC 2D No NA NA NA Fluoride FS-C .2601 and General Condition JJ. Polymer If the results of this test are above Manufac- the limit given in Section 2.1 1.2.a. turing above, the Permittee shall be Facilities No. deemed in noncompliance with • 1 & 2 15A NCAC 2D .0521. [2D .2601] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 46 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary �' (Yes / No) (Yes / No / issue? Status Number NA) (Yes / No) To assure compliance, once a month the Permittee shall observe Polyvinyl FS-B and 2.1(I)(2)(c) the emission point of the affected No Yes NA Monthly Fluoride FS-C source for any visible emissions visual Polymer above normal. The monthly observation Manufac- observation must be made for each record turing month of the calendar year period Facilities No. to ensure compliance with this 1 & 2 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, or ii. Demonstrate that the percent opacity from the emission points of the emission source is below the limit given in Section 2.1 I.2.a. above. [2Q.0508( f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 47 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation Records Maintained Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary es / No (Yes ) ( Yes / No / issue? Status Number NA) (Yes / No) The results of the monitoring shall be maintained in a logbook Polyvinyl FS-B and 2.1(I)(2)(d) (written or electronic format) on- No Yes NA Monthly Fluoride FS-C site and made available to an visual Polymer authorized representative upon observation Manufac- request. The logbook shall record record turing the following: Facilities No. i. The date and time of each 1 & 2 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. 2 .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 48 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Device ID Permit Condition ? ? compliance Compliance Comments Description No.(s) Condition Summary ry (Yes / No) (Yes / No I issue? Status Number NA) (Yes / No) The Permittee shall submit a summary report of the Polyvinyl FS-B and 2.1(1)(2)(e) observations postmarked on or No Yes NA Semi-annual Fluoride FS-C before January 30 of each calendar reports to NC Polymer year for the preceding six-month Division of Manufac- period between July and Air Quality turing December and July 30 of each FRO Facilities No. calendar year for the preceding 1 & 2 six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. [2 .0508(f)] In order to avoid applicability of Polyvinyl this regulation, the Polyvinyl The PVF Fluoride FS-B and 2.1(I)(4)(a) Fluoride (PVF) Manufacturing No NA NA NA Manufac- Polymer FS-C Facility No. 1 and No. 2 (ID Nos. turing Facility Manufac- FS-B and FL-C) shall discharge No. 2 tuning into the atmosphere less than 40 (FS-C) has Facilities No. tons of VOCs per consecutive 12- not started up 1 & 2 month period. as of 12/31/08 [2Q .0317] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 49 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? Yes / No ( ) � ( Yes / No / compliance Compliance Comments No.(s) Condition Summary issue7 Status Number NA) (Yes / No) Polyvinyl If emissions testing is required, the Fluoride Permittee shall perform such Polymer FS-B and 2.1(I)(4)(b) testing in accordance with General No NA NA NA Manufac- FS-C Condition JJ. [2D .2601] turing Facilities No. 1&2 To demonstrate compliance with the limit provided in Section 2.1 Polyvinyl FS-B and 2.1(I)(4)(c) I.4.a., each calendar month No NA NA NA The PVF Fluoride FS-C ollowin the initial start-up of the Manufac- Polymer PVF Manufacturing Facility No. 2 turing Facility Manufac- (ID No. FS-C), the Permittee shall No. 2 turing create and retain production (FS-C) has Facilities No. records and estimate associated not started up 1 & 2 VOC emissions as specified. as of 12/31/08 [2Q .0508(f)] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 50 of 54 Emission Source or Terms and Conditions Deviation Records Maintained Was Deviation a Method(s) of Permit Condition Source Control Device ID ? ? non- compliance Determining Compliance Comments Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a semi- annual summary report of Polyvinyl FS-B and 2.1(I)(4)(d) monitoring and recordkeeping No NA NA NA The PVF Fluoride FS-C activities. The report shall contain Manufac- Polymer the following: turing Facility Manufac- i. The monthly VOC emissions No. 2 turing from two affected polyvinyl (FS-C) has Facilities No. fluoride manufacturing not started up 1 & 2 operations for the previous 17 as of 12/31/08 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 .osos(t)1 In order to avoid applicability of No. 2/No. 6 this regulation, the affected boilers fuel oil -fired PS-1, PS- 2.2(A)(1)(a) (ID Nos. PS-1, PS-2, and PS- No Yes NA Monthly boilers 2, and Temp) shall discharge into the Emissions and PS -Temp atmosphere less than 702.5 tons of Report No. 2 fuel S02 per consecutive 12-month oil -fired period. boiler [2Q .0317] Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 51 of 54 Source or Terms and Conditions Records Was Deviation a Method(s) of Emission Control Deviation Maintained non- Determining Source Description Device ID Permit Condition ? (Yes / No) ? (Yes / No / compliance Compliance Comments No.(s) Condition Summary �1' NA) issue? Status Number (Yes / No) If emissions testing is required, the No. 2/No. 6 Permittee shall perform such fuel oil -fired PS-1, PS- 2.2(A)(1)(b) testing in accordance with General No NA NA NA boilers 2, and Condition JJ. and PS -Temp [2D .2601] No. 2 fuel oil -fired boiler The Permittee shall keep monthly No. 2/No. 6 records of fuel usage in a logbook fuel oil -fired PS-1, PS- 2.2(A)(1)(c) (written or in electronic format), as No Yes NA Fuel boilers 2, and follows: Consumption and PS -Temp i. The total quantity (in 1,000 Records and No. 2 fuel gal) of No. 2 and No. 6 fuel Certificates of oil -fired oil fired at the affected Analysis from boiler boilers; and, Oil Supplier ii. 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). [2 .0508( Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 52 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No. s () Condition Summary( Yes / No ) es / No / issue? Status Number NA) (Yes / No) The Permittee shall calculate No. 2/No. 6 monthly and 12-month rolling S02 fuel oil -fired PS-1, PS- 2.2(A)(1)(d) emissions from the affected boilers No Yes NA Emissions boilers 2, and within 30 days after the end of determined and PS -Temp each calendar month. Calculations monthly using No. 2 fuel shall be recorded in a logbook AP-42 factors oil -fired (written or electronic format), boiler according to the following formulas: i. Calculate S02 emissions from the previous calendar month using the specified equation. ii. Sum the S02 emissions from the affected boilers for the previous 12-month period to determine the 12-month rolling emission total. [2 .0317] 0 m p' C� n I 0 0 0 w ch m m w Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 53 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Y/ No (es ) ( Yes / No / issue? Status Number NA) (Yes / No) The Permittee shall submit a semi - No. 2/No. 6 annual summary report of fuel oil -fired PS-1, PS- 2.2(A)(1)(e) monitoring and recordkeeping No Yes NA Semi-annual boilers 2, and activities postmarked on or before reports to NC and PS -Temp January 30 of each calendar year Division of No. 2 fuel for the preceding six-month period Air Quality oil -fired between July and December, and FRO boiler 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 two affected boilers for the previous 17 calendar months; ii. The 12-month rolling SOz 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 .0508(f) Permit 03735T33 TITLE V AIR PERMIT COMPLIANCE SUMMARY REPORT For Calendar Year 2008 Page 54 of 54 Emission Source Source or Control Device ID Terms and Conditions Deviation ? Records Maintained ? Was Deviation a non- compliance Method(s) of Determining Compliance Comments Permit Condition Description No.(s) Condition Summary Yes / No ( ) ( Yes / No / issue? Status Number NA) (Yes / No) 40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION All sources All 2.2(B)(4) REQUIREMENTS: RISK No Yes NA Risk MANAGEMENT PROGRAMS Management UNDER THE CLEAN AIR ACT, Plan submittal 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. 40 CFR Part 68]