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HomeMy WebLinkAbout5106_Blackwood_Airpermit_20190329ROY COOPER Governor MICHAEL S. REGAN Secretary MICHAEL A. ABRACZINSKAS Director Mr. Ryan Conrad Vice President Blackwood Associates, LLC 699 West Dillman Road Bloomington, IN 47401 NORTH CAROLINA Environmental Quality March 29, 2019 Subject: Air Permit No. 10312R02 Blackwood Associates, LLC Newton Grove, Johnston County, North Carolina Permit Class: Synthetic Minor Facility ID# 5100210 Dear Mr. Conrad: In accordance with your completed application received March 4, 2019, we are forwarding herewith Permit No. 10312R02 to Blackwood Associates, LLC, Newton Grove, Johnston County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. 15013-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 15013-23. Unless exempted by a condition of this permit or the regulations, construction of new North Carolina Department of Environmental Quality I Division of Air Quality �i Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, NC 27609 4 7f:tCN:iLNl4 �� 0"Allmmt of Brvke —ul owl ��""`� 919.791.4200 T 1 919.881.2261 F Ryan Conrad March 29, 2019 Page 2 air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143- 215.114B. This permit shall be effective from March 29, 2019 until September 30, 2026, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Specific changes and additions are summarized below (note: this list may not include all changes and additions): Facility name and ownership changed from West Farms — Shaving Mill to Blackwood Associates, LLC. Should you have any questions concerning this matter, please contact Elisabeth Nystrom at 919- 791-4200. Sincerely, / I T. Ray Stewa J ., E., CPM, Regional Supervisor Division of Air uality, NC DEQ AEN Enclosures c: Raleigh Regional Office NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY AIR PERMIT NO. 10312R02 Issue Date: March 29, 2019 Expiration Date: September 30, 2026 Effective Date: March 29, 2019 Replaces Permit: 10312ROI To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21 B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations, Blackwood Associates, LLC 1683 Barefoot Road Newton Grove, Johnston County, North Carolina Permit Class: Synthetic Minor Facility ID# 5100210 (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: Emission Emission Source Control Control System Source ID Description System ID Description wood -fired fluidized bed burner (20 million ES-2, ES-3 Btu/hour heat input, ID No. ES-2) connected CD-2 cyclone (96 inches in diameter) to a rotary shavings dryer (1620 cubic foot per hour capacity, ID No. ES-3) in accordance with the completed application 5100210.19A received March 4, 2019 including any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter Permit No. 10312R02 Page 2 2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0535, 2D .0540, 2D .1100, 2D .1806, 2Q .0315 and 2Q .0711. 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q .0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2025 calendar year. 3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes," particulate matter emissions from the emission sources shall not exceed allowable emission rates. The allowable emission rates are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be determined by the following equation(s), where P is the process throughput rate in tons per hour (tons/hr) and E is the allowable emission rate in pounds per hour (lbs/hr). E = 4.10 * (P) 0-" for P <= 30 tons/hr, or E = 55 * (P) 0- " - 40 for P >30 tons/hr 4. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 213.0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six -minute period, except that six -minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with a visible emissions standard in 15A NCAC 2D .0524 "New Source Performance Standards" or. I 110 "National Emission Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521 visible emissions standard. 6. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, Permit No. 10312R02 Page 3 ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration, and V. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 7. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints are received or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads). 8. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT - Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration, the following permit limits shall not be exceeded: Affected Source(s) Toxic Air Pollutant Emission Limit Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic 3.85 pounds per year compounds) (ASC (7778394)) !Nos. burner/dryer (ID Benzene (71-43-2) 498.88 pounds per year ES-2 and ES-3) Formaldehyde (50-00-0) 1.11 pounds per hour r(7 Hy drogen chloride (hydrochloric acid) 647-01-0) )9.12 pounds per day Manganese & compounds (MNC) 0.77 pounds per day 9. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not operate the facility without implementing management practices or installing and operating Permit No. 10312R02 Page 4 odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. 10. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility -wide emissions shall be less than the following: Pollutant Emission Limit (Tons per consecutive 12-month period) PM10 100 VOC 100 CO 100 a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply: i. The throughput of oven dried shavings shall not exceed 23,450 tons per consecutive 12-month period. b. Inspection and Maintenance Requirements - i. Cyclone Requirements - Particulate matter emissions shall be controlled as described in the permitted equipment list. To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform an annual (for each 12 month period following the initial inspection) inspection of the cyclone system. In addition, the Permittee shall perform periodic inspections and maintenance (I&M) as recommended by the manufacturer. c. Recordkeeping Requirements i. The Permittee shall record monthly and total annually the following: A. The throughput of oven dried shavings, and B. The facility -wide PM-10, CO, and VOC emissions. d. Reporting Requirements - Within 30 days after each calendar year, regardless of the actual emissions, the Permittee shall submit the following: emissions and/or operational data listed below. The data should include monthly and 12 month totals for the previous 12 month period. A. The throughput of oven dried shavings, and B. The facility -wide PM-10, CO, and VOC emissions. 11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed Permit No. 10312R02 Page 5 toxic air pollutants (TAPs), the Permittee has made a demonstration that facility -wide actual emissions, where one or more emission release points are obstructed or non -vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPS from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 2Q .071 I (a). a. A permit to emit any of the below listed TAPS shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible for obtaining a permit to emit TAPS and for demonstrating compliance with the requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants". c. In accordance with the approved application, the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: Pollutant Carcinogens (lb/yr) Chronic Toxicants (lb/day) Acute Systemic Toxicants (lb/hr) Acute Irritants (lb/hr) Acetaldehyde (75-07-0) F—r 6.8 Acrolein (107-02-8) 0.053 6.02 Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic compounds) (ASC (7778394)) Benzo(a)pyrene (Component of 83329/POMTV & 56553/7PAH) (50- 32-8) 2.2 Beryllium Metal (unreacted) (Component of BEC) (7440-41-7) 0.28 Cadmium Metal, elemental, unreacted (Component of CDC) (7440-43-9) 0.37 Carbon tetrachloride (56-23-5) 460 F— Chlorine (7782-50-5) F 0. 99 0.23 Chlorobenzene (108-90-7) 46 290 �— Chloroform (67-66-3) Chromium (VI) Soluble Chromate Compounds (Component of CRC) I 0.013 (SolCR6) i 1DEHP (Di(2-ethylhexyl)phthalate) (117-81-7) FO.63 Permit No. 10312R02 Page 6 Ethylene dichloride (1,2- dichloroethane) (107-06-2) 260 Hexachlorodibenzo-p-dioxin 0.0051 1,2,3,6,7,8 (57653-85-7) MEK (methyl ethyl ketone, 2- I 78 F22.4 butanone) (78-93-3) F(74 rcury, vapor (Component of HGC) 0.013 39-97-6) Methyl chloroform (71-55-6) 1 250 I 1 64 Methylene chloride (75-09-2) 1600 0.39 F— Nickel metal (Component of N1C) 0.13 (7440-02-0) PCB (polychlorinated biphenyls) (1336-36-3) 5.6 E Pentachlorophenol (87-86-5) 0.063 0.0064 �— P (tetrachloroethylene) (127-18-4) erchloroethylene i 3QOQ F Phenol (108-95-2) Styrene (10042-5) �— TCE (trichloroethylene) (79-01-6) 4000 Tetrachlorodibenzo-p-dioxin, 2,3,7,8- (Component of CLDC & 0.Q002 83329/POMTV) (1746-01-6) Tetrachloroethane, 1,1,2,2- (79-34-5) 430 0.24 2.7 Toluene (108-88-3) 1 1 98 1 1 14.4 Vinyl chloride (75-01-4) 26 F �— Xylene (mixed isomers) (1330-20-7) 57 1 F-16.4 Permit No. 10312R02 Page 7 B. GENERAL CONDITIONS AND LIMITATIONS 1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the: Regional Supervisor North Carolina Division of Air Quality Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 919-791-4200 For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number. 2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605, any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or c. changes in the quantity or quality of materials processed. If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. In Permit No. 10312R02 Page 8 accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and maintained at all times in a manner that will effectuate an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device(s) and appurtenances. 7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. 9. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority. 10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but is not limited to, process weight rates, firing rates, hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.11413, and 143-215.114C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the responsibility of complying with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site. 15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section I I2(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. Permit No. 10312R02 Page 9 16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases - Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally -enforceable only. 17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall follow the procedures for obtaining any required audit sample and reporting those results. Permit issued this the 291h of March, 2019. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION T. Ray Ste rt Jr., P.E., CP Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 10312R02 ATTACHMENT to Permit No. 10312R02, March 29, 2019 Insignificant / Exempt Activities Source rfES-1A - green wood chipper/shaver (25 tons per hour capacity) S-2A - green wood chipper/shaver 5 tons per hour capacity) S-3A - woodwaste handling Exemption Regulation Source of Source of Title V TAPs? Pollutants? 2Q .0102 (h)(5) No i Yes I2Q .0102 (h)(5) No Yes 2Q .0102 (h)(5) I No J Yes 1. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates Requiring a Permit." 3. Sample permit conditions showing the regulatory requirements for exempt sources subject to NESHAP, NSPS, and NCAC rules may be found here: htips:Hdeq. nc. gov/about/divisions/air-quality/air-quality-permits/specific-permit-conditions- regulatory-wide