donald r. van der vaart secretary - north carolina quality/permits/draft_permits/hexion... · mr....
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State of North Carolina | Environmental Quality | Air Quality
1641 Mail Service Center | 217 W. Jones Street, Suite 4000 | Raleigh, NC 27609-1641
919 707 8400 T
PAT MCCRORY Governor
DONALD R. VAN DER VAART Secretary
SHEILA C. HOLMAN Director
XXXX, 2015
Mr. Kevin Morris
Site Leader
Hexion Inc. – Fayetteville Facility
1411 Industrial Drive
Fayetteville, North Carolina 28301
SUBJECT: Air Quality Permit No. 03387T44
Facility ID: 2600009
Hexion Inc. – Fayetteville Facility
Fayetteville, Cumberland County
Fee Class: Title V
PSD Status: Minor
Dear Mr. Morris:
In accordance with your completed Air Quality Permit Applications for renewal and minor
modification of your Title V Permit received April 25, 2014, October 7, 2014, and February 12,
2015, we are forwarding herewith Air Quality Permit No. 03387T44 to Hexion Inc. – Fayetteville
Facility at 1411 Industrial Drive in Fayetteville, North Carolina authorizing the operation of the
emission sources and associated air pollution control devices specified herein. Additionally, any
emissions activities determined from your Air Quality Permit Application as being insignificant
per 15A North Carolina Administrative Code 02Q .0503(8) have been listed for informational
purposes as an "ATTACHMENT." Please note the requirements for the annual compliance
certification are contained in General Condition P in Section 3. The current owner is responsible
for submitting a compliance certification for the entire year regardless of who owned the facility
during the year.
As the designated responsible official it is your responsibility to review, understand, and
abide by all of the terms and conditions of the attached permit. It is also your responsibility to ensure
that any person who operates any emission source and associated air pollution control device subject
to any term or condition of the attached permit reviews, understands, and abides by the condition(s)
of the attached permit that are applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality Permit are
unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days
following receipt of this permit, identifying the specific issues to be contested. This hearing request
must be in the form of a written petition, conforming to NCGS (North Carolina General Statutes)
150B-23, and filed with both the Office of Administrative Hearings, 6714 Mail Service Center,
Raleigh, North Carolina 27699-6714 and the Division of Air Quality, Permitting Section, 1641 Mail
Service Center, Raleigh, North Carolina 27699-1641. The form for requesting a formal adjudicatory
Mr. Morris
XXXX, 2016
Page 2
hearing may be obtained upon request from the Office of Administrative Hearings. Please note that
this permit will be stayed in its entirety upon receipt of the request for a hearing. Unless a request
for a hearing is made pursuant to NCGS 150B-23, this Air Quality Permit shall be final and binding
30 days after issuance.
You may request modification of your Air Quality Permit through informal means pursuant
to NCGS 150B-22. This request must be submitted in writing to the Director and must identify the
specific provisions or issues for which the modification is sought. Please note that this Air Quality
Permit will become final and binding regardless of a request for informal modification unless a
request for a hearing is also made under NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in
this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior
to construction unless the Permittee has fulfilled the requirements of GS 143-215.108A(b) and
received written approval from the Director of the Division of Air Quality to commence
construction. Failure to receive an Air Quality Permit or written approval prior to commencing
construction is a violation of GS 143-215.108A and may subject the Permittee to civil or criminal
penalties as described in GS 143-215.114A and 143-215.114B.
Cumberland County has been triggered for increment tracking under PSD for sulfur dioxide
(SO2) and PM10. However, no changes in actual emissions of these pollutants are associated with this
permit renewal/modification.
This Air Quality Permit shall be effective from XXXX, 2016 until XXXX, 2021, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein. Should you have any questions concerning this matter, please contact Betty
Gatano, P.E., at (919) 707-8736 or [email protected].
Sincerely,
William D. Willets, P.E., Chief, Permitting Section
Division of Air Quality, NCDEQ
Enclosure
cc: Heather Ceron, EPA Region 4 (with review)
Steven Vozzo, Fayetteville Regional Office, Supervisor
Connie Horne, Raleigh Central Office
Central Files
ATTACHMENT to Permit No. 03387T44
Insignificant Activities per 15A NCAC 2Q .0503(8)
Source ID Number Emission Source Description
IDTS Formaldehyde plant No. 4 dilute tank (may be rerouted to process or atmosphere)
IDTP Formaldehyde plant No. 4 distillate tank (may be rerouted to process or atmosphere)
IAAD Formaldehyde plant No.1/2 acetic acid drums and totes
IDTA Dowtherm tank (800 gallon)
IDTB Dowtherm tank (1,800 gallon)
IWWT Resin reactor wash water tank (30,000 gallon)
ITEA Triethanolamine storage tank (10,000 gallon)
IAA Aqueous ammonia tank (20,000 gallon)
IPFMT Urea formaldehyde resin and phenol formaldehyde resin dry material hoppers and mixing tanks
IATE Triethylamine drums and totes
ITBT Sodium lignosulfonate and glycerin solution and temulose/beet molasses tank
IFORMDT
MACT EEEE
Formaldehyde/UFC product drum and tote loading
IPW Parts washer
IDSTA Diesel fuel storage tank 270 gallons capacity
IDSTB Diesel fuel storage tank 270 gallons capacity
IDSTC Diesel fuel storage tank 200 gallons capacity
IFOST Fuel oil storage tank (36,000 gallons)
IURCU Urea Railcar Unloading
IAAT Anhydrous ammonia tank, 40,000 gallons capacity
IRPU Resin product unloading
IRWT1 and IRWT2 Two resin water tanks (18,000 gallons each)
IRPT4
MACT EEEE
Phenol unloading – track 4
IRCHT4 Caustic unloading and liquid hexamine loading/unloading – track 4
IRWT4 Slack wax unloading and emulsified wax loading/unloading – track 4
IRTBMT4 Unload temulose/beet molasses – track 4
IRAT5 Anhydrous ammonia unloading – track 5
IRMT6
MACT EEEE
Methanol unloading – track 6
ITUNL-6FO Unload fuel oil
ITUNL-AA Unload anhydrous ammonia at tank
ITUNL-TEA Unload triethanolamine
ITUNL-SA Unload stearic acid
ITUNL-MT
MACT EEEE
Unload methanol trucks
ITUNL-R4 Unloading dock R4 warehouse
IWD Warehouse dock
Source ID Number Emission Source Description
ITUNL-MD
MACT EEEE)
unload methanol distillate
ITUNL-DEG/C Unload DEG and catalyst totes
ITUNL-FMU
MACT EEEE
Unload formaldehyde, methaform, and UFC trucks/railcars
ITUNL-H Unload liquid hexamine
ITUNL-GLY Glycerin truck unloading
ITUNL-SLS Sodium lignosulfonate unloading
I105 Wastewater holding basin (25,7000 gallons)
ICT Cooling water towers
ICS Caustic storage
IBP-1, IBP-2, and
IBP-3
Reactor 4 three blow pots (approximately 100 gallons each)
ISP Reactor 4 slurry pot (approximately 100 gallons)
IUWC3 Urea water, defoamer , and catalyst tank (16,000 gallons)
IUWLOAD Urea water truck and railcar loading
IB2-1 and IB2-2 Reactor 2, two blow pots (approximately 100 gallons each)
IB3-1 and IB3-2 Reactor 3, two blow pots (approximately 100 gallons each)
I-FWT Fire water storage tank
I-LST Lime storage tank
I-T300 T-300 scrubber tank
I-DWT Deionized water tank
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement or that
the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D .1100, “Control of Toxic Air
Pollutants” or 15A NCAC 02Q .0711, “Emission Rates Requiring a Permit.”
Summary of Changes to Permit
The following changes were made to the Hexion Inc. – Fayetteville Facility, Air Permit No. 03387T44
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
Cover and
throughout
-- Cover and
throughout
-- Updated all dates and permit revision numbers.
-- Insignificant
Activities List
-- Insignificant
Activities List Added reactor 2, two blow pots
(approximately 100 gallons each) (ID Nos.
IB2-1 and IB2-2).
Added reactor 3, two blow pots
(approximately 100 gallons each) (ID Nos.
IB3-1 and IB3-2).
Added fire water storage tank (ID No. I-
FWT).
Added lime storage tank (ID No. I-LST).
Added T-300 scrubber tank (ID No. I-T300).
Added a glycerin truck unloading (ID No.
ITUNLY-GLY).
Added sodium lignosulfonate unloading (ID
No. SLS)
Added deionized water tank (ID No. I-DWT).
Added MACT Subpart EEEE label to
applicable storage tanks.
-- Table of
Contents
-- Table of
Contents
Added Section 2.3, Other Applicable
Requirements, for 112(r).
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
3 – 8 Section 1.0 –
Equipment List
3 – 9 Section 1.0 –
Equipment List Modified silver formaldehyde process
description (ID Nos. FORM12 and FORM3)
to simplify description and specify that Plant
1 and 2 boiler (ID No. CDB1) and Plant 3
boiler (ID No. CDB2) serve as control
devices.
Revised description of how emissions are
returned to formaldehyde processes (ID Nos.
FORM12, FORM3, or ES16) for product
recovery.
Added labels on distillation column raw
product feed tanks (ID Nos. CFR12 and
CFR3) indicating that they are subject to 40
CFR Part 63, Subpart G, as Group 2 storage
vessels.
Added capacity to descriptions of the
distillation columns (ID Nos. CFR12 and
CFR3).
Added methanol reflux tank and product
sump to equipment under the silver catalyst
formaldehyde process (ID No. FORM3).
Added heat exchanger (ID No. HX12).
Changed description of catalytic fume
incinerator (ID No. CD17) to catalytic
oxidizer.
Clarified that emission sources FORMEQLK
and HEXAEQLK equipment have no add-on
control devices.
Grouped together emission sources in resin
production process being controlled by
packed bed scrubbers CD200A and CD200B.
Modified control options allowing load out
operations (ID Nos. RLOAD3 and
TLOAD2A) to vent to the atmosphere.
Modified description of storage tanks (ID
Nos. MOSTORE 1A through MOSTORE 1A
and MOSTORE 2) to specify that the store
50% wt formaldehyde, UFC, and hydrolyzed
re-work resin.
Removed liquid hexamine storage tank (ID No.
ESLH2).
Added label indicating that boilers (ID Nos.
ES3 and ES4) are subject to MACT DDDDD.
Removed footnotes discussing minor
modifications.
Added footnotes specifying compliance dates
for MACT Subpart DDDDD.
9 2.1.A –
Regulations
Table
10 2.1.A –
Regulations
Table
Removed equation under 02D .0503 and
replaced with numerical PM emission limit.
Reordered table so that regulations follow
numerical order.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
10 2.1.A.2
10 2.1.A.1
Moved regulation 15A NCAC 02D .0503 to
Section 2.1.A.1.
Removed equation under 15A NCAC
02D .0503 and replaced with numerical PM
emission limit.
Revised testing language to reflect most
current permit language.
10 2.1.A.3
11 2.1.A.2 Moved regulation 15A NCAC 02D .0516 to
2.1.A.2.
10 2.1.A.4
11 2.1.A.3
Moved regulation 15A NCAC 02D .0521 to
2.1.A.3.
10 2.1.A.1 11 2.1.A.4 Moved regulation 15A NCAC 02D .1111 to
2.1.A.4.
10 2.1.B –
Regulations
Table
12 2.1.B –
Regulations
Table
Removed the term “superseded” from the
table. This term is not correctly used in this
situation.
Reordered table so that regulations follow
numerical order.
-- -- 12 2.1.B.1
Added condition specifying that the Permittee is
subject to 40 CFR Part 60, Subpart VV and
complies with this rule by complying with 40
CFR Part 63, Subpart H.
-- -- 13 2.1.B.2
Added condition specifying that the Permittee is
subject to 40 CFR Part 60, Subpart III and
complies with this rule by complying with 40
CFR Part 63, Subpart G for Group 1 process
vents.
12 – 14 2.1.B.1 13 2.1.B.3
Added noncompliance statements throughout
condition.
-- -- 13, 15 2.1.B.3.e and
2.1.B.3.cc
Added testing requirements for new catalytic
oxidizer (ID No. CD17).
14 2.1.C 15 2.1.C Added heat exchanger (ID No. HX12).
14 – 16 2.1.C.1 16 – 17 2.1.C.1 Added noncompliance statements throughout
condition.
17 – 29 2.1.D 17 – 30 2.1.D Changed the title of this section to “Process
Equipment Subject to 40 CFR Part 63,
Subpart H (LDAR).”
Clarified the equipment in the equipment list.
Added noncompliance statements throughout
the section.
Added references.
30 – 31 2.1.E 30 2.1.E Changed the title of this section to “Urea Storage,
Handling, and Conveying.”
2.1.E
Regulations
Table and
2.1.E.1.a
30 – 31 2.1.E
Regulations
Table and
2.1.E.1.a
Added equation for allowable PM emission limit
under 02D .0515 for process rates above 30 tons
per hour.
30 2.1.E.1.c 31 2.1.E.1.c Updated the permit condition for monitoring
under 15A NCAC 02D .0515 to reflect the most
current permit language.
31 2.1.E.2.c 32 2.1.E.2.c Updated the permit condition for monitoring
under 15A NCAC 02D .0521 to reflect the most
current permit language.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
32 – 33 2.1.F 32 – 33 2.1.F Changed the title of this section to “Equipment
Subject to 40 CFR Part 63, Subpart G, Group 2
Process Vents, Storage Vessels, Transfer
Operations, and Wastewater Operations”
Revised permit to include all emission sources
Group 2 equipment as defined under 40 CFR
Part 63, Subpart G under this permit condition.
As a result, Group 2 Storage Tanks and Group
2 Transfer operations, which were previously
listed under Section 2.1.K, are now included in
2.1.F.
Added distillation column raw product feed
tanks (ID Nos. CFR12 and CFR3), which are
subject to 40 CFR Part 63, Subpart G, as Group
2 storage vessels.
Modified description of storage tanks (ID Nos.
MOSTORE 1A through MOSTORE 1A and
MOSTORE 2) to specify that they store 50%
wt formaldehyde, UFC, and hydrolyzed re-work
resin.
Added the option for the load operations (ID
Nos. RLOAD3 and TLOAD2A) to vent to the
atmosphere.
Removed superscripts on emission sources.
32 2.1.F –
Regulations
Table
33 2.1.F –
Regulations
Table
Revised permit to include all Group 2
equipment under 40 CFR Part 63, Subpart G
under this permit condition.
Removed superscripts and specified more
clearly which emission sources are subject to
each regulation.
32 2.1.F.1.f 34 2.1.F.1.f Moved condition requiring records pursuant to
Section 2.2. “Multiple Emission Sources”
requirements from reporting section to
recordkeeping section.
33 2.1.F.1.g 34 2.1.F.1.g Added noncompliance statement.
-- 2.1.F.1.i 34 2.1.F.1.i Added condition requiring submittal of
applicable reports pursuant to Section 2.2
“Multiple Emission Sources” requirements.
-- --
34 2.1.F.2
Moved condition for Group 2 storage vessels
from Section 2.1.K.1 to 2.1.F.2.
Added noncompliance statement.
-- --
35 2.1.F.3
Moved condition for Group 2 transfer racks
from Section 2.1.K.2 to 2.1.F.3.
Added noncompliance statement.
33 2.1.F.2
35 2.1.F.4
Moved condition for Group 2 wastewater
from Section 2.1.F.2 to Section 2.1.F.4.
Added noncompliance statement.
34 2.1.G –
Equipment List
35 – 36 2.1.G –
Equipment List Revised permit to include all emission
sources in the Resin Production under this
permit condition. As a result, tanks in the
Resin Production Process that were
previously listed under Section 2.1.K are now
included in Section 2.1.G.
Removed superscripts on emission sources.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
34 2.1.G –
Regulations
Table
36 2.1.G –
Regulations
Table
Removed superscripts and specified more
clearly which emission sources are subject to
each regulation.
Removed requirement specifying that CVS3
and NRBPV1 are subject to the startup,
shutdown, and malfunction procedures under
40 CFR 63, Subpart A.
34 2.1.G.1.a 37 2.1.G.1.a Removed superscripts and listed equipment
subject to 15A NCAC 02D .0515.
35 2.1.G.1.c 37 2.1.G.1.c Added requirement specifying that no monitoring
or recordkeeping of RTU mix tank (ID No.
ES103) with associated particle separator (ID No.
CD-104PS) and a wet scrubber (ID No. CD-
104S) is required for compliance with NCAC
02D .0515.
35 2.1.G.1.d 37 2.1.G.1.d Updated monitoring and recordkeeping
requirements under NCAC 02D .0515 with most
current permitting language.
35 2.1.G.2.c 37 2.1.G.2.c Updated monitoring requirements under NCAC
02D .0521 with most current permitting
language.
-- -- 38 2.1.G.3.c Added emission limits for pressure relief devices.
36 2.1.G.3.c 38 2.1.G.3.d Removed statement specifying that the emission
limits do not apply during SSM.
36 2.1.G.3.d 38 2.1.G.3.e Revised language relating to shut down of a
control device.
36 2.1.G.3.e 38 2.1.G.3.f Removed language regarding SSM and added
general duty language.
36 2.1.G.3.h -- -- Removed statement referencing a deviation of the
SSM plan.
37 2.1.G.3.l 39 2.1.G.3.l Added noncompliance statement.
37 2.1.G.3.m 39 2.1.G.3.m Added noncompliance statement.
37 2.1.G.3.n 39 2.1.G.3.n Removed references to SSM.
-- --- 39 – 40 2.1.G.3.o. and p Added requirements for pressure relief devices
subject to MACT Subpart OOO.
38 2.1.G.3.p.iii 40 2.1.G.3.r.iii Removed references to SSM.
38 2.1.G.3.t 41 2.1.G.3.v Removed references to SSM.
-- -- 41 2.1.G.3.w Added noncompliance statement.
-- 2.1.G.3.v
41 2.1.G.3.y
Clarified requirement specifying exemptions to
reporting requirements.
38 2.1.G.w
-- -- Removed requirement for submitting reports in
accordance with Part 3, General Conditions.
This requirement is redundant.
38 – 39 2.1.3.G.x 41 2.1.3.G.z Removed references to the term “exceedance.”
Exceedance as defined in this permit condition is
not included in 40 CFR Part 63, Subpart OOO.
39 2.1.3.G.y -- -- Removed requirements to submit a semiannual
SSM report.
-- -- 41 – 42 2.1.G.3.aa Added requirements for periodic reporting.
-- -- 42 2.1.G.bb Added reporting requirements for pressure relief
devices.
-- -- 42 2.1.G.cc Added reporting requirements for electronic
reporting of source tests.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
40 – 49 2.1.H 42 2.1.H Changed the title of this section to “Process
Equipment Subject to Equipment Leak
Provisions under 40 CFR Part 63, Subpart
OOO/UU.”
Clarified the equipment included under this
permit condition.
Added noncompliance statements throughout
section.
Added references throughout section.
40 2.1.H.1 43 2.1.H.1.a and b. Revised condition to correspond to revised
language under 40 CFR 63.1410.
Added condition specifying that emission
limits apply at all time under 40 CFR 63
Subpart UU, except during periods of
nonoperation.
42 2.1.H.4.e.iv
(A)
46 2.1.H.4.e.iv
(A)
Removed references to SSM.
48 2.1.H.12.a.i 51 2.1.H.12.a.i Removed references to SSM.
50 – 52 2.1.I 53 – 55 2.1.I Changed the title of this section to
“Equipment Subject to 40 CFR Part 63,
Subpart G, Group 1 Transfer Operations.”
Added noncompliance statements throughout
section.
Added references section.
51 2.1.I.1.k- 54 2.1.I.1.k –
2.1.I.1.n
Revised requirements for monitoring for vapor
collection systems that contain by-pass lines.
Permit 03387T42 indicated that the Permittee had
to comply with provisions under Section 2.2.A.2.
for by-pass lines. However, that permit condition
did not address by-pass lines.
51 2.1.I.1.m 55 2.1.I.1.q
Revised requirements for recordkeeping for
vapor collection systems that contain by-pass
lines. Permit 03387T42 indicated that the
Permittee had to comply with provisions under
Section 2.2.A.2 for recordkeeping. However,
that permit condition did not address by-pass
lines.
52 – 54 2.1.J 55 2.1.J Changed the title of this section to “Equipment
Subject to 40 CFR Part 63, Subpart G, Group 1
Storage Vessels.”
-- -- 56 2.1.J.1
Added condition specifying that the Permittee is
subject to 40 CFR Part 60, Subpart Kb and
complies with this rule by complying with 40
CFR Part 63, Subpart G for Group 1 storage
vessels.
52 – 54 2.1.J.1
56 – 58 2.1.J.2 Added noncompliance statements throughout.
Added references.
55 – 56 2.1.K 58 2.1.K Changed the title of this section to “Other
Emission Sources.
Moved equipment subject to 40 CFR Part 63,
Subpart Group 2 Storage Vessels and Group 2
Transfer Rack Operations requirements to
Section 2.1.F.
Moved equipment associated with Resin
Production to 2.1.G.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
56 2.1.K.1 -- -- Moved condition for Group 2 storage vessels
from Section 2.1.K.1 to 2.1.F.2.
56 2.1.K.2 -- -- Moved condition for Group 2 transfer racks
from Section 2.1.K.2 to 2.1.F.3.
57 – 61
2.1.L 59 2.1.L Added No. 2 fuel oil firing in the boilers
throughout the section.
57 2.1.L –
Regulations
Table
59 – 66 2.1.L –
Regulations
Table
Removed equation under 02D .0503 and
replaced with numerical PM emission limit.
Added reference to MACT Subpart DDDDD.
57 2.1.L.1 59 2.1.L.1 Removed equation under 15A NCAC
02D .0503 and replaced with numerical PM
emission limit.
Revised testing language to reflect most
current permit language.
59 2.1.L.4. 61 2.1.L.4. Added noncompliance statements throughout.
59 2.1.L.5.b 62 2.1.L.5.b Corrected dates to indicate that the boilers will be
subject to the NESHAP for Industrial,
Commercial, and Institutional Boilers and
Process Heaters, 40 CFR Part 63, Subpart
DDDDD beginning May 20, 2019.
-- -- 63 – 66 2.1.L.6 Added MACT DDDDD requirements.
62 2.1.M –
Regulations
Table
67 2.1.M –
Regulations
Table
Removed equation under 02D .0503 and
replaced with numerical PM emission limit.
Removed extraneous statements specifying
that the temporary back-up boiler (ID No.
TPB1) is subject to 40 CFR Part 60, Subpart
Dc and 40 CFR Part 63, Subpart G.
62 2.1.M.1 a and b
67 2.1.M.1 a and b
Removed equation under 02D .0503 and
replaced with numerical PM emission limit.
Revised testing language to reflect most
current permit language.
63 – 64 2.1.M.4 68 2.1.M.4 Revised permit language under 40 CFR Part 60,
Subpart Dc.
-- 2.1.N –
Regulations
Table
68 – 69 2.1.N –
Regulations
Table
Added requirement for PSD avoidance to the
regulations table. With the use of slack wax
with trace amounts of toluene, the Permittee
must account for VOC emissions from the
wax plant (ID No. WAX).
-- -- 69 – 70 2.1.N.1 Added requirements under MACT Subpart FFFF
for the wax plant (ID No. WAX).
-- 2.1.O.3 71 – 73 2.1.O.3 Revised permit condition for NESHAP for
Stationary Reciprocating Internal Combustion
Engines, 40 CFR Part 63, Subpart ZZZZ to most
current permitting language.
67 2.2A.
Regulations
Table
74 2.2A.
Regulations
Table
Specified that startup, shutdown, and malfunction
requirements are not applicable to MACT
Subpart OOO/UU/SS affected sources.
Previous Permit New Permit Description of Changes
Pages Sections Pages Sections
69 – 71 2.2.A.2 76 – 79 2.2.A.2 Specified equipment that is subject to
regulations 40 CFR Part 63, Subpart G,
National Emission Standards for Organic
HAP (NESOHAP) from the SOCMI for
Process Vents, Storage Vessels, Transfer
Operations, and Wastewater, and 40 CFR Part
63, Subpart SS, NESHAP for Closed Vent
Systems, Control Devices, Recovery Devices
and Routing to a Fuel Gas System or a
Process.
Added noncompliance statements throughout
section.
Added references throughout section.
69 2.2.A.2.b. and c 76 2.2.A.2.b. and c Clarified that these requirements are only
applicable to closed vent systems subject to 40
CFR Part 63, Subpart OOO/SS (ID Nos. CVS1,
CVS2, CVS3, and NRBV1).
69 2.2A.2.d.ii.(F) 76 2.2A.2.d.ii.(F)
and (G)
Added inspection and recordkeeping
requirements subject to closed vent systems
subject to 40 CFR Part 63, Subpart G (ID Nos.
CVS1 and CVS2) only.
-- -- 76 – 79 2.2A.2.d. ii.(H)
through (J)
Clarified that these requirements are only
applicable to closed vent systems subject to 40
CFR Part 63, Subpart OOO/SS (ID Nos. CVS3
and NRBV1).
70 – 71 2.2A.2.e.vii. and
viii
77 2.2A.2.e.vii. and
viii
Added inspection and recordkeeping
requirements subject to closed vent systems
subject to 40 CFR Part 63, Subpart G (ID Nos.
CVS1 and CVS2) only.
71 2.2A.2.g. vi. 78 2.2A.2.g. vi.
through viii Added noncompliance statements throughout.
Added references.
71 2.2.A.3 79 2.2A.3 Added noncompliance statements throughout.
Added references.
72 2.2.B –
Regulations
Table
79 2.2.B –
Regulations
Table
Removed reference to 02Q .0705, Existing
Sources and SIC Calls. This rule was repealed
on May 1, 2014.
Added reference to 15A NCAC 02Q .0711.
72 2.2.B.1.b and c 79 – 80 2.2.B.1.b and c Added noncompliance statements.
74 2.2.B.4 81 – 82 2.2.B.4 Removed reference to 02Q .0705, Existing
Sources and SIC Calls. This rule was repealed
on May 1, 2014.
Updated emission source descriptions.
-- -- 82 – 83 2.2.B.5 Added requirements for compliance with 15A
NCAC 02Q .0711 for toluene.
75 2.2.B.5 83 2.3.A Moved requirements for 15A NCAC
02Q .0508(h), Prevention of Accidental
Releases, to new section to be consistent with
DAQ formatting.
Updated permit condition for 15A NCAC
02Q .0508(h), Prevention of Accidental
Releases, with most current permit language.
76 – 87 3.0 84 – 93 3.0 Updated the General Conditions and the List of
Acronyms to the most current version (V4.0:
12/17/2015).
State of North Carolina
Department of Environmental Quality
Division of Air Quality
AIR QUALITY PERMIT Permit No. Replaces Permit No. Effective Date Expiration Date
0 3387T44 03387T42 XXXX, 2016 XXXX, 2021
Until such time as this permit expires or is modified or revoked, the below named Permittee is permitted to construct
and operate the emission source(s) and associated air pollution control device(s) specified herein, in accordance with
the terms, conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B of
Chapter 143, General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes
(15A NCAC), Subchapters 02D and 02Q, and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 02Q, the Permittee shall not construct, operate, or modify any emission
source(s) or air pollution control device(s) without having first submitted a complete Air Quality Permit Application
to the permitting authority and received an Air Quality Permit, except as provided in this permit.
Permittee: Hexion Inc. – Fayetteville Facility Facility ID: 2600009
Facility Site Location: 1411 Industrial Drive
City, County, State, Zip: Fayetteville, Cumberland County, North Carolina, 28301
Mailing Address: 1411 Industrial Drive
City, State, Zip: Fayetteville, Cumberland County, North Carolina, 28301
Application Number: 2600009.14A, 2600009.14B, and 2600009.15B
Complete Application Date: April 25, 2014, October 7, 2014, and February 12, 2015
Primary SIC Code: 2869, 2821, 2891
Division of Air Quality, Fayetteville Regional Office
Systel Building
225 Green Street, Suite 714
Fayetteville, North Carolina 28301
Permit issued this the XXth day of XXXX, 2016
_______________________________________________________
William D. Willets, P.E., Chief, Permitting Section
By Authority of the Environmental Management Commission
Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE (S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1- Emission Source(s) Specific Limitations and Conditions (Including specific
requirements, testing, monitoring, recordkeeping, and reporting requirements)
2.2- Multiple Emission Source(s) Specific Limitations and Conditions (Including specific
requirements, testing, monitoring, recordkeeping, and reporting requirements)
2.3- Other Applicable Requirements
Section 112(r)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
Permit 03387T44
Page 3
SECTION 1- PERMITTED EMISSION SOURCES AND ASSOCIATED AIR
POLLUTION CONTROL DEVICES AND APPURTENANCES The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances:
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
FORMALDEHYDE PRODUCTION
10, 74 FORM12 MACT G
(fuel gas system
process vent
exemptions)
Silver catalyst formaldehyde processes
consisting of:
two parallel silver catalyst converter sets
two methaform columns
four primary absorbers
four secondary absorbers
product distillation column
purifier
methanol reflux tank
product sump
CDB1
CDB2
Overheads from the secondary
absorbers sent to the following:
Plant 1 and 2 boiler (12.4 million
Btu per hour heat input)
And /Or
Plant 3 boiler (20.9 million Btu
per hour heat input)
32, 74 CFR12 MACT G STVG2
Distillation column raw product feed tank for
formaldehyde process, 4000 gallons
(ID No. FORM12)
FORM12,
FORM3,
or ES16
Emissions from tanks are
collected via the closed vent
system (CVS1) and returned to
the formaldehyde processes (ID
Nos. FORM12, FORM3, or
ES16) as raw material feed
15, 74 HX9A and HX9B MACT F 63.104
Two formaldehyde/cooling tower water plate
and frame heat exchangers (Plant 1 of
FORM12)
N/A N/A
15, 74 HXT5 and HXE16 MACT F 63.104
Two cooling tower water shell and methanol
tube heat exchangers (Plant 1 of FORM12)
N/A N/A
15, 74 HXT1 and HXT2 MACT F 63.104
Two formaldehyde/cooling tower water plate
and frame heat exchangers (Plant 2 of
FORM12)
N/A N/A
10,
32, 74
FORM3 MACT WW2
(fuel gas system
process vent
exemption)
Silver catalyst formaldehyde process
consisting of:
one silver catalyst converter set
one primary absorber
one secondary absorber
product distillation column
purifier
methanol reflux tank
product sump
De-acidifier resin bed regeneration (optional)
CDB2 Overheads from the secondary
absorber sent to the Plant 3
boiler (20.9 million Btu per hour
heat input)
32, 74 CFR3 MACT G STVG2
Distillation column raw product feed tank for
formaldehyde process, 16,000 gallons
(ID No. FORM3)
FORM12,
FORM3,
or ES16
Emissions from tanks are
collected via the closed vent
system (CVS1) and returned to
the formaldehyde processes (ID
Nos. FORM12, FORM3, or
ES16) as raw material feed
33, 74 CFRT3
MACT G STVG2
One distillation column raw product feed
tank; 2,000 gallons (ID No. FORM3)
FORM12,
FORM3,
or ES16
Emissions from tanks are
collected via the closed vent
system (CVS1) and returned to
the formaldehyde processes (ID
Nos. FORM12, FORM3, or
ES16) as raw material feed
15, 74 HX2 MACT F 63.104
Formaldehyde/cooling tower water plate and
frame heat exchanger (ID No. FORM3)
N/A N/A
Permit 03387T44
Page 4
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
15, 74 HX6 MACT F 63.104
Cooling tower water shell and methanol tube
heat exchanger (ID No. FORM3)
N/A N/A
15, 74 HX7C MACT F 63.104
Cooling tower water shell and formaldehyde
tube heat exchanger (ID No. FORM3)
N/A N/A
15, 74 HX8 MACT F 63.104
Formaldehyde/cooling tower water plate and
frame heat exchanger (ID No. FORM3)
N/A N/A
15, 74 HX12 MACT F 63.104
Loading cooler, formaldehyde /cooling
tower water plate and frame heat exchanger
(ID No. FORM3)
N/A N/A
32, 74 STORE1MAF1
and
STORE1MAF2 MACT G STVG2
Two methaform/wastewater storage tanks;
16,195 gallons each
FORM12,
FORM3,
or ES16
Emissions from tanks and
distillation column raw feed
tanks are collected via the closed
vent system (CVS1) and
returned to the formaldehyde
processes (ID Nos. FORM12,
FORM3, or ES16) as raw
material feed
32, 74 STORE1FORM1
through
STORE1FORM9 MACT G STVG2
Nine formaldehyde (various blends) /
wastewater storage tanks; 16,195 gallons
each
32, 74 FORMSTG1
through
FORMSTG4 MACT G STVG2
Four formaldehyde (various blends) and
methaform storage tanks; 30,000 gallons
each
32, 74 FORMSTG5
MACT G STVG2
One formaldehyde (various blends) and
methaform storage tank; 13,000 gallons
32, 74 FORMSTG6 and
FORMSTG7
MACT G STVG2
Two formaldehyde (various blends) and
methaform storage tanks; 7,000 gallons each
12,
18, 74
ES16 NSPS VV
NSPS III
MACT G PVG1
Metal oxide catalyst formaldehyde process
consisting of:
one methanol preheater
one booster blower
a demister
two heater transfer fluid condensers
two sets of vaporizer/ reactor/after cooler
one adsorption column
CD17
Catalytic oxidizer via CVS2
15, 74 HX7 MACT F 63.104
Urea formaldehyde concentrate/cooling
tower heat exchanger (Plant 4, ID No. ES16)
N/A N/A
15, 74 HX8A MACT F 63.104
Formaldehyde/cooling tower heat exchanger
(Plant 4, ID No. ES16)
N/A N/A
15, 74 HX8B MACT F 63.104
Formaldehyde/cooling tower heat exchanger
(Plant 4, ID No. ES16)
N/A N/A
15, 74 HX10 MACT F 63.104
Formaldehyde/cooling tower heat exchanger
(Plant 4, ID No. ES16)
N/A N/A
15, 74 HX11 MACT F 63.104
Formaldehyde/cooling tower heat exchanger
(Plant 4, ID No. ES16)
N/A N/A
17, 74 FORMEQLK MACT H
Pumps, compressors, agitators, pressure
relief devices, sampling connection systems,
open-ended valves or lines, valves,
connectors, surge control vessels, bottoms
receivers, instrumentation systems, and
control devices or closed vent systems
(required by MACT H) in HAP service
N/A N/A
30 UW1 Urea water tank; 20,306 gallon capacity with
cyclone separator
CD-UWBH Pleated Cartridge filters, 490
square feet of total surface area
30 UW2
Urea water tank; 20,306 gallon capacity with
cyclone separator
Permit 03387T44
Page 5
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
32, 74 MOSTORE 1A
through
MOSTORE 1C MACT G STVG2
Three 50% wt formaldehyde, UFC, and
hydrolyzed re-work resin storage tanks;
67,686 gallons each
CD200A
CD200B
Or
N/A
Packed bed scrubber using once
through water (minimum liquid
to gas ratio is 0.0049 gpm/scfm)
venting to
Packed bed scrubber with
sulfuric acid scrubbing medium
(maximum pH of 4.9) via CVS3
Or
Vent to atmosphere when
scrubbers (ID Nos. CD200A and
CD200B) are not in operation
33, 74 MOSTORE 1D
and
MOSTORE 1E MACT G STVG2
Two 50% wt formaldehyde, UFC, and
hydrolyzed re-work resin storage tanks;
67,686 gallons each
32, 74 MOSTORE 2 MACT G STVG2
50% wt formaldehyde, UFC, and hydrolyzed
re-work resin storage tank; 25,031 gallons
HEXAMINE PRODUCTION
32, 74 HRE MACT G PV2
MACT G WW2
Hexamethylenetetramine reactor with liquid
ring vacuum pump; five tons per hour
nominal rate
CDSC2 Tray tower scrubber; 11 gallons
per minute minimum water
injection rate
15, 74 HX5 MACT F 63.104
Ammonia absorber water/cooling tower heat
exchanger
N/A N/A
33, 74 ESOT1 MACT G STVG2
Hexamine process water, defoamer, catalyst,
and wastewater tank; 21,757 gallons
N/A N/A
33, 74 ESOT2 MACT G STVG2
Hexamine process water, defoamer, catalyst,
and wastewater tank; 23,311 gallons
N/A N/A
33, 74 ESOT3 MACT G STVG2
Hexamine process water, defoamer, catalyst,
and wastewater tank; 19,363 gallons
N/A N/A
33, 74 ESCT1 MACT G STVG2
Hexamine concentrate water, defoamer,
catalyst, and wastewater tank; 12,956 gallons
N/A N/A
33, 74 ESCT2 MACT G STVG2
Hexamine concentrate water, defoamer,
catalyst, and wastewater tank; 12,956
gallons
N/A N/A
33, 74 ESLH1 MACT G STVG2
Liquid hexamine, defoamer, catalyst, and
wastewater tank; 30,728 gallons
N/A N/A
33, 74 ESDS MACT G STVG2
Hexamine distillate, defoamer, catalyst, and
wastewater tank; 10,364 gallons
N/A N/A
18, 74 HEXAEQLK MACT H
Pumps, compressors, agitators, pressure
relief devices, sampling connection systems,
open-ended valves or lines, valves,
connectors, surge control vessels, bottoms
receivers, instrumentation systems, and
control devices or closed vent systems
(required by MACT H) in HAP service
N/A N/A
Permit 03387T44
Page 6
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
RESIN PRODUCTION
35, 74 BR2 MACT OOO
RBPV 63.1408
Urea/formaldehyde No. 2 batch reactor
(17,000 gallon) with internal heat transfer
coils and reflux condenser
CD200A
CD200B
Packed bed scrubber using once
through water (minimum liquid
to gas ratio is 0.0049 gpm/scfm)
venting to
Packed bed scrubber with
sulfuric acid scrubbing medium
(maximum pH of 4.9) via CVS3
35, 74 BR2DRT MACT OOO
NRBPV 63.1408
Distillate receiving tank for reflux condenser
on batch reactor No. 2
35, 74 FWTBR2 MACT OOO
NRBPV 63.1408
Weigh tank (12,000 gallons) for batch
reactors No. 2 and No. 3
35, 74 BR3 MACT OOO
RBPV 63.1408
Urea/formaldehyde No. 3 batch reactor
(15,000 gallons) with internal heat transfer
coils and reflux condenser
35, 74 BR3DRT MACT OOO
NRBPV 63.1408
Distillate receiving tank for reflux condenser
on No. 3 batch reactor
35, 74 BR4 MACT OOO
RBPV 63.1408
UF/PF swing No. 4 batch reactor (18,000
gallons) with internal heat transfer coils and
reflux condenser
35, 74 BR4DRT MACT OOO
NRBPV 63.1408
Distillate receiving tank for reflux condenser
on No. 4 batch reactor
36 VST2/3 Liquid ring vacuum seal water tank (11,000
gallons) for batch reactors No. 2 and No. 3
vacuum systems
CD200A
CD200B
Or
N/A
Packed bed scrubber using once
through water (minimum liquid
to gas ratio is 0.0049 gpm/scfm)
venting to
Packed bed scrubber with
sulfuric acid scrubbing medium
(maximum pH of 4.9) via CVS3
Or
Vent to atmosphere when
scrubbers (ID Nos. CD200A and
CD200B) are not in operation
36 VST4 Liquid ring vacuum seal water tank for No. 4
batch reactor vacuum system
42, 74 BREQLK MACT OOO
63.1410
Pumps, compressors, agitators, pressure
relief devices, sampling connection systems,
open-ended valves or lines, valves,
connectors, surge control vessels, bottoms
receivers, instrumentation systems in HAP
service, and control devices or closed vent
systems (required by MACT UU) for resin
batch reactors (ID Nos. BR2, BR3, and
BR4)
N/A N/A
30 ES24 Urea weighing and conveying operation for
BR2
CD24 Fabric filter 172 square feet of
filter area
30 UWC1 Urea weighing and conveying operation for
BR2 and BR3
CDBF1 Fabric filter 172 square feet of
filter area
30 UWC2 Urea weighing and conveying operation for
BR3
CDBF2 Fabric filter 172 square feet of
filter area
30 ES26 Urea weighing and conveying operation for
BR4
CD26 Fabric filter 172 square feet of
filter area
Permit 03387T44
Page 7
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
35 PT1, PT2 Two phenol tanks; 14.48 kPa @149F,
25,000 gallons each
N/A N/A
36 RTF9 Resin/resin washwater/diethylene glycol /
defoamer/catalyst storage tank; 10,000
gallons
N/A N/A
36 RTF11 through
RTF 37
27 resin/resin washwater storage tanks;
30,000 gallons each
N/A N/A
36 RTF38 Resin/resin washwater storage tank; 15,000
gallons
N/A N/A
36 RTF39 Resin/resin washwater storage tank; 25,000
gallons
N/A N/A
36 RTF40 Resin/resin washwater storage tank; 20,000
gallons
N/A N/A
35, 74 ES103
MACT OOO
NRBPV 63.1407
RTU (ready to use) mixing tank with filter;
3,000 gallons
CD-104PS
CD-104S
Particulate separator venting to
scrubber (minimum liquid to gas
ratio is 0.042 gpm/scfm) via
NRBPV1
36 ES-103WW
RTU wash water/resin storage tank; 20,000
gallons
N/A N/A
35 ES-RTUDM Three dry materials storage silos with weigh
hopper consisting of three separate
compartments and one scale; 200 cubic foot
capacity each
CD-RTUDC1 Fabric filter 1,300 square feet of
filter area
TRANSFER OPERATIONS
53, 74 RLOAD1 MACT G TOG1
Railcar methaform product load out (two
arms)
FORM12,
FORM3,
or ES16
Emissions from product load out
are collected via the closed vent
system (CVS1) and returned to
the formaldehyde processes (ID
Nos. FORM12, FORM3, or
ES16) as raw material feed
53, 74 RLOAD2 MACT G TOG1
Railcar formaldehyde product load out (two
arms)
53, 74 TLOAD1A MACT G TOG1
Tank truck formaldehyde and methaform
load out (one arm)
58, 74 TLOAD1B Tank truck urea formaldehyde resin, phenol
formaldehyde resin, and urea load out
N/A N/A
33, 74 RLOAD3 MACT G TOG2
Railcar urea formaldehyde concentrate
product load out (two arms)
CD200A
CD200B
Or
N/A
Packed bed scrubber using once
through water (minimum liquid
to gas ratio is 0.0049 gpm/scfm)
venting to
Packed bed scrubber with
sulfuric acid scrubbing medium
(maximum pH of 4.9) via CVS3
Or
Vent to atmosphere when
scrubbers (ID Nos. CD200A and
CD200B) are not in operation
33, 74 TLOAD2A MACT G TOG2
Tank truck urea formaldehyde concentrate
product load out (one arm)
58 TLOAD2B Tank truck urea formaldehyde resin and
phenol formaldehyde resin load out
N/A N/A
33, 74 TLOAD3A MACT G TOG2
Tank truck hexamine load out N/A N/A
58 TLOAD3B Tank truck urea formaldehyde resin and wax
product load out
N/A N/A
33, 74 RLOAD4 MACT G TOG2
Railcar liquid hexamine load out and
receiving
N/A N/A
Permit 03387T44
Page 8
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
58 TLOAD4
Tank truck phenol formaldehyde resin load
out, and receiving for caustic, temulose/beet
molasses, and phenol
N/A N/A
58 TLOAD5
Tank truck urea formaldehyde resin and
phenol formaldehyde resin load out, and
receiving for aqueous ammonia
N/A N/A
TLOAD6
Tank truck urea formaldehyde resin load out N/A N/A
CLOSED VENT SYSTEMS
10, 74 CVS1 MACT G 63.148
Vent collection header for CFR12, CFR3,
STORE1MAF1, STORE1MAF2,
STORE1FORM1 through STORE1FORM9,
FORMSTG1 through FORMSTG7, CFRT3,
RLOAD1, RLOAD2, and TLOAD1A
FORM12,
FORM3, or ES16
Emissions from tanks are
collected via the closed vent
system (CVS1) and returned to
the formaldehyde processes (ID
Nos. FORM12, FORM3, or
ES16) as raw material feed
12, 74 CVS2 MACT G 63.148
Vent collection header for ES16 CD17 Catalytic oxidizer
35, 74 CVS3 MACT OOO/SS
63.983
Vent collection header for MOSTORE 1A
through MOSTORE 1E, MOSTORE 2,
BR2, BR2DRT, FWTBR2, BR3, BR3DRT,
VST2/3, BR4, VST4, BR4DRT, RLOAD3,
and TLOAD2A
CD200A
CD200B
Packed bed scrubber using once
through water (minimum liquid
to gas ratio is 0.0049 gpm/scfm)
venting to
Packed bed scrubber with
sulfuric acid scrubbing medium
(maximum pH of 4.9) via CVS3
35, 74 NRBPV1
MACT OOO/SS
63.983
Vent collection header for ES103 CD-104PS
CD-104S
Particulate separator venting to
scrubber (minimum liquid to gas
ratio is 0.042 gpm/scfm) via
NRBPV1
OTHER
55, 74 METH1 NSPS Kb
MACT G STVG1
Methanol storage No. 1 internal floating roof
(two seals one mounted above the other)
tank; 254,715 gallons
N/A N/A
55, 74 METH2 NSPS Kb
MACT G STVG1
Methanol storage tank No. 2 internal floating
roof (two seals one mounted above the other)
tank; 254,715 gallons
N/A N/A
58 WWTP Wastewater treatment plant N/A N/A
68, 74 WAX MACT FFFF/F
63.105
Wax emulsion plant N/A N/A
59, 74 ES3 Case-by-Case
MACT1
MACT DDDDD2
Boiler No. 3; natural gas, No. 2, No. 4, No.
5, No. 6 fuel oil-fired; 20.9 million Btu per
hour input
N/A N/A
59, 74 ES4 Case-by-Case
MACT1
MACT DDDDD2
Boiler No. 4; natural gas, No. 2, No. 4, No.
5, No. 6 fuel oil-fired; 20.9 million Btu per
hour input
N/A N/A
67, 74 TB1
NSPS DC
MACT G
Temporary, back-up boiler; formaldehyde
process tail gas and/or natural gas fired;
maximum heat input less than 30 million Btu
per hour
N/A N/A
70 ES-EG 1
MACT ZZZZ
340 hp diesel fired emergency generator N/A N/A
Permit 03387T44
Page 9
Page
Nos. Source ID No. Emission Source Description
Control/Recover
y Device ID No.
Control/Recovery Device
Description
70 ES-FP1 and ES-
FP2 MACT ZZZZ
Two 150 hp diesel-fired fire pumps N/A N/A
1. The Permittee shall comply with this CAA §112(j) standard until May 19, 2019.
2. The Permittee shall comply with 40 CFR Part 43, Subpart DDDDD, ‘‘National Emission Standards for Hazardous Air Pollutants
for Industrial, Commercial, and Institutional Boilers and Process Heaters,” beginning May 20, 2019.
Permit 03387T44
Page 10
2.1 - Emission Sources and Control Devices Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s) and appurtenances listed below are subject to the
following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting
requirements as specified herein:
A. Silver Catalyst Formaldehyde Processes
Closed vent system (ID No. CVS1)
Silver catalyst formaldehyde process (ID No. FORM12) venting as fuel gas to Plant 1 and
2 boiler and/or Plant 3 boiler (ID Nos. CDB1 and CDB2)
Silver catalyst formaldehyde process (ID No. FORM3) venting as fuel gas to Plant 3 boiler
(ID No. CDB2)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
PM 0.35 pounds per million Btu heat input. 15A NCAC 02D .0503
SO2 Sulfur dioxide emissions shall not exceed 2.3 pounds per
million Btu heat input
15A NCAC 02D .0516
Visible emissions Visible emissions shall not exceed 40 percent opacity 15A NCAC 02D .0521
HAPs Emissions from the process shall be at all times ducted to
the process fuel gas system and combusted in the
respective boiler.
15A NCAC 02D .1111
40 CFR 63, Subpart G
HAP Leak Inspection Provisions of Vapor Collection and
Closed Vent Systems - 40 CFR 63.148
(See Section 2.2 A.2. Multiple Emission Sources)
15 A NCAC 02D .1111
40 CFR 63, Subpart G
HAP Start up, shut down and malfunction
(See Section 2.2 A.1. Multiple Emission Sources)
15 A NCAC 02D .1111
40 CFR 63, Subpart A
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subpart F
VOC VOC emissions shall not exceed 100 tons per
consecutive 12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D .0958
Odor Odor control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D .1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 02D .1100
1. 15A NCAC 02D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter from the combustion of formaldehyde process gases that are discharged from
these boilers into the atmosphere shall not exceed 0.35 pounds per million Btu heat input.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 A.1.a above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0503.
Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of process fuel gas
in these boilers.
Permit 03387T44
Page 11
2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from these boilers shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included when
determining compliance with this standard. [15A NCAC 02D .0516]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found
in Section 3. If the results of this test are above the limit given in Section 2.1 A.2.a. above, the Permittee shall
be deemed in noncompliance with 15A NCAC 02D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from process fuel gas
combusted in these boilers.
3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers shall not be more than 40 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 40 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event shall the six-minute average exceed 90 percent
opacity. [15A NCAC 02D .0521(c)]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the respective limit given in Section 2.1 A.3.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of process fuel gas in
these boilers.
4. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart
G, National Emission Standards for Organic Hazardous Air Pollutants from the SOCMI for Process Vents,
Storage Vessels, Transfer Operations, and Wastewater a. The Permittee shall reduce emissions of total organic hazardous air pollutants by 98 weight percent or to a
concentration of 20 parts per million by volume, whichever is less stringent. The Permittee meets the intent of
this limit by using the process gas stream as primary fuel. [40 CFR 63.113(a)(2)]
Testing [15A NCAC 02Q .0508(f)] and 40 CFR 63.116(b)(2)]
b. If emissions testing is required, testing shall be conducted in accordance with the procedures contained in 40
CFR 63.116. For such testing, the emission reduction or concentration shall be calculated on a dry basis,
corrected to 3-percent oxygen, and compliance can be determined by measuring either organic hazardous air
pollutants or total organic carbon. If the testing demonstrates the least stringent limit given in Section 2.1
A.4.a. above is exceeded, the Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111.
Monitoring/Recordkeeping, Reporting [15A NCAC 02Q .0508(f)] and 40 CFR 63.114(a)(3)]
c. No monitoring, recordkeeping or reporting is required other than that required pursuant to applicable Section 2.2
"Multiple Emissions Source" requirements (e.g., maintenance waste water, start-up/shut-down/malfunction,
LDAR for closed vent systems).
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B. Metal Oxide Catalyst Formaldehyde Process
Vent collection header for ES16 (ID No. CVS2)
Metal oxide catalyst formaldehyde process (ID No. ES16) with catalytic oxidizer (ID No.
CD17)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
VOC 98 wt percent or 20 ppmv control
A Group 1 process vent that is also subject to 40 CFR Part
60, Subpart III is required to comply only with 40 CFR
Part 63, Subpart G. [40 CFR 63.110(d)]
15A NCAC 02D .0524
40 CFR 60, Subpart III
NSPS for VOC from SOCMI
Air Oxidation Units
VOC Leak Detection and Repair
All equipment subject to this NSPS will be monitored in
accordance with 40 CFR Part 63, Subpart H. [40 CFR
63.160(c)]
(See Section 2.1.D)
15A NCAC 02D .0524
40 CFR 60, Subpart VV
NSPS for Equipment leaks of
VOC from the SOCMI
HAP The Permittee shall reduce HAP emissions by 98 percent by
weight or to a concentration of 20 ppm by volume,
whichever is less stringent. [40 CFR 63.113(2)]
15A NCAC 02D .1111
40 CFR 63, Subpart G
HAP Start up, shut down and malfunction
(See Section 2.2 A.1. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subpart A
HAP Leak Inspection Provisions of Vapor Collection and Closed
Vent Systems - 40 CFR 63.148
(See Section 2.2 A.2. Multiple Emission Sources)
15 A NCAC 02D .1111
40 CFR 63, Subpart G.
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subpart F
VOC VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D .0958
Odor Odor Control
(See Section 2.2 B.3.. Multiple Emission Sources)
15A NCAC 02D .1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 02D .1100
1. 15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS
a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting,
recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard
15A NCAC 02D .0524 “New Source Performance Standards” (NSPS), “Standards of Performance for
Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for Which
Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November
7, 2006,” 40 CFR Part 60, Subpart VV, including Subpart A “General Provisions.” [15A NCAC 02D .0524]
b. Per request of the Permittee for the purposes of applicability and compliance with 40 CFR Part 60, Subpart
VV, the Permittee shall consider all VOC in such equipment as if it were organic hazardous air pollutant.
Compliance with 40 CFR Part 63, Subpart H as provided in Section 2.1.D constitutes compliance with 40 CFR
Part 60, Subpart VV. [40 CFR 63.160(c)]
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2. 15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS
a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting,
recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard
15A NCAC 02D .0524 “New Source Performance Standards” (NSPS) as promulgated in 40 CFR Part 60,
Subpart III, “Standards of Performance for Volatile Organic Compound (VOC) Emissions from the Synthetic
Organic Chemical Manufacturing Industry (SOCMI) Air Oxidation Unit Processes,” including Subpart A
“General Provisions.” [15A NCAC 02D .0524]
b. The Permittee shall comply with 40 CFR Part 60, Subpart III by complying with the requirements in 40 CFR
Part 63, Subpart G for Group 1 process vents as provided in Section 2.1. B.3. below. [40 CFR 63.110(d)(1)]
3. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart
G, Group 1 Process Vent Requirements a. The Permittee shall reduce emissions of total organic hazardous air pollutants by 98 weight percent or to a
concentration of 20 parts per million by volume, whichever is less stringent.
b. An excursion shall be a failure to comply with the daily average temperature and/or insufficient monitoring data
to determine compliance. Multiple failures occurring during the same daily averaging period shall count as one
excursion. [40 CFR 63.152(c)(2)(ii)(A)]
c. Monitoring data that is not collected is considered an excursion unless it is due to start-up, shutdown,
malfunction, or non-operation. [40 CFR 63.152(c)(2)(ii)(C)]
d. The Permittee is allowed one excursion per semiannual reporting period. The Permittee shall be deemed in
noncompliance with 15A NCAC 02D .1111 for each excursion beyond the allowed exception. [40 CFR
63.152(c)(2)(ii)(B)(6)]
Testing [15A NCAC 02Q .0508(f)]
e. Testing is required to establish parametric operating parameters and compliance upon the installation and
operation of the new catalytic oxidizer (ID No. CD17) on the metal oxide catalyst formaldehyde process (ID No.
ES16). Testing shall follow the procedures specified in 40 CFR 63.116(c)(1) through 63.116(c)(4) and the
requirements in General Condition JJ of the permit. Stack testing shall be conducted within 180 days of permit
issuance.
f. Testing is required to establish parametric operating parameters and compliance for the metal oxide catalyst
formaldehyde process (ID No. ES16) following the addition of the methanol preheater and/or booster blower.
Testing shall follow the procedures specified in 40 CFR 63.116(c)(1) through 63.116(c)(4) and the
requirements in General Condition JJ of the permit. [40 CFR 63.116(c)]
g. During the performance test, the Permittee is not required to maintain the daily average temperature of the vent
stream immediately before the catalyst bed above the minimum temperature established in 2.1.B.1.k.i. or ii
when following approved performance test protocol.
h. The emission reduction or concentration shall be calculated on a dry basis, corrected to 3-percent oxygen, and
compliance can be determined by measuring either organic hazardous air pollutants or total organic carbon.
[40 CFR 63.113(2)] If the testing demonstrates the least stringent limit given in Section 2.1 B.3.a. above is
exceeded, the Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111.
i. Following DAQ approval of the performance test results as required pursuant to Section 2.1.B.3.e or f, the
Permittee shall maintain the daily average temperature of the vent stream immediately before the catalyst bed
in accordance with the test results. The Permittee shall attach the memorandum approving the performance
test results to this permit.
Monitoring [15A NCAC 02Q .0508(f)]
j. The Permittee shall use temperature monitoring devices with continuous recorder(s) installed in the gas stream
immediately before the catalyst bed. Monitoring equipment shall be installed, calibrated, maintained, and
operated according to manufacturer’s specifications or other written procedures that provide adequate
assurance that the equipment would reasonably be expected to monitor accurately. [40 CFR 63.114(1)(ii)]
k. Monitoring Parameters established pursuant to 40 CFR Part 63, Subpart G [40 CFR 63.151(g)(5), 40
CFR63.114(e)]:
i. Formaldehyde Process Mode – The Permittee shall maintain the daily average temperature of the vent
stream immediately before the catalyst bed at or above 220°C.
ii. Urea-Formaldehyde Process Mode - The Permittee shall maintain the daily average temperature of the
vent stream immediately before the catalyst bed at or above 240°C.
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iii. The Permittee shall conduct annual inspections of catalyst activity in accordance with a written plan. The
plan shall be submitted to the DAQ regional office for approval, maintained on site, and specify the testing
procedures used to determine the catalyst activity using a micro gas chromatograph.
iv. The Permittee shall perform a monthly visual inspection of the catalytic oxidizer for structural integrity.
v. The Permittee shall conduct an annual internal visual inspection of the catalyst bed to check for
channeling, abrasion, and settling. If problems are found, the Permittee must take corrective action
consistent with the manufacturer's recommendations and conduct a catalyst activity check within 30 days
of completing corrective actions.
The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the above requirements are not
met, or if a catalyst activity check shows an exceedance of the limits in Section 2.1 B.3.a. of this permit, except as
provided in Section 2.1 B.3.b., c., and d.
Recordkeeping [15A NCAC 02Q .0508(f), 40 CFR 63.118(a), and 40 CFR 63.151(g) for Alternative
Monitoring]
l. The Permittee shall continuously record temperature upstream of the catalyst bed.
m. The Permittee shall maintain records of the production scenario (urea-formaldehyde or formaldehyde) during
which times the appropriate inlet temperature to the catalyst bed must be maintained.
n. The Permittee shall maintain records of the upstream temperatures that were determined during performance
testing.
o. The Permittee shall record the daily average upstream temperature for each operating day and each operating
scenario.
i. Daily averages shall consist of an average temperature for the operating day for the upstream temperature.
If all recorded values during an operating day are within the operating range, a statement to this effect can
be recorded instead of the daily average.
ii. Records of the daily average temperature values for each operating day shall be determined according to
the procedures specified below:
(A) the monitoring system shall measure data values at least once every 15 minutes;
(B) the Permittee shall record either:
(1) each measured data value; or
(2) block average values for 15-minute or shorter periods calculated from all measured data values
during each period; or
(3) at least one measured data value per minute if measured more frequently than once per minute.
(C) If the daily average temperature for a given operating day is within the permitted limit, the Permittee
shall either retain
(1) block hourly average values for that operating day for five years and discard the 15-minute or
more frequent average values and readings at the end of the day; or
(2) retain all the data for five years.
(D) If the daily average temperature for a given operating day is outside the temperature limit, the
Permittee shall retain the data recorded that operating day for five years.
(E) Daily average temperature shall be calculated for each operating day, and retained for five years,
unless all recorded values are within the limits or except as specified below in (F) and (G).
(1) The daily average shall be calculated as the average of all values for a monitored temperature
recorded during the operating day. The average shall cover a 24-hour period if operation is
continuous, or the number of hours of operation per operating day if operation is not continuous.
(2) The operating day shall be from midnight to midnight.
(F) If all recorded values for a monitored temperature during an operating day are within the limit, the
Permittee may record that all values were within the range and retain this record for five years rather
than calculating and recording a daily average for that operating day. For these operating days, the
records required in (C) above shall also be retained for 5 years.
(G) Monitoring data recorded during periods specified in (1) through (6) below shall not be included in
any calculated average. Records shall be kept of the times and durations of all such periods and any
other periods during process or control device operation when monitors are not operating.
(1) Monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level
adjustments;
(2) Start-ups;
(3) Shutdowns;
(4) Malfunctions;
(5) Performance Tests; and
Permit 03387T44
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(6) Periods of non-operation of the chemical manufacturing process unit (or portion thereof),
resulting in cessation of the emissions to which the monitoring applies.
p. The Permittee shall maintain records of each monthly external inspection and annual internal inspection of the
catalyst bed.
q. The Permittee shall maintain records of the procedures used in performing catalyst activity checks.
r. The Permittee shall keep records up-to-date and readily accessible.
s. Records required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
t. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the requirements in 2.1.B.3.l
through s are not met.
Reporting [15A NCAC 02Q .0508(f) and 40 CFR 63.118(f)]
u. The Permittee shall report all daily average upstream temperatures that are less than the established operating
temperature.
v. The Permittee shall report the results of monthly external catalytic oxidizer structural integrity inspections and
annual internal catalyst checks and any maintenance performed.
w. The Permittee shall report the results of the annual catalyst activity check.
x. The Permittee shall report all operating days when insufficient monitoring data are collected.
y. The periodic reports shall include the duration of periods when monitoring data is not collected for each
excursion. An excursion is any of the following cases:
i. When the daily average temperature value is less than permitted limit.
ii. When the period of control device operation is four hours or greater in an operating day and monitoring
data are insufficient to constitute a valid hour of data for at least 75 percent of the operating hours.
iii. When the period of control device operation is less than 4 hours in an operating day and more than one of
the hours during the period of operation does not constitute a valid hour of data due to insufficient
monitoring data.
iv. When insufficient catalyst activity is determined during the annual catalyst activity check.
z. Reports pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance waste
water, start-up/shut-down/malfunction, LDAR for closed vent systems).
aa. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
bb. The Permittee shall submit the results of the stack tests performed for the metal oxide catalyst formaldehyde
process (ID No. ES16) within 180 days of the initial operation of the methanol preheater and/or booster blower.
cc. The Permittee shall submit the results of the stack test performed on the new catalytic oxidizer (ID No. CD17)
on the metal oxide catalyst formaldehyde process (ID No. ES16) not later than 30 days after sample collection
as specified in General Condition JJ of the permit.
C. Heat Exchangers Systems Subject to 40 CFR Part 63, Subpart F
Six heat exchanger systems for formaldehyde process FORM12 (ID Nos. HX9A, HX9B,
HXT5, HXE16, HXT1, and HXT2)
Five heat exchanger systems for formaldehyde process FORM3 (ID Nos. HX2, HX6,
HX7C, HX8, and HX12)
Five heat exchanger systems for formaldehyde process ES16 (ID Nos. HX7, HX8A, HX8B,
HX10, and HX11)
One heat exchanger system for hexamine process (ID No. HX5)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAP Heat Exchanger leak detection and repair 15A NCAC 02D.1111
40 CFR 63, Subpart F
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D.1111
40 CFR 63, Subpart F
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1. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY -40 CFR Part 63, Subpart
F, Heat Exchange System Requirements
Monitoring [15A NCAC 02Q .0508(f) and 40 CFR 63.104(b)]
a. The Permittee shall monitor the cooling water for total hazardous air pollutants, total volatile organic
compounds, total organic carbon, one or more speciated HAP compounds, or other representative substances
that would indicate the presence of a leak in the heat exchange system.
b. The Permittee shall monitor the cooling water each quarter to detect leaks.
i. For recirculating heat exchange systems (cooling tower systems), the monitoring of speciated hazardous air
pollutants or total hazardous air pollutants refers to the hazardous air pollutants listed in Table 4 of 40 CFR
Part 63, Subpart F.
ii. For once-through heat exchange systems, the monitoring of speciated hazardous air pollutants or total
hazardous air pollutants refers to the hazardous air pollutants listed in Table 9 of 40 CFR Part 63, Subpart
G.
c. The concentration of the monitored substance(s) in the cooling water shall be determined using any EPA-
approved method as long as the method is sensitive to concentrations as low as 10 parts per million and the
same method is used for both entrance and exit samples.
d. The samples shall be collected either at the entrance and exit of each heat exchange system or at locations
where the cooling water enters and exits each heat exchanger or any combination of heat exchangers.
i. For samples taken at the entrance and exit of recirculating heat exchange systems, the entrance is the point
at which the cooling water leaves the cooling tower prior to being returned to the process equipment and
the exit is the point at which the cooling water is introduced to the cooling tower after being used to cool
the process fluid.
ii. For samples taken at the entrance and exit of once-through heat exchange systems, the entrance is the
point at which the cooling water enters and the exit is the point at which the cooling water exits the plant
site or chemical manufacturing process units.
iii. For samples taken at the entrance and exit of each heat exchanger or any combination of heat exchangers
in chemical manufacturing process units, the entrance is the point at which the cooling water enters the
individual heat exchanger or group of heat exchangers and the exit is the point at which the cooling water
exits the heat exchanger or group of heat exchangers.
e. A minimum of three sets of samples shall be taken at each entrance and exit. The average entrance and exit
concentrations shall then be calculated. The concentration shall be corrected for the addition of any makeup
water or for any evaporative losses, as applicable.
f. A leak is detected if the exit mean concentration is found to be greater than the entrance mean using a one
sided statistical procedure at the 0.05 level of significance and the amount by which it is greater is at least 1
part per million or 10 percent of the entrance mean, whichever is greater.
g. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the monitoring requirements in
2.1.C.1.a through e are not met.
Leak Detection and Repair Requirements [15A NCAC 02Q .0508(f) and 40 CFR 63.104(d), (e)]
h. If a leak is detected according to the criteria above, the Permittee shall comply with the following
requirements, except as provided in delay of repair provisions under Section 2.1.C.1.i.
i. The leak shall be repaired as soon as practical but not later than 45 calendar days after the Permittee
receives results of monitoring tests indicating a leak. The leak shall be repaired unless the Permittee
demonstrates that the results are due to a condition other than a leak.
ii. Once the leak has been repaired, the Permittee shall confirm that the heat exchange system has been
repaired within seven calendar days of the repair or startup, whichever is later.
i. Delay of repair of heat exchange systems for which leaks have been detected is allowed if the equipment is
isolated from the process or if repair is technically infeasible without a shutdown.
i. If a shutdown is expected within the next two months, a special shutdown before that planned shutdown is
not required.
ii. If a shutdown is not expected within the next two months, the Permittee may delay repair. However,
documentation of this decision to delay repair shall state the reasons repair was delayed and shall specify a
schedule for completing the repair as soon as practical.
iii. If a shutdown for repair would cause greater emissions than the potential emissions from delaying repair,
the Permittee may delay repair until the next shutdown of the process equipment associated with the
leaking heat exchanger. The Permittee shall document the basis for the determination that a shutdown for
repair would cause greater emissions than the emissions likely to result from delaying repair.
Permit 03387T44
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(A) The Permittee shall calculate the potential emissions from the leaking heat exchanger by multiplying
the concentration of total hazardous air pollutants listed in Table 4 of 40 CFR Part 63, Subpart F in
the cooling water from the leaking heat exchanger by the flow rate of the cooling water from the
leaking heat exchanger by the expected duration of the delay. The Permittee may calculate potential
emissions using total organic carbon concentration instead of total hazardous air pollutants listed in
Table 4 of 40 CFR Part 63, Subpart F.
(B) The Permittee shall determine emissions from purging and depressurizing the equipment that will
result from the unscheduled shutdown for the repair.
iv. If repair is delayed for reasons other than those specified above, the Permittee may delay repair up to a
maximum of 120 calendar days. The Permittee shall demonstrate that the necessary parts or personnel
were not available.
v. All time periods shall be determined from the date when the Permittee determines that delay of repair is
necessary.
j. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the requirements in Section
2.1.C.1.h and i are not met.
Recordkeeping [15A NCAC 02Q .0508(f), 40 CFR 63.104(f)(1), and 40 CFR 63.103(c)(1)]
k. The Permittee shall retain the following records:
i. Monitoring data indicating a leak and the date when the leak was detected, and if demonstrated not to be a
leak, the basis for that determination;
ii. Records of any leaks detected and the date the leak was discovered;
iii. The dates of efforts to repair leaks; and
iv. The method or procedure used to confirm repair of a leak and the date repair was confirmed.
l. All applicable records shall be maintained in such a manner that they can be readily accessed. The most recent
six months of records shall be retained on site or shall be accessible from a central location by computer or
other means that provides access within two hours after a request. The remaining four and one-half years of
records may be retained offsite. Records may be maintained in hard copy or computer-readable form
including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche.
m. Records required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
n. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the recordkeeping requirements
in 2.1.C.1.k through m are not met.
Reporting [15A NCAC 02Q .0508(f) and 40 CFR 63.104(f)(2)]
n. If a Permittee invokes the delay of repair provisions for a heat exchange system, or if the leak remains
unrepaired, the following information shall be submitted in the next semiannual periodic report. The
information shall also be submitted in each subsequent periodic report, until repair of the leak is reported.
i. The Permittee shall report the presence of the leak and the date that the leak was detected.
ii. The Permittee shall report whether or not the leak has been repaired.
iii. The Permittee shall report the reason(s) for delay of repair. If delay of repair is invoked due to the delay of
repair provisions, documentation of emissions estimates must also be submitted.
iv. If the leak remains unrepaired, the Permittee shall report the expected date of repair.
v. If the leak is repaired, the Permittee shall report the date the leak was successfully repaired.
o. Reporting required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g.,
maintenance waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
p. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified
D. Process Equipment Subject to 40 CFR Part 63, Subpart H (LDAR)
Methanol tanks and Silver Catalyst Formaldehyde Process Areas - Pumps, agitators,
pressure relief devices, open-ended valves or lines, valves, connectors, instrumentation
systems, compressors, and sampling connection systems (ID No. FORMEQLK)
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Metal Oxide Catalyst Formaldehyde Process Area (ID No. ES16) - Pumps, agitators,
pressure relief devices, open-ended valves or lines, valves, connectors, instrumentation
systems in VOC service, compressors, sampling connection systems in VOC service and
subject to 40 CFR Part 60, Subpart VV.
Hexamine Production Equipment Group - Pumps, agitators, pressure relief devices,
open-ended valves or lines, valves, connectors, and instrumentation systems,
compressors, and sample connection systems (ID No. HEXAEQLK)
The following table provides a summary of limits and standards for the emission sources describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAPs Equipment Leak Detection and Repair
15A NCAC 02D .1111
40 CFR 63, Subpart H
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D.1111
40 CFR 63, Subpart F
VOC
VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 02D.1100
1. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Applicability and Designation of Source [40 CFR 63.160]
a. Each process unit which has equipment subject to 40 CFR Part 60, Subpart VV provisions which is also
subject 40 CFR Part 63, Subpart H shall apply the provisions of 40 CFR Part 63, Subpart H only. [40 CFR
63.160(b)]
b Per request of the Permittee, each process unit that has equipment to which the provisions of 40 CFR Part 63,
Subpart H do not apply but that is subject to 40 CFR Part 60, Subpart VV shall apply the provisions of 40 CFR
Part 63, Subpart H to all such equipment in the process unit. All VOC in such equipment shall be considered,
for purposes of applicability and compliance, as if it were a HAP. [40 CFR 63.160(c)]
2. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
General Standards [40 CFR 63.162]
a. Each piece of equipment in a process unit to which 40 CFR Part 63, Subpart H applies shall be identified such
that it can be distinguished readily from equipment that is not subject. The equipment may be identified on a
plant site plan, in log entries, or by designation of process unit boundaries by some form of weatherproof
identification. [40 CFR 63.162(c)]
b. Equipment that is in vacuum service is excluded from the requirements of 40 CFR Part 63, Subpart H. 40 CFR
63.162(d):
c. Equipment that is in organic HAP service less than 300 hours per calendar year excluded from the
requirements 40 CFR Part 63, Subpart H must be identified either by list, location (area or group) of
equipment. 40 CFR 63.162(e):
d. When each leak is detected for: pumps in light liquid service (40 CFR 63.163), valves in gas/vapor/light liquid
service (40 CFR 63.168), pumps/valves/connectors/agitators in heavy liquid service and instrumentation
systems/pressure relief devices in liquid service (40 CFR 63.169), agitators in gas/vapor/light liquid service (40
Permit 03387T44
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CFR 63.173), and connectors in gas/vapor/light liquid service (40 CFR 63.174), the following requirements
apply [40 CFR 63.162(f)]:
i. A weatherproof and readily visible identification, marked with the equipment identification number, shall
be attached to the leaking equipment.
ii. The identification on a valve may be removed after it has been repaired and monitored in accordance with
40 CFR 63.180(b) within three months of the repair and no leak has been detected during the follow-up
monitoring for two successive months.
iii. The identification on a connector may be removed after it is monitored after reconnection within the first
three months after being returned to service and no leak is detected during that monitoring.
iv. The identification that has been placed on equipment determined to have a leak may be removed after it is
repaired, except for a valve or connector.
e. It is a violation of this subpart to fail to take action to repair the leaks within the specified time. If action is
taken to repair the leaks within the specified time, failure of that action to successfully repair the leak is not a
violation. However, if the repairs are unsuccessful, a leak is detected and the Permittee shall take further
action as required. [40 CFR 63.162(h)]
3. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Pumps in Light Liquid Service [40 CFR 63.163]
[Light liquid means a liquid with a VOC with a vapor pressure greater than 0.3 kPa [0.0435 psi] at 20°C that is
present in the liquid in a concentration greater than 20 percent by weight.]
a. The Permittee shall monitor each affected pump monthly to detect leaks by the method specified in 40 CFR
63.180(b) and shall comply as set forth below. [40 CFR 63.163(b)]
i. The instrument reading, as determined by the method as specified in 40 CFR 63.180(b), that defines a leak
in each phase of the standard is 1,000 parts per million or greater.
ii. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal. If there are indications of liquids dripping from the pump seal, a leak is detected.
iii. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after
it is detected, except repair is not required unless an instrument reading of 2,000 parts per million or
greater is detected or delay in repair is necessary per 40 CFR 63.171.
iv. A first attempt at repair shall be made no later than five calendar days after the leak is detected. First
attempts at repair include, but are not limited to: tightening of packing gland nuts, and ensuring that the
seal flush is operating at design pressure and temperature.
b. The Permittee shall calculate percent leaking pumps on a process unit basis source wide basis. [40 CFR
63.163(d)]
i. If the greater of either 10 percent of the pumps or three pumps leak (calculated on a 6-month rolling
average), the Permittee shall implement a quality improvement program for pumps in accordance with 40
CFR 63.176.
ii. The number of pumps shall be the sum of all the pumps in organic HAP service, except that pumps found
leaking in a continuous process within one month after start-up of the pump shall not count in the percent
leaking pumps calculation for that one monitoring period only.
iii. Percent leaking pumps shall be determined by the following equation:
%PL + [(PL-PS)/(PT-PS)] x 100
where:
%PL = Percent leaking pumps.
PL = Number of pumps found leaking.
PT = Total pumps in organic HAP service, including those exempt from monitoring.
PS = Number of pumps leaking within 1 month of start-up during the current monitoring period.
c. Each pump equipped with a dual mechanical seal system that includes a barrier fluid system is exempt from
monitoring requirements provided the following requirements are met. [40 CFR 63.163(e)]
i. Each dual mechanical seal system is:
(A) operated with the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure; or
(B) equipped with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device complying with 40 CFR 63.172; or
Permit 03387T44
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(C) equipped with a closed-loop system that purges the barrier fluid into a process stream.
ii. The barrier fluid is not in light liquid service.
iii. Each barrier fluid system is equipped with a sensor that will detect failure of the seal system and /or the
barrier fluid system.
iv. Each pump is checked by visual inspection each calendar week for indications of liquids dripping from the
pump seal.
(A) If there are indications of liquids dripping from the pump seal at the time of the weekly inspection, the
pump shall be monitored to determine if there is a leak of organic HAP in the barrier fluid.
(B) If an instrument reading of 1,000 parts per million or greater is measured, a leak is detected.
v. Each seal system and /or the barrier fluid system sensor is observed daily or is equipped with an alarm
unless the pump is located within the boundary of an unmanned plant site.
vi. The Permittee determines, based on design considerations and operating experience, criteria applicable to
the presence and frequency of drips and to the sensor that indicates failure of the seal and/or barrier
system.
(A) If indications of liquids dripping from the pump seal or the sensor indicates failure (i.e., criteria
exceeded) of the seal system, the barrier fluid system, or both, a leak is detected.
(B) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days
after it is detected, except as provided in for in delay of repair pursuant to 40 CFR 63.171.
vii. A first attempt at repair shall be made no later than five calendar days after each leak is detected.
d. Any pump that is designed with no externally actuated shaft penetrating the pump housing is exempt from
monitoring requirements. [40 CFR 63.163(f)]
e. Any pump equipped with a closed vent system capable of capturing and transporting any leakage from the seal
or seals to a process or to a fuel gas system or to a control device is exempt from monitoring requirements and
calculations for percent leaking pumps. [40 CFR 63.163(g)]
f. Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual
inspection requirements and the daily requirements for seal/barrier fluid system sensor observation provided
that each pump is visually inspected as often as practicable and at least monthly. If more than 90 percent of the
pumps at a process unit are equipped with a closed vent system or located at an unmanned site, the process unit
is exempt from the calculation of percent leaking pumps requirement. [40 CFR 63.163(h) and (i)]
g. Any pump that is designated as an unsafe-to-monitor pump is exempt from monitoring and percent leaking
pumps calculation if:
i. the Permittee determines that the pump is unsafe to monitor because monitoring personnel would be
exposed to an immediate danger as a consequence of complying these above requirements; and
ii. the Permittee has a written plan that requires monitoring of the pump as frequently as practical during
safe-to-monitor times.
[40 CFR 63.163(j)]
h. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.3 a through g are not met.
4. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Pressure Relief Devices in Gas/Vapor Service [40 CFR 63.165]
a. Each pressure relief device in gas/vapor service shall be operated with an instrument reading of less than 500
parts per million above background, except during pressure releases, as measured by the method specified in
40 CFR 63.180(c).
b. After each pressure release, the pressure relief device shall be returned to a condition indicated by an
instrument reading of less than 500 parts per million above background, as soon as practicable, but no later
than five calendar days after each pressure release, except as provided in delay of repair 40 CFR 63.171.
c. No later than five calendar days after the pressure release and being returned to organic HAP service, the
pressure relief device shall be monitored to confirm the condition indicated by an instrument reading of less
than 500 parts per million above background.
d. Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed-vent system
capable of capturing and transporting leakage from the pressure relief device to a control device is exempt
from monitoring.
e. Any pressure relief device that is equipped with an upstream rupture disk is exempt from monitoring provided
the rupture disk is reinstalled as soon as practicable after each pressure release, but no later than five calendar
days after each pressure release, except as provided in delay of repair 40 CFR 63.171.
Permit 03387T44
Page 21
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.4 a through e are not met.
5. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Open Ended Valves or Lines [40 CFR 63.167]
a. Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as
provided below, which shall seal the open end at all times except during operations requiring process fluid
flow through the open-ended valve or line, or during maintenance or repair.
b. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve
on the process fluid end is closed before the second valve is closed.
c. When a double block and bleed system is being used, the bleed valve or line may remain open during
operations that require venting the line between the block valves but shall be closed at all other times.
d. Open-ended valves or lines in an emergency shutdown system that are designed to open automatically in the
event of a process upset are exempt from the above requirements.
e. Open-ended valves or lines containing materials which would auto catalytically polymerize or, would present
an explosion, serious over pressure, or other safety hazard if capped or equipped with a double block and bleed
system are exempt from the above requirements.
6. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Valves in Gas/Vapor/Light Liquid Service [40 CFR 63.168]
[Light liquid means a liquid with a VOC with a vapor pressure greater than 0.3 kPa [0.0435 psi] at 20°C that is
present in the liquid in a concentration greater than 20 percent by weight.]
a. The Permittee of a source subject to this subpart shall monitor using the method specified in 40 CFR 63.180(b)
all valves, except as provided below, at the intervals specified as follows.
i. At process units with two percent or greater leaking valves, the Permittee shall either:
(A) monitor each valve once per month; or
(B) implement a quality improvement program for valves pursuant to 40 CFR 63.175 (d) or (e) of this
subpart and monitor quarterly.
ii. At process units with less than two percent leaking valves, the Permittee shall monitor each valve once
each quarter
iii. At process units with less than one percent leaking valves, the Permittee may monitor each valve once
every two quarters.
iv. At process units with less than 0.5 percent leaking valves, the Permittee may monitor each valve once
every four quarters.
[40 CFR 63.168(d)]
b. An instrument reading of 500 part per million or greater defines a leak.
c. Percent leaking valves at a process unit shall be determined by the following equation:
%VL = [VL/(VT+VC)] x 100
where:
%VL = Percent leaking valves as determined through periodic monitoring.
VL = Number of valves found leaking, excluding nonrepairable valves. 1
VT = Total valves monitored, in a monitoring period excluding valve monitoring as required within three
months after a repair.
VC = Optional credit for removed valves = 0.67 x net number (i.e., total removed minus total added) of
valves in organic HAP service removed from process unit. If credits are not taken, then VC = 0.
[40 CFR 63.168(e)(1)]
d. The percent leaking valves shall be calculated as a rolling average of two consecutive monitoring periods for
monthly, quarterly, or semiannual monitoring programs; and as an average of any three out of four consecutive
monitoring periods for annual monitoring programs.[40 CFR 63.168(e)(2)]
1 Nonrepairable valves shall be included in the calculation of percent leaking valves the first time the valve is identified as "leaking
and nonrepairable." If the number of nonrepairable valves exceeds one percent of the total number of valves in organic HAP
service at a process unit, then the number of nonrepairable valves exceeding one percent of the total number of valves in organic
Permit 03387T44
Page 22
e. When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after the
leak is detected, except as provided in delay of repair 40 CFR 63.171. A first attempt at repair shall be made
no later than five calendar days after each leak is detected. [40 CFR 63.168(f)(1) and (2)]
f. When a leak has been repaired, the valve shall be monitored (as specified in 40 CFR 63.180(b) and (c), as
appropriate) at least once within the first three months after its repair to determine whether the valve has
resumed leaking. If a leak is detected, the Permittee shall count the valve as a leaking valve unless it is
repaired and shown by periodic monitoring not to be leaking. [40 CFR 63.168(f)(3)]
g. First attempts at repair include, but are not limited to, the following practices where practicable:
i. tightening of bonnet bolts,
ii. replacement of bonnet bolts,
iii. tightening of packing gland nuts, and
iv. injection of lubricant into lubricated packing.
[40 CFR 63.168(g)]
h. Any valve that is unsafe-to-monitor is exempt from the monitoring, percent leaking valves calculation, and
repair requirements if:
i. The Permittee determines that the valve is unsafe to monitor because monitoring personnel would be
exposed to an immediate danger as a consequence of complying with requirements; and
ii. The Permittee has a written plan that requires monitoring of the valve as frequently as practicable during
safe-to-monitor times.
[40 CFR 63.168(h)]
i. Any valve that is determined as difficult-to-monitor is exempt from the monitoring and percent leaking valves
calculation requirements if:
i. The Permittee determines that the valve cannot be monitored without elevating the monitoring personnel
more than two meters above a support surface or it is not accessible at anytime in a safe manner;
ii. The process unit within which the valve is located is an existing source or the Permittee designates less
than three percent of the total number of valves in a new source as difficult-to-monitor; and
iii. The Permittee follows a written plan that requires monitoring of the valve at least once per calendar year.
[40 CFR 63.168(i)]
j. Any equipment located at a plant site with fewer than 250 valves in organic HAP service is exempt from the
requirements for monthly monitoring and a quality improvement program. Instead, the Permittee shall monitor
each valve in organic HAP service for leaks once each quarter, or once every two quarters at process units with
less than one percent leaking valves, or once every four quarters at process units with less than 0.5 percent
leaking valves, with exception for unsafe or difficult to monitor valves. [40 CFR 63.168(j)]
k. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.6 a through j are not met.
7. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Pumps, Valves, Connectors, and Agitators in Heavy Liquid Service, Pressure Relief Devices in Light and
Heavy Liquid Service, and Instrumentation Systems [40 CFR 63.169]
a. Pumps, valves, connectors, and agitators in heavy liquid service, pressure relief devices in light liquid or heavy
liquid service, and instrumentation systems shall be monitored by the method specified in 40 CFR 63.180(b)
within five calendar days if evidence of a potential leak to the atmosphere is found by visual, audible,
olfactory, or any other detection method. If such a potential leak is repaired as set forth below, it is not
necessary to monitor the system for leaks by the method specified in 40 CFR 63.180(b). [40 CFR 63.169(a)]
b. If an instrument reading of 10,000 parts per million or greater for agitators, 2,000 parts per million or greater
for pumps, or 500 parts per million or greater for valves, connectors, instrumentation systems, and pressure
relief devices is measured, a leak is detected.
c. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is
detected, except as provided in delay of repair 40 CFR 63.171. The first attempt at repair shall be made no
later than five calendar days after each leak is detected. [40 CFR 63.169(c)(1) and (2)]
d. For a potential leak to the atmosphere found by visual, audible, olfactory, or any detection method other than
that prescribed in accordance with 40 CFR 63.180(b), repaired shall mean that the visual, audible, olfactory, or
HAP service shall be included in the calculation of percent leaking valves. Otherwise, a number of nonrepairable valves (identified
and included in the percent leaking calculation in a previous period) up to a maximum of one percent of the total number of valves
in organic HAP service at a process unit may be excluded from calculation of percent leaking valves for subsequent monitoring
periods.
Permit 03387T44
Page 23
other indications of a leak to the atmosphere have been eliminated; that no bubbles are observed at potential
leak sites during a leak check using soap solution; or that the system will hold a test pressure. [40 CFR
63.169(c)(3)]
e. First attempts at repair include, but are not limited to:
i. tightening of packing gland nuts, and ensuring that the seal flush is operating at design pressure and
temperature for pumps; and
ii. tightening of bonnet bolts, replacement of bonnet bolts, tightening of packing gland nuts, and injection of
lubricant into lubricated packing for valves.
[40 CFR 63.169(d)]
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.7.a, c, d, and e are not met.
8. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Agitators in Gas/Vapor/Light Liquid Service [40 CFR 63.173]
[Light liquid means a liquid with a VOC with a vapor pressure greater than 0.3 kPa [0.0435 psi] at 20°C that is
present in the liquid in a concentration greater than 20 percent by weight.]
a. Each agitator shall be monitored monthly to detect leaks by the methods specified in 40 CFR 63.180(b). If an
instrument reading of 10,000 parts per million or greater is measured, a leak is detected.
b. Each agitator shall be checked by visual inspection each calendar week for indications of liquids dripping from
the agitator. If there are indications of liquids dripping from the agitator, a leak is detected.
c. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is
detected, except as provided in delay of repair 40 CFR 63.171. A first attempt at repair shall be made no later
than five calendar days after each leak is detected.
d. Each agitator equipped with a dual mechanical seal system that includes a barrier fluid system is exempt
monthly monitoring by the methods specified in 40 CFR 63.180(b) provided the following requirements are
met.
i. Each dual mechanical seal system shall be:
(A) operated with the barrier fluid at a pressure that is at all times greater than the agitator stuffing box
pressure; or
(B) equipped with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device; or
(C) equipped with a closed-loop system that purges the barrier fluid into a process stream.
ii. The barrier fluid shall not be in light liquid organic HAP service.
iii. Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal and/or barrier
fluid system.
iv. Each agitator shall be checked by visual inspection each calendar week for indications of liquids dripping
from the agitator seal.
(A) If there are indications of liquids dripping from the agitator seal at the time of the weekly inspection,
the agitator shall be monitored as specified in 40 CFR 63.180(b) to determine the presence of organic
HAP in the barrier fluid.
(B) If an instrument reading of 10,000 parts per million or greater is measured, a leak is detected.
v. Each barrier fluid/seal system equipped with a sensor shall be observed daily or equipped with an alarm,
unless the agitator is located within the boundary of an unmanned plant site.
vi. The Permittee shall determine, based on design considerations and operating experience, criteria
applicable to the presence and frequency of drips and to the sensor that indicates failure of the seal and/or
barrier system.
(A) If indications of liquids dripping from the agitator seal exceed these criteria, or if, based on the
criteria, the sensor indicates failure of the seal and/or barrier fluid system, a leak is detected.
(B) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days
after it is detected, except as provided in delay of repair 40 CFR 63.171, and a first attempt at repair
shall be made no later than five calendar days after each leak is detected.
e. Any agitator that is designed with no externally actuated shaft penetrating the agitator housing is exempt from
monitoring requirements.
f. Any agitator equipped with a closed-vent system capable of capturing and transporting any leakage from the
seal or seals to a process or fuel gas system or to a control device is exempt from monitoring requirements.
Permit 03387T44
Page 24
g. Any agitator that is located within the boundary of an unmanned plant site is exempt from the weekly visual
inspection for liquids dripping requirements, and the daily requirements for monitoring seal/barrier fluid sensor
systems, provided that each agitator is visually inspected as often as practical and at least monthly.
h. Any agitator that is difficult-to monitor is exempt from monitoring requirements if:
i. The Permittee determines that the agitator cannot be monitored without elevating the monitoring personnel
more than two meters above a support surface or it is not accessible at anytime in a safe manner;
ii. The process unit within which the agitator is located is an existing source or the Permittee designates less
than three percent of the total number of agitators in a new source as difficult-to-monitor; and
iii. The Permittee follows a written plan that requires monitoring of the agitator at least once per calendar
year.
i. Any agitator that is obstructed by equipment or piping that prevents access to the agitator by a monitor probe is
exempt from monitoring requirements.
j. Any agitator that is designated as an unsafe-to-monitor agitator is exempt from the monitoring requirements if:
i. the Permittee determines that the agitator is unsafe to monitor because monitoring personnel would be
exposed to an immediate danger; and
ii. the Permittee has a written plan that requires monitoring of the agitator as frequently as practical during
safe-to-monitor times.
k. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.8.a through j are not met
9. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Connectors in Gas/Vapor/Light Liquid Service [40 CFR 63.174]
[Light liquid means a liquid with a VOC with a vapor pressure greater than 0.3 kPa [0.0435 psi] at 20°C that is
present in the liquid in a concentration greater than 20 percent by weight.]
a. The Permittee shall monitor connectors to detect leaks by the method specified in 40 CFR 63.180(b). If an
instrument reading greater than or equal to 500 parts per million is measured, a leak is detected.
b. The Permittee shall monitor for leaks according to the schedule established as follows.
i. Once per year (i.e., 12-month period), if the percent leaking connectors in the process unit was 0.5 percent
or greater during the last required annual or biennial monitoring period,
ii. Once every two years, if the percent leaking connectors was less than 0.5 percent during the last required
monitoring period. The Permittee may comply with this paragraph by monitoring at least 40 percent of the
connectors in the first year and the remainder of the connectors in the second year. The percent leaking
connectors will be calculated for the total of all monitoring performed during the two year period.
iii. If the Permittee of a process unit in a biennial leak detection and repair program calculates less than 0.5
percent leaking connectors from the two year monitoring period, the Permittee may monitor the
connectors once every 4 years. A Permittee may comply with these requirements by monitoring at least 20
percent of the connectors each year until all connectors have been monitored within four years.
iv. If a process unit complying with the monitoring requirements using a four year monitoring interval
program has greater than or equal to 0.5 percent but less than one percent leaking connectors, the
Permittee shall increase the monitoring frequency to one time every two years. A Permittee may comply
with the requirements of this paragraph by monitoring at least 40 percent of the connectors in the first year
and the remainder of the connectors in the second year. The Permittee may again elect to monitor on the
four year schedule when the percent leaking connectors decreases to less than 0.5 percent.
v. If a process unit complying with on the four year monitoring schedule has one percent or greater leaking
connectors, the Permittee shall increase the monitoring frequency to one time per year.
The Permittee may again elect to monitor on the four year schedule when the percent leaking connectors
decreases to less than 0.5 percent.
c. Each connector that has been opened or has otherwise had the seal broken shall be monitored for leaks when it
is reconnected or within the first three months after being returned to organic hazardous air pollutants service.
If the Permittee chooses not to monitor these connectors, the Permittee shall not count nonrepairable
connectors in determining the monitoring frequency and calculate the percent leaking connectors by setting the
nonrepairable component CAN of the equation to zero for all monitoring periods. The Permittee may switch
alternatives for the accounting of nonrepairable valves at the end of a monitoring period provided that it is
documented in the periodic report. The Permittee may begin the new alternative in annual monitoring. The
initial monitoring in the new alternative shall be completed no later than 12 months after reporting the switch.
d. If the monitoring detects a leak, it shall be repaired as soon as practicable, but no later than 15 calendar days
after the leak is detected, except as provided for unsafe or inaccessible connectors, or if a delay of repair is
Permit 03387T44
Page 25
required pursuant to 40 CFR 63.171, or if it is nonrepairable. A first attempt at repair shall be made no later
than five calendar days after the leak is detected.
e. As an alternative to the monitoring schedule established above, each screwed connector two inches or less in
nominal inside diameter installed in a process unit before December 31, 1992 may comply with leak detection
by visual, audible, olfactory, or any detection method other than that prescribed in accordance with 40 CFR
63.180(b).
i. The repair of connectors detected by visual audible, olfactory, or other than 40 CFR 63.180(b) method
shall mean that the visual, audible, olfactory, or other indications of a leak to the atmosphere have been
eliminated; that no bubbles are observed at potential leak sites during a leak check using soap solution; or
that the system will hold a test pressure.
ii. The connectors shall be monitored for leaks within the first three months after being returned to organic
hazardous air pollutants service after having been opened or otherwise had the seal broken. If that
monitoring detects a leak, it shall be repaired it shall be repaired as soon as practicable, but no later than
15 calendar days after the leak is detected, except as provided for unsafe or inaccessible connectors, or if a
delay of repair is required pursuant to 40 CFR 63.171, or if it is nonrepairable. A first attempt at repair
shall be made no later than five calendar days after the leak is detected.
f. Any connector that is designated unsafe to monitor is exempt from monitoring of connectors that have not been
opened requirements if:
i. the Permittee determines that the connector is unsafe to monitor because personnel would be exposed to an
immediate danger; and
ii. the Permittee has a written plan that requires monitoring of the connector as frequently as practicable
during safe to monitor periods.
g. Any connector that is designated unsafe to repair is exempt from monitoring of connectors that have not been
disconnected and the 5/15 day repair schedule requirements if:
i. the Permittee determines that the connector is unsafe to repair because personnel would be exposed to an
immediate danger; and
ii. the connector will be repaired before the end of the next scheduled process unit shutdown.
h. Any connector that is inaccessible or is ceramic or ceramic-lined (e.g., porcelain, glass, or glass-lined), is
exempt from the monitoring requirements from recordkeeping and reporting requirements. An inaccessible
connector is one that is:
i. buried,
ii. insulated in a manner that prevents access to the connector by a monitor probe,
iii. obstructed by equipment or piping that prevents access to the connector by a monitor probe,
iv. unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold which would allow access to
connectors up to 7.6 meters (25 feet) above the ground,
v. inaccessible because it would require elevating the monitoring personnel more than two meters above a
permanent support surface or would require the erection of scaffold, or not able to be accessed at any time
in a safe manner to perform monitoring. Unsafe access includes, but is not limited to, the use of a wheeled
scissor-lift on unstable or uneven terrain, the use of a motorized man-lift basket in areas where an ignition
potential exists, or access would require near proximity to hazards such as electrical lines, or would risk
damage to equipment.
If any inaccessible or ceramic or ceramic-lined connector is observed by visual, audible, olfactory, or other
means to be leaking, the leak shall be repaired as soon as practicable, but no later than 15 calendar days
after the leak is detected, except as provided in delay of repair pursuant to 40 CFR 63.171, or has been
determined to be unsafe to repair. A first attempt at repair shall be made no later than five calendar days
after the leak is detected.
i. The percent leaking connectors shall be calculated with the following equation:
% CL = [(CL-CAN)/(Ct + CC)] 100
where:
% CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors, including nonrepairables, measured at 500 parts per million or greater.
CAN = Number of allowable nonrepairable connectors, as determined by monitoring, not to exceed two
percent of the total connector population, Ct.
Ct = Total number of monitored connectors, including nonrepairables, in the process unit.
CC = Optional credit for removed connectors = 0.67 x net number (i.e., total removed - total added) of
connectors in organic hazardous air pollutants service removed from the process unit. If credits are
not taken, then CC= 0.
Permit 03387T44
Page 26
j. If the Permittee eliminates a connector subject to monitoring, the Permittee may receive credit for elimination
of the connector in the calculation of percent leaking connectors provided the following requirements are met.
i. The connector was welded after December 31, 1992.
ii. The integrity of the weld is demonstrated by monitoring it according to the procedures in 40 CFR
63.180(b) or by testing using X-ray, acoustic monitoring, hydrotesting, or other applicable method.
iii. Welds created after December 31, 1992 but before April 22, 1994 are monitored or tested within three
months after the applicable compliance date [40 CFR 63.100(k)(3)].
iv. Welds created after April 22, 1994 are monitored or tested within three months after being welded.
v. If an inadequate weld is found or the connector is not welded completely around the circumference, the
connector is not considered a welded connector.
k. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.9.a through j are not met
10. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Compressors [40 CFR 63.164]
a. Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents
leakage of process fluid to the atmosphere, except as provided in below, and shall be:
i. operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or
ii. equipped with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device; or
iii. equipped with a closed-loop system that purges the barrier fluid directly into a process stream.
b. The barrier fluid shall not be in light liquid service.
c. Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system and/or barrier
fluid system.
d. Each seal and/or barrier fluid system sensor shall be observed daily or shall be equipped with an alarm unless
the compressor is located within the boundary of an unmanned plant site.
e. The Permittee shall determine, based on design considerations and operating experience, a criterion that indicates
failure of the seal system, the barrier fluid system, or both.
f. If indications of liquids dripping from the compressor seal or the sensor indicate failure (i.e., criteria exceeded)
of the seal system, the barrier fluid system, or both, a leak is detected.
g. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is
detected, except as provided in delay of repair 40 CFR 63.171. A first attempt at repair shall be made no later
than five calendar days after each leak is detected.
h. A compressor is exempt from monitoring requirements if it is equipped with a closed-vent system to capture and
transport leakage from the compressor drive shaft seal back to a process or a fuel gas system or to a control
device.
i. Any compressor that is designated to operate with an instrument reading of less than 500 parts per million
above background, as specifically listed per recordkeeping requirements of Section 2.1 D.12.b.v., may
demonstrate on an annual basis, or at the request of the DAQ, that it is operating with an instrument reading of
less than 500 parts per million above background as measured by the method specified in 40 CFR 63.180(c) is
exempt.
j. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.10.a through g are not met.
11. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Sampling Connection Systems [40 CFR 63.166]
a. Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed-vent system.
Gases displaced during filling of the sample container are not required to be collected or captured.
b. Each closed-purge, closed-loop, or closed-vent system shall:
i. Return the purged process fluid directly to the process line; or
ii. Collect and recycle the purged process fluid to a process; or
iii. Be designed and operated to capture and transport the purged process fluid to a control device; or
iv. Collect, store, and transport the purged process fluid to:
(A) A group 1 wastewater if the purged process fluid contains any organic HAP listed in Table 9 of 40 CFR
Part 63, Subpart G;
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(B) A treatment, storage, or disposal facility subject to regulation under 40 CFR Part 262, 264, 265, or 266;
or
(C) A facility permitted, licensed, or registered by a State to manage municipal or industrial solid waste, if
the process fluids are not hazardous waste as defined in 40 CFR Part 261.
c. In-situ sampling systems and sampling systems without purges are exempt.
d. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.D.11.a and b are not met.
12. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Recordkeeping Requirements [40 CFR 63.181]
a. The Permittee may comply with the recordkeeping requirements for multiple process units in one
recordkeeping system if the system identifies each record by process unit and the program being implemented
(e.g., quarterly monitoring, quality improvement) for each type of equipment. All records and information shall
be maintained in a manner that can be readily accessed at the plant site.
b. The following information pertaining to all equipment in each affected process unit shall be recorded.
i. A list of identification numbers for all affected equipment (except connectors exempt from monitoring and
recordkeeping and instrumentation systems). Connectors need not be individually identified if all
connectors in a designated area or length of pipe subject to the provisions of this subpart are identified as a
group, and the number of affected connectors is indicated.
ii. A schedule, by process unit, for monitoring affected connectors and valves.
iii. Physical tagging of the equipment to indicate that it is in organic HAP service is not required. Affected
equipment may be identified on a plant site plan, in log entries, or by other appropriate methods.
iv. A list of identification numbers for affected pressure relief devices.
v. A list of identification numbers for compressors that the Permittee elects to designate as operating with an
instrument reading of less than 500 parts per million above background pursuant to Section 2.2 D.10.i.
vi. A list of identification numbers for affected pressure relief devices equipped with rupture disks.
vii. Identification of affected instrumentation systems. Individual components in an instrumentation system
need not be identified.
viii. Identification of screwed connectors two inches in diameter or less and installed before December 31,
1992 that will be electively monitored in accordance with Section 2.1 D.9.e. Identification can be by area
or grouping as long as the total number within each group or area is recorded.
ix. The following information shall be recorded for each dual mechanical seal system:
(A) Design criteria required in Section 2.1 D.3.c.vi. for pumps in light liquid service, Section 2.1 D.8.d.vi.
for agitators in gas/vapor/light liquid service, and Section 2.1 D.10.e. for compressors and an
explanation of the design criteria pertaining to the presence and frequency of drips and to the sensor
that indicates a failure of the seal and/or barrier system; and
(B) Any changes to these criteria and the reasons for the changes.
x. The following information pertaining to all unsafe to monitor pumps (Section 2.1 D.3.g.), unsafe or
difficult to monitor valves (Section 2.1 D.6.i. and Section 2.1 D.6.j., respectively), difficult to monitor or
unsafe to monitor agitators (Section 2.1 D.8.h. and Section 2.1 D.8.j., respectively), and unsafe to monitor
or unsafe to repair connectors (Section 2.1 D.9.f. and 2.1 D.9.g., respectively) shall be recorded:
(A) Identification of equipment designated as unsafe to monitor, difficult to monitor, or unsafe to inspect
and the plan for monitoring or inspecting this equipment.
(B) A list of identification numbers for the equipment that is designated as difficult to monitor, an
explanation of why the equipment is difficult to monitor, and the planned schedule for monitoring this
equipment.
(C) A list of identification numbers for connectors that are designated as unsafe to repair and an
explanation why the connector is unsafe to repair.
xi. A list of valves removed from and added to the process unit for calculation of percent leaking valves
(Section 2.1 D.6.c.) if the net credits for removed valves (VC) are expected to be used.
xii. A list of connectors removed from and added to the process unit during the first monitoring period as
determined pursuant to 40 CFR 63.174(i)(1), and documentation of the integrity of the weld for any
removed connectors in the calculation of percent leaking connectors (Section 2.1 D.9.i.). This is not
required unless the net credits for removed connectors (CC) are expected to be used.
c. For visual inspections of pumps in light liquid service (Section 2.1 D.3.a.ii. and Section 2.1 D.3.c.iv.(A)), the
Permittee shall document that the inspection was conducted and the date of the inspection. The Permittee shall
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maintain records as specified below in 2.1 D.12.d. for leaking equipment identified in this inspection, except as
provided below in 2.1 D.12.e.
d. When each leak is detected as specified for affected equipment including: pumps in light liquid service
(Section 2.1 D.3.), valves in gas/vapor/light liquid service (Section 2.1 D.6.),
pumps/valves/connectors/agitators in heavy liquid service/pressure relief devices in liquid
service/instrumentation systems (Section 2.1 D.7.), agitators in gas/vapor/light liquid service (Section 2.1
D.8.), connectors in gas/vapor/light liquid service (Section 2.1 D.9.), and compressors (Section 2.1 D.10.) the
following information shall be recorded and retained in accordance with the general provisions of this permit:
i. The instrument and the equipment identification number and the operator name, initials, or identification
number.
ii. The date the leak was detected and the date of first attempt to repair the leak.
iii. The date of successful repair of the leak.
iv. Maximum instrument reading measured by Method 21 of 40 CFR Part 60, Appendix A after it is
successfully repaired or determined to be nonrepairable.
v. "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after
discovery of the leak.
(A) The Permittee may develop a written procedure that identifies the conditions that justify a delay of
repair. The written procedures may be included as part of the startup/shutdown/ malfunction plan for
the source or may be part of a separate document that is maintained at the plant site. In such cases,
reasons for delay of repair may be documented by citing the relevant sections of the written
procedure.
(B) If delay of repair was caused by depletion of stocked parts, there must be documentation that the spare
parts were sufficiently stocked on-site before depletion and the reason for depletion.
vi. Dates of process unit shutdowns that occur while the equipment is unrepaired.
vii. Identification, either by list, location (area or grouping), or tagging of connectors that have been opened or
otherwise had the seal broken since the last monitoring period established pursuant to Section 2.1 D.9.b.,
as described in Section 2.1 D.9.c., unless the Permittee chooses not to monitor theses valves and sets the
variable CAN equal to zero in the calculation of percent leaking valves pursuant to Section 2.1 D.9.c.
viii. The date and results of monitoring connectors that have been opened pursuant Section 2.1 D.9.c. If
identification of connectors that have been opened or otherwise had the seal broken is made by location
above in Section 2.1 D.9.d.vii., then all connectors within the designated location shall be monitored.
ix. Copies of the periodic reports, if records are not maintained on a computerized database capable of
generating summary reports from the records.
e. The dates and results of each compliance test required for compressors operating with an instrument reading of
less than 500 ppmv above background and exempt from monitoring requirements for compressors (Section 2.2
D.10.) and the dates and results of the monitoring following a pressure release for each affected pressure relief
device. The results shall include:
i. The background level measured during each compliance test.
ii. The maximum instrument reading measured at each piece of equipment during each compliance test.
[40 CFR 63.181(f)]
f. The Permittee shall maintain the records for quality improvement programs for valve and pumps developed
pursuant to 40 CFR 63.175 and 40 CFR 63.176 as specified below for the period of the quality improvement
program for the process unit. [40 CFR 63.181(h)]
i. If the Permittee elects to use a reasonable further progress quality improvement program, as specified in
40 CFR 63.175(d) for valves, the following records must be maintained:
(A) All data required in 40 CFR 63.175(d)(2).
(B) The percent leaking valves observed each quarter and the rolling average percent reduction observed
in each quarter.
(C) The beginning and ending dates while meeting the requirements of 40 CFR 63.175(d) of this subpart.
ii. If the Permittee elects to use a quality improvement program of technology review and improvement, as
specified in 40 CFR 63.175(e) for valves, the following record must be maintained:
(A) All data required in 40 CFR 63.175(e)(2).
(B) The percent leaking valves observed each quarter.
(C) Documentation of all inspections conducted pursuant to 40 CFR 63.175(e)(4) and any
recommendations for design or specification changes to reduce leak frequency.
(D) The beginning and ending dates while meeting the requirements of 40 CFR 63.175(e).
iii. If the Permittee is subject to the requirements of the pump quality improvement program as specified in 40
CFR 63.176, the following records must be maintained:
(A) All data required in 40 CFR 63.176(d)(2).
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(B) The rolling average percent leaking pumps.
(C) Documentation of all inspections conducted pursuant to 40 CFR 63.176(d)(4) and any
recommendations for design or specification changes to reduce leak frequency.
(D) The beginning and ending dates while meeting the requirements of 40 CFR 63.176(d).
iv. If a leak is not repaired within 15 calendar days after discovery of the leak, the reason for the delay and the
expected date of successful repair.
v. Records of all analyses required in 40 CFR 63.175(e) for valves and 40 CFR 63.176(d) for pumps. The
records will include the following:
(A) A list identifying areas associated with poorer than average performance and the associated service
characteristics of the stream, the operating conditions and maintenance practices.
(B) The reasons for rejecting specific candidate superior emission performing valve or pump technology
from performance trials.
(C) The list of candidate superior emission performing valve or pump technologies, and documentation of
the performance trial program items required pursuant to 40 CFR 63.175(e)(6)(iii) and 40 CFR
63.176(d)(6)(iii).
(D) The beginning date and duration of performance trials of each candidate superior emission performing
technology.
vi. All records documenting the quality assurance program for valves or pumps as specified in 40 CFR
63.175(e)(7) and 40 CFR 63.176(d)(7).
vii. Records indicating that all valves or pumps replaced or modified during the period of the quality
improvement program are in compliance with the quality assurance requirements in 40 CFR 63.175(e)(7)
and 40 CFR 63.176(d)(7).
viii. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps as
specified in 40 CFR 63.176(d)(8).
g. The Permittee shall retain information, data, and analyses used to determine that a piece of equipment is in
heavy liquid service, or demonstrate that the piece of equipment or process is in heavy liquid service when
requested by the DAQ. A determination or demonstration that a piece of equipment or process is in heavy
liquid service shall include an analysis or demonstration that the process fluids do not meet the definition of "in
light liquid service." Examples of information that could document this include, but are not limited to, records
of chemicals purchased for the process, analyses of process stream composition, engineering calculations, or
process knowledge. [40 CFR 63.181(i)]
h. Identification, either by list, location (area or group) of equipment in organic HAP service less than 300 hours
per year within a process unit subject to the provisions of 40 CFR Part 63, Subpart H. [40 CFR 63.181(j)]
i. Records required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
j. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the recordkeeping requirements
in Section 2.1.D.12.a through i are not met.
13. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
H, National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks
Reporting Requirements [40 CFR 63.182(d)]
a. The Permittee shall submit periodic reports postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the preceding
six-month period between January and June. For each affected process unit, the report shall contain a summary
of information for each monitoring period during the 6-month period regarding the following items. [40 CFR
63.182(d)(2)]
i. The number of valves for which leaks were detected as described in Section 2.1 D.6.a., the percent leakers,
and the total number of valves monitored.
ii. The number of valves for which leaks were not repaired as required in Sections 2.1 D.6.e. and g.,
identifying the number of those that are determined nonrepairable.
iii. The number of pumps for which leaks were detected as described in Sections 2.1 D.3.a., a.i., and a.ii., the
percent leakers, and the total number of pumps monitored.
iv. The number of pumps for which leaks were not repaired as required in Sections 2.1 D.3.a.iii, and a.iv.
v. The number of agitators for which leaks were detected as described in Sections 2.1 D.8a. and b.
vi. The number of agitators for which leaks were not repaired as required in Section 2.1 D.8.c.
vii. The number of connectors for which leaks were detected as described in Section 2.1 D.9.a., the percent of
connectors leaking, and the total number of connectors monitored.
Permit 03387T44
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viii. The number of connectors for which leaks were not repaired as required in Section 2.1 D.9.d., identifying
the number of those that are determined nonrepairable;
ix. The number of compressors for which leaks were detected as described in Section 2.2 D.10.f.
x. The number of compressors for which leaks were not repaired as required in Sections 2.2 D.10.g.
xi. The facts that explain any delay of repairs and, where appropriate, why a process unit shutdown was
technically infeasible.
xii. The results of all monitoring to show compliance with Section, 2.1 D.4.a. (pressure relief devices) and
Section 2.1D.10.i. (compressors) conducted within the semiannual reporting period.
xiii. If applicable, the initiation of a monthly monitoring program under Section 2.1 D.6.a.i.(A) for process
units with two percent or greater leaking valves, or a quality improvement program under either 40 CFR
63.175 or 40 CFR 63.176.
xiv. If applicable, notification of a change in connector monitoring alternatives as described in Section 2.1
D.9.c.
b. Any revisions to items reported in earlier Notification of Compliance Status, if the method of compliance has
changed since the last report. [40 CFR 63.182(d)(4)]
c. Reporting required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g.,
maintenance waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
E. Urea Storage, Handling, and Conveying
Formaldehyde Production
o Urea water tank with cyclone separator (ID No. UW1) with cartridge filter (ID No.
CD-UWBH)
o Urea water tank with cyclone separator (ID No. UW2) with cartridge filter (ID No.
CD-UWBH)
Resin Production
o Urea weighing and conveying for BR2 (ID No. ES24) with fabric filter (ID No. CD24)
o Urea weighing and conveying for BR2 and BR3 (ID No. UWC1) with fabric filter (ID
No. CDBF1)
o Urea weighing and conveying for BR3 (ID No. UWC2) with fabric filter (ID No.
CDBF2)
o Urea weighing and conveying for BR4 (ID No. ES26) with fabric filter (ID No. CD26)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
PM For process rates up to 30 tons per hour
E = 4.10 x P 0.67
For process rates greater than 30 tons per hour
E = 55.0 x P 0.11 -40
Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
15A NCAC 02D .0515
Visible emissions Visible emissions shall not exceed 20 percent opacity 15A NCAC 02D .0521
VOC VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
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Regulated Pollutant Limits/Standards Applicable Regulation
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 2 D.1100
1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from the emission sources shall not exceed an allowable emission rate as
calculated by the following equation: [15A NCAC 02D .0515(a)]
For process rates up to 30 tons per hour
E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
For process rates greater than 30 tons per hour
E = 55.0 x P 0.11 -40 Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 E.1.a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0515.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the listed emission sources shall be controlled by a fabric filter or cartridge
filter as delineated in the equipment list. To assure compliance, the Permittee shall perform inspections and
maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and
maintenance recommendations, or if there are no manufacturer’s inspection and maintenance
recommendations, as a minimum, the inspection and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and the baghouses for leaks and structural integrity;
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and baghouses
are not inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-
site and made available to an authorized representative upon request. The logbook shall record the following
for ductwork and the baghouse:
i. the date and time of each recorded action;
ii. the results of each inspection; and
iii. the results of any maintenance performed on the baghouse.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on each control device within 30 days of a
written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the listed emission sources shall not be more than 20 percent opacity when averaged
over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average
exceed 87 percent opacity. [15A NCAC 02D .0521(d)]
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Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 E.2.a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year
period to ensure compliance with this requirement. If visible emissions from this source are observed to be
above normal, the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 E.2.a.above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be
made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
F. Equipment Subject to 40 CFR Part 63, Subpart G, Group 2 Process Vents, Storage Vessels,
Transfer Operations, and Wastewater Operations
Hexamine Reactor (ID No. HRE)
Formaldehyde Plant No. 3 De-acidifier (ID No. FORM3)
Group 2 Storage Tanks
o Distillation column raw product feed tanks for formaldehyde processes (ID Nos.
CFR12 and CFR3)
o Two methaform / wastewater storage tanks (ID Nos. STORE1MAF1 and
STORE1MAF2)
o Nine formaldehyde / wastewater storage tanks (ID Nos. STOREFORM1 through
STORE1FORM9)
o 50% formaldehyde, UFC, and hydrolyzed re-work resin storage tank (ID No.
MOSTORE 2) vented to scrubbers (ID Nos. CD200A and CD200B) or to atmosphere
when scrubbers (ID Nos. CD200A and CD200B) are not in operation
o Seven formaldehyde (various blends)/methaform storage tanks (FORMSTG1
through FORMSTG7)
o Three 50% formaldehyde, UFC, and hydrolyzed re-work resin storage tanks (ID
Nos. MOSTORE 1A through MOSTORE 1C) vented to scrubbers (ID Nos. CD200A
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and CD200B) or to atmosphere when scrubbers (ID Nos. CD200A and CD200B) are
not in operation
o Two 50% formaldehyde, UFC, and hydrolyzed re-work resin storage tanks (ID No.
MOSTORE 1D through MOSTORE 1E) vented to scrubbers (ID Nos. CD200A and
CD200B) or to atmosphere when scrubbers (ID Nos. CD200A and CD200B) are not in
operation
o One distillation column raw product feed tank (ID No. CFRT3)
o Three hexamine process water, defoamer, catalyst, and wastewater tanks (ID Nos.
ESOT1, ESOT2, and ESOT3)
o Two hexamine concentrate water, defoamer, catalyst, and wastewater tanks (ID Nos.
ESCT1 and ESCT2)
o One liquid hexamine, defoamer, catalyst, and wastewater tank (ID No. ESLH1)
o Hexamine distillate, defoamer, catalyst, and wastewater tank (ID No. ESDS)
Group 2 Transfer Racks
o Railcar urea formaldehyde concentrate product load out (ID No. RLOAD3) vented to
scrubbers (ID Nos. CD200A and CD200B) or to atmosphere when scrubbers (ID Nos.
CD200A and CD200B) are not in operation
o Tank truck urea formaldehyde concentrate product load out (ID No. TLOAD2A)
vented to scrubbers (ID Nos. CD200A and CD200B) or to atmosphere when
scrubbers (ID Nos. CD200A and CD200B) are not in operation
o Tank truck hexamine load out (ID No. TLOAD3A)
o Rail car hexamine load out (ID No. RLOAD4)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAP The Permittee shall maintain a TRE greater than 4.0 for the
Group 2 process vent
(ID No. HRE only)
15A NCAC 02D .1111
40 CFR 63, Subpart G
HAP The Permittee shall retain records for the Group 2 wastewater
sources (ID Nos. HRE and FORM3 only)
15A NCAC 02D .1111
40 CFR 63, Subpart G
HAP The Permittee shall retain records for Group 2 storage tanks
(as delineated above)
15A NCAC 02D.1111
40 CFR 63, Subpart G
HAP The Permittee shall retain records for Group 2 transfer racks
(as delineated above)
15A NCAC 02D.1111
40 CFR 63, Subpart G
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D.1111
40 CFR 63, Subpart F
VOC VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 2 D.1100
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1. 15A NCAC 02D .1111, MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
G, Group 2 Process Vent Requirements
a. The Permittee shall maintain a TRE index value greater than 4.0 (ID No. HRE only).
Testing [15A NCAC 02Q .0508(f) and 40 CFR 63.115]
b. The Permittee shall recalculate the TRE index value, flow, or organic hazardous air pollutants concentration
for each process vent, as necessary to determine whether the vent is Group 1 or Group 2, whenever process
changes are made that could reasonably be expected to change the vent to a Group 1 vent.
c. The TRE index value, flow rate, or organic HAP concentration shall be recalculated based on measurements of
vent stream flow rate, TOC, and organic HAP concentrations, and heating values as specified in 40 CFR
63.115 (a), (b),(c), and (d), as applicable, or on best engineering assessment of the effects of the change.
Engineering assessments shall meet the specifications in 40 CFR 63.115(d)(1).
Monitoring and Recordkeeping [15A NCAC 02Q .0508(f)]
d. The Permittee shall maintain records of measurements, engineering assessments, and calculations performed to
determine the TRE index value of the vent stream. Documentation of engineering assessments shall include all
data, assumptions, and procedures used for the engineering assessments, as specified in 40 CFR 63.115(d)(1).
[40 CFR 63.117(b)]
e. The Permittee shall keep up to date, readily accessible records of:
i. Any process changes including, but are not limited to, changes in production capacity, production rate,
feedstock type, or catalyst type, or whenever there is replacement, removal, or addition of recovery
equipment. Process changes do not include: process upsets; unintentional, temporary process changes;
and changes that are within the range on which the original TRE calculation was based; and
ii. Any recalculation of the TRE index value performed in accordance with 40 CFR 63.115(e).
[40 CFR 63.118(c)]
f. The Permittee shall conduct and maintain records required pursuant to applicable Section 2.2 "Multiple Emissions
Source" requirements (e.g., maintenance wastewater).
g. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the monitoring and
recordkeeping requirements in 2.1.F.1.d through f are not met.
Reporting [15A NCAC 02Q .0508(f)]
h. Whenever a process change is made that causes a Group 2 process vent with a TRE greater than 4.0 to become
a Group 2 process vent with a TRE less than 4.0, the Permittee shall submit a report within 180 calendar days
after the process change. The report may be submitted as part of the next periodic report. The report shall
include:
i. A description of the process change,
ii. The results of the recalculation of the TRE index value, and
iii. A statement that the Permittee will comply with the requirements specified in 40 CFR 63.113(d).
[40 CFR 63.118(h)]
i. The Permittee shall submit reports required pursuant to applicable Section 2.2 "Multiple Emissions Source"
requirements (e.g., maintenance wastewater).
2. 15A NCAC 02D .1111, MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
G, Group 2 Storage Vessel Requirements
a. For the Group 2 storage tanks only as delineated above, the Permittee shall maintain readily accessible records
showing the dimensions of the storage vessel and an analysis showing the capacity of the storage vessel. These
records shall be kept as long as the storage vessels Group 2 status and are in operation. [40 CFR 63.119(a)(3)]
b. No other record keeping or reporting is required other than that required pursuant to applicable Section 2.2
"Multiple Emissions Source" requirements (e.g., maintenance waste water).
c. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the recordkeeping requirements
in Sections 2.1.F.2.a and b are not met.
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3. 15A NCAC 02D .1111, MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – – 40 CFR Part 63,
Subpart G, Group 2 Transfer Rack Requirements
For the Group 2 transfer racks only as delineated above, the Permittee shall record, update annually, and maintain the
following information in a readily accessible location on site. [40 CFR 63.126(c), 40 CFR 63.130(f)]
a. An analysis demonstrating the design and actual annual throughput of the transfer rack;
b. Documentation of the weight-percent organic HAP’s in the liquid loaded (e.g., analyses of the material and
engineering calculations);
c. An analysis documenting the annual rack weighted average HAP partial pressure of the transfer rack.
i. Documentation is required of the organic HAP’s (by compound) that are transferred for Group 2 transfer
racks that are limited to the transfer of organic HAP’s with partial pressures less than 10.3 kilopascals. The
rack weighted average partial pressure does not need to be calculated.
ii. A rack weighted partial pressure shall be documented for racks transferring one or more organic HAP’s
with partial pressures greater than 10.3 kilopascals, as well as one or more organic HAP’s with partial
pressures less than 10.3 kilopascals. The rack weighted average HAP partial pressure shall be weighted by
the annual throughput of each chemical transferred.
d. No other record keeping or reporting is required other than that required pursuant to applicable Section 2.2
"Multiple Emissions Source" requirements (e.g., maintenance waste water).
e. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the monitoring and
recordkeeping requirements in Sections 2.1.F.3.a through d are not met.
4. 15A NCAC 02D .1111, MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63, Subpart
G, Group 2 Wastewater Requirements
The Permittee shall keep in a readily accessible location and made available to the DAQ on request the records
specified below [40 CFR 63.147(b)(8)].
a. Each process unit identification and description.
b. Each stream identification code.
c. The concentration of 40 CFR 63, Subpart G - Table 9 compound(s) in parts per million, by weight and
documentation of the methodology used to determine concentration.
d. Each flow rate in liter per minute.
e. No other recordkeeping or reporting is required other than that required pursuant to applicable Section 2.2
"Multiple Emissions Source" requirements (e.g., maintenance wastewater).
f. The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the recordkeeping requirements
in Sections 2.1.F.4.a through e are not met.
G. Resin Production
Aggregate Batch Vent Stream (ID No. CVS3) consisting of
o three reactors (ID Nos. BR2, BR3, and BR4) with wet scrubbers (ID Nos. CD200A and
CD200B)
o three distillate receiving tanks (ID Nos. BR2DRT, BR3DRT, and BR4DRT) with wet
scrubbers (ID Nos. CD200A and CD200B) on:
o a weigh tank (ID No. FWTBR2) with wet scrubbers (ID Nos. CD200A and CD200B)
Non-Reactor Batch Process Vent Stream (NRBPV1) consisting of
o RTU mix tank with filter (ID No. ES103) with particulate separator (ID No. CD-
104PS) and wet scrubber (ID No. CD-104S)
Three dry materials storage silos/weigh hopper (ID No. ES-RTUDM) with fabric filter (ID
No. CD-RTUDC1)
Two phenol tanks (ID Nos. PT1 and PT2)
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30 resin/resin wash water storage tanks (ID Nos. RTF11 through RTF40)
Resin/resin wash water/diethylene glycol / defoamer/catalyst storage tank (ID No. RTF9)
Two liquid ring vacuum seal water tanks (ID Nos. VST2/3 and VST4) vented to scrubbers
(ID Nos. CD200A and CD200B) or to atmosphere when scrubbers (ID Nos. CD200A and
CD200B) are not in operation
RTU wash water/resin storage tank (ID No. ES-103WW)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
PM Particulate emissions shall not exceed the rate prescribed by
the process weight equation for process rates up to 30 tons
per hour:
E = 4.10 x P 0.67
Where: E = allowable emission rate in pounds per hour and
P = process weight in tons per hour
(ID Nos. NRBPV1 and ES-RTUDM only)
15A NCAC 02D .0515
Visible emissions Visible emissions shall not exceed 20 percent opacity
(ID Nos. NRBPV1 and ES-RTUDM only)
15A NCAC 02D .0521
HAP Reduce HAP emissions by 83 percent or to less than or equal
to 50 ppmv, whichever is less stringent.
(ID No. CVS3 only)
Reduce HAP emissions by 62 percent or to less than or equal
to 50 ppmv.
(ID No. NRBPV1 only)
15 A NCAC 02D .1111
40 CFR 63, Subpart OOO
HAP Closed Vent System Equipment and Operating Requirements
[40 CFR 63.983]
(See Section 2.2 A.2. Multiple Emission Sources)
(ID Nos. CVS3 and NRBPV1 only)
15 A NCAC 02D .1111
40 CFR 63, Subpart
OOO/SS
VOC
VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
(Excluding ID No. ES-RTUDM)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
(Excluding ID No. ES-RTUDM)
15A NCAC 02D .0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
(Excluding ID No. ES-RTUDM)
15A NCAC 02D .1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
(Excluding ID No. ES-RTUDM)
15A NCAC 02D .1100
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1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from the non-reactor batch process vent stream (ID No. NRBPV1) and the storage
silos/weigh hopper (ID No. ES-RTUDM) shall not exceed an allowable emission rate as calculated by the
following equation: [15A NCAC 02D .0515(a)]
E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 G.1.a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0515.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the RTU mix tank (ID No. ES103) shall be controlled by a particle separator
(ID No. CD-104PS) and a wet scrubber (ID No. CD-104S). No monitoring or recordkeeping is necessary to
ensure compliance with 15A NCAC 02D .0515 from this emission source.
d. Particulate matter emissions from the storage silos/weigh hopper (ID No. ES-RTUDM) shall be controlled by a
fabric filter (ID No. CD-RTUDC1). To assure compliance, the Permittee shall perform inspections and
maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and
maintenance recommendations, or if there are no manufacturer’s inspection and maintenance
recommendations, as a minimum, the inspection and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and baghouse for leaks and structural integrity;
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and baghouse
are not inspected and maintained.
e. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-
site and made available to an authorized representative upon request. The logbook shall record the following
for ductwork and the baghouse:
i. the date and time of each recorded action;
ii. the results of each inspection; and
iii. the results of any maintenance performed on the baghouse.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
f. The Permittee shall submit the results of any maintenance performed on each control device within 30 days of a
written request by the DAQ.
g. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from the non-reactor batch process vent stream (ID No. NRBPV1) and the storage silos/weigh
hopper (ID No. ES-RTUDM) shall not be more than 20 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent
opacity. [15A NCAC 02D .0521(d)]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 G.2.a. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To assure compliance, each month the Permittee shall observe the emission point of the sources, listed above,
during source operation for any visible emissions above normal. The monthly observation must be made for
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each month of the calendar year period to ensure compliance with this requirement. If visible emissions from
this source are observed to be above normal, the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 G.2.a.above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be
made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
3. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart OOO, NESHAP for Manufacture of Amino/Phenolic Resins
a. For aggregate vent system (ID No. CVS3), the Permittee shall reduce organic HAP emissions by 83 weight
percent or to a concentration of less than or equal to 50 ppmv, whichever is less stringent, on a continuous
basis. [40 CFR 63.1408(a)(2)(ii)]
b. For the non-reactor batch process vent stream (ID No. NRBPV1), the Permittee shall reduce organic HAP
emissions by 62 weight percent using a control device or control technology or to a concentration of less than
or equal to 50 ppmv using a non-combustion control device. [40 CFR 63.1407(a)(3)(ii) or (b)(1)]
c. The Permittee shall operate each pressure relief device in organic HAP gas or vapor service with an instrument
reading of less than 500 ppm above background as described in Method 21 of 40 CFR part 60, Appendix A,
except during a pressure release vent. [40 CFR 63.1411(a))]
d. The emission limitations shall apply at all times except during periods of non-operation of the affected source
(or specific portion thereof) resulting in cessation of emissions to which this subpart applies. [40 CFR
63.1400(k)(1)]
e. The Permittee shall not shut down a control device used for compliance with this subpart during times when
emissions are being routed to the control device if the shutdown would contravene requirements of this subpart
applicable to the control device. [40 CFR 63.1400(k)(3)]
f. At all times, the Permittee shall operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control
practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to
make any further efforts to reduce emissions if levels required by the applicable standard have been achieved.
Determination of whether a source is operating in compliance with operation and maintenance requirements
will be based on information available to the Director, which may include, but is not limited to, monitoring
results, review of operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source. [40 CFR 63.1400(k)(4)]
g. The daily average pH of scrubbing medium shall not exceed 4.9 at the sulfuric acid scrubber (ID No. CD200B)
effluent. The daily average liquid to gas ratio at the once through water scrubber (ID No. CD200A) shall not
be less than 0.0049 gallons per standard cubic feet (0.0049 gpm/scfm). [40 CFR 63.1413(a)(4)] The Permittee
shall be deemed in noncompliance with 15A NCAC 02D .1111 if an exceedance of the maximum daily pH or
minimum daily liquid to gas ratio occurs.
h. The scrubbing medium entering scrubber (ID No. CD-104S) shall be once-through municipal drinking water
with a liquid to gas ratio not be less than 0.042 gallons per standard cubic feet (0.042 gpm/scfm). [40 CFR
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Page 39
63.1413(a)(4)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the liquid to
gas ratio falls below the minimum value or if another scrubbing medium is used.
i. A deviation from the emission standard occurs if monitoring data for scrubbers (ID Nos. CD200A and
CD200B) is insufficient to establish a valid hour of data for at least 75 percent of the operating hours when the
period of control device operation is four hours or greater in an operating day and monitoring does not include
a valid hour of data for at least 75 percent of the operating hours; or when the period of control device
operation is less than four hours in an operating day and more than one of the hours during the period of
operation does not constitute a valid hour of data. Measured values must be available for all of the 15-minute
periods within the hour for the data to be considered valid. [40 CFR 63.1413(h)(4)]
Testing [15A NCAC 02Q .0508(f)]
j. The Permittee has demonstrated compliance with the emission reduction standard of Section 2.1 G.3.a for the
aggregate vent system (ID No. CVS3) through performance testing, completed June 27 and 28, 2006 and
approved January 30, 2008. If additional testing is required, the Permittee shall demonstrate compliance with the
emission reduction standard or concentration standard of Section 2.1 G.3.a. or b. using emission source testing
performed at the maximum representative operating conditions achievable. [40 CFR 63.1413(a)(2)(ii)]
Monitoring [15A NCAC 02Q .0508(f)]
k. The Permittee has demonstrated that potential organic HAP emissions from non-reactor batch process vent
stream (ID No. NRBPV1), prior to control, are less than one ton per year. In accordance with a monitoring
procedure approved December 16, 2009, the Permittee shall demonstrate the scrubber (ID No. CD-104S) is
working as designed during each batch operation. The Permittee shall monitor the liquid injection rate for
scrubber (ID No. CD-104S) either continuously or once during each batch processed in RTU mix tank with
filter (ID No. ES103). [CFR 63.1415(a)(2)] The Permittee shall be deemed in noncompliance with 15A
NCAC 02D .1111 if the liquid injection rate is not monitored as required.
l. The Permittee shall install the monitoring equipment specified below in order to demonstrate compliance with
the provisions of Section 2.1 G.3.a, b, g and h listed above. All monitoring equipment shall be installed,
calibrated, maintained, and operated according to manufacturer’s specifications or other written procedures
that provide adequate assurance that the equipment would reasonably be expected to monitor accurately. [40
CFR 63.1415(a) and (b)]
i. A pH monitoring device equipped with a continuous recorder to monitor the pH of the scrubbing medium
effluent for scrubber (ID No.CD200B).
ii. A flow measurement device equipped with a continuous recorder to monitor the liquid injection rate for
scrubber (ID No. CD200A).
iii. A flow measurement device to monitor the liquid injection rate for scrubber (ID No. CD-104S).
When emissions are vented to scrubbers (ID Nos. CD200A and CD200B), the pH and flow monitoring
devices associated with these scrubbers shall be in operation at all times. The Permittee shall be deemed in
noncompliance with 15A NCAC 02D .1111 if the pH and flow monitoring devices are not properly installed,
calibrated, maintained, or operated or if they are not operated when emissions are vented to the scrubbers.
m. The Permittee shall prepare and implement a gas stream flow determination plan that documents an appropriate
method that will be used to determine the gas stream flow to or through scrubbers (ID No. CD200A) and
scrubber (ID No. CD-104S). The plan shall require determination of gas stream flow by a method which will
at least provide a value for either a representative or the highest gas stream flow anticipated in each scrubber
during representative operating conditions other than start-ups, shutdowns, or malfunctions. The plan shall
include a description of the methodology to be followed and an explanation of how the selected methodology
will reliably determine the gas stream flow, and a description of the records that will be maintained to
document the determination of gas stream flow. The Permittee shall maintain the plan for at least five years.
[40 CFR 63.1415(b)(1)(ii)(C)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111
if the gas stream flow monitoring plan is not prepared, implemented or maintained.
n. The periods listed below are not considered to be part of the period of control device operation for purposes of
determining averages or periods of control device operation or control technology operations. [40 CFR
63.1413(i)(6)]
i. monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level
adjustments, and
ii. periods of non-operation of the emissions units, resulting in cessation of the emissions to which the
monitoring applies.
o. For pressure relief devices in organic HAP gas or vapor service, the Permittee shall comply with the following
paragraphs, as applicable.
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i. If the pressure relief device does not consist of or include a rupture disk, conduct instrument monitoring,
as described in Method 21 of 40 CFR part 60, appendix A, no later than 5 calendar days after the pressure
relief device returns to organic HAP service following a pressure release to verify that the pressure relief
device is operating with an instrument reading of less than 500 ppm above background, except as provided
in 40 CFR 63.1024(d).
ii. If the pressure relief device consists of or includes a rupture disk, install a replacement disk as soon as
practicable after a pressure release, but no later than 5 calendar days after the pressure release, except as
provided in 40 CFR 63.1024(d).
[40 CFR 63.1411(b)(2)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if these requirements are not
met.
p. Beginning October 9, 2017, emissions of organic HAP to the atmosphere from pressure relief devices in
organic HAP service are prohibited, and the Permittee shall comply with the requirements specified in the
following paragraphs for all pressure relief devices in organic HAP service.
i. The Permittee shall equip each pressure relief device in organic HAP service with a device(s) or parameter
monitoring system that is capable of:
A) Identifying the pressure release;
B) Recording the time and duration of each pressure release; and
C) Notifying operators immediately that a pressure release is occurring. The device or monitoring system
may be either specific to the pressure relief device itself or may be associated with the process system
or piping sufficient to indicate a pressure release to the atmosphere. Examples of these types of
devices and systems include, but are not limited to, a rupture disk indicator, magnetic sensor, motion
detector on the pressure relief valve stem, flow monitor, or pressure monitor.
ii. If any pressure relief device in organic HAP service releases to atmosphere as a result of a pressure release
event, the Permittee shall calculate the quantity of organic HAP released during each pressure release
event and report this quantity as required in 40 CFR 63.1417(f)(13)(iii) as specified in Section 2.1.G.3.bb
below. Calculations may be based on data from the pressure relief device monitoring alone or in
combination with process parameter monitoring data and process knowledge.
[40 CFR 63.1411(c)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if these requirements are not
met.
Recordkeeping [15A NCAC 02Q .0508(f) and 40 CFR 63.1416]
q. The Permittee shall keep copies of all applicable records and reports for at least five years. Records shall be
maintained in such a manner that they can be readily accessed. The most recent six months of records shall be
retained on site or shall be accessible from a central location by computer or other means that provides access
within two hours after a request. The remaining four and one-half years of records may be retained offsite.
Records may be maintained in hard copy or computer readable form including, but not limited to, on paper,
microfilm, computer, floppy disk, CD–ROM, optical disc, magnetic tape, or microfiche. [40 CFR 63.1416(a)]
r. The Permittee shall keep monitoring records as follows [40 CFR 63.1416(c)]:
i. Record either each measured data value or average values for one hour or shorter periods calculated from
all measured data values during each period. If values are measured more frequently than once per minute,
a single value for each minute may be used to calculate the hourly (or shorter period) average instead of all
measured values.
ii. Calculate and record the daily average value of each continuously monitored parameter for each operating
day. The calculated daily average shall cover a 24-hour period if operation is continuous or the number of
hours of operation per operating day if operation is not continuous. The operating day shall be from
midnight to midnight. [40 CFR 63.1416(c)(2)(i) and (ii) and 40 CFR 63.1402] The Permittee may record
“within the established limits” rather than calculate and record the daily average for a monitoring
parameter if all hourly average values for that parameter for that operating day are within the applicable
limit listed in 2.1.G.3.f above. [40 CFR 63.1416(c)(3)]:
iii. Record the time and duration of all periods when a monitoring device in not operating during a process
and/or control device operation. Include the following information: [40 CFR 63.1416(c)(4)]
(A) monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level
adjustments, and
(B) periods of non-operation of the affected source (or portion thereof) resulting in cessation of the
emissions to which the monitoring applies.
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Page 41
When choosing to monitor the performance of scrubber (ID No. CD-104S) on a once per batch basis, the
Permittee is exempt from the recordkeeping requirements associated with scrubber (ID No. CD-104S) listed
above in Section 2.1.G.3.p.i through iii. [40 CFR 63.1416(d)(3) and (e)(3) and 40 CFR 63.1415(a)(2)]
s. The Permittee shall maintain documentation showing the establishment of the maximum or minimum scrubber
pH, and minimum liquid to gas ratio that indicates proper operation of the control devices. Monitored
parameter documentation shall include the parameter monitoring data used to establish these levels (i.e., source
test data). [40 CFR 63.1416(d)(2) and (e)(2)]
t. The Permittee shall keep readily accessible continuous records of scrubber pH, scrubbing medium flow rate,
and air flow to scrubbers (ID Nos. CD200A and CD200B) and either continuous or per batch monitoring
records of the liquid injection rate, air flow rate, and time of measurement for scrubber (ID No. CD-104S).
u. The Permittee shall keep records documenting the completion of calibration checks and records documenting
the maintenance of continuous monitoring systems that are specified in the manufacturer’s instructions or that
are specified in other written procedures that provide adequate assurance that the equipment would reasonably
be expected to monitor accurately. [40 CFR 63.1416(g)(1)]
v. The Permittee shall keep records required pursuant to applicable Section 2.2 "Multiple Emissions Source"
requirements.
w. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the recordkeeping in Sections
2.1.G.3.q through v is not conducted or maintained.
Reporting [15A NCAC 02Q .0508(f) and 40 CFR 63.1417]
x. In addition to the reports and notifications required by 40 CFR Part 63, Subpart A as specified in Table 1 of 40
CFR Part 63, Subpart OOO, the Permittee shall prepare and submit the reports, listed in Sections 2.1 G.3.x and
y, as applicable. All reports required by this subpart and the submittal schedule are listed in Table 5 of 40 CFR
Part 63, Subpart OOO.
y. The Permittee is required to meet the reporting requirements unless the Permittee can demonstrate that failure
to submit information required to be included in a specified report was due to the following circumstances:
i. The information was not known in time for inclusion in the report specified herein,
ii. The Permittee has been diligent in obtaining the information, and
iii. The Permittee submits a follow up report if expressly required by this permit or DAQ.
In any other case not addressed above, the Permittee shall submit the information with the first periodic report
which has a submission deadline at least 60 days after the information is obtained.
[40 CFR 63.1417(b)]
z. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified. If none of the compliance exceptions specified below
occurred during the 6-month period, the periodic report shall be a statement that the affected source was in
compliance for the preceding 6-month period and no deviations occurred during the preceding 6-month period.
Periodic reports shall include the following [40 CFR 63.1417(f)]:
i. The reporting period dates, the total source operating time for the reporting period.
ii. Periodic reports shall include the daily average values of monitored parameters for each day when the
daily average value is outside the permitted value, or the data availability requirements are not met (i.e.,
deviation). The duration of periods when monitoring data were not collected shall be specified for
deviation caused by lack of monitoring data. An excursion means any of the following cases:
(A) When the daily average value of one or more monitored parameters is outside the permitted range.
(B) When the period of control or recovery device operation is four hours or greater in an operating day
and monitoring data are insufficient to constitute a valid hour of data for at least 75 percent of the
operating hours.
(C) When the period of control or recovery device operation is less than four hours in an operating day
and more than one of the hours during the period of operation does not constitute a valid hour of data
due to insufficient monitoring data.
(D) Monitoring data are insufficient to constitute a valid hour of data if measured values are unavailable
for any of the 15-minute periods within the hour.
[40 CFR 63.1417(f)(3)(ii) and 40 CFR 63.1413(h)(4)]
iii. When once per batch monitoring is conducted for scrubber (ID No. CD-104S), periodic reports shall
include the monitored parameter for each batch when the measure value is outside the permitted value.
aa. If the Permittee fails to meet an applicable standard, the Permittee shall report such events in the Periodic
Report. The Permittee shall report the number of failures to meet an applicable standard. For each failure the
report must include a list of the affected sources or equipment, an estimate of the quantity of each regulated
Permit 03387T44
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pollutant emitted over any emission limit, and a description of the method used to estimate the emissions. [40
CFR 63.1417(g)]
bb. Beginning October 9, 2017, the Permittee shall include the following information in the periodic reports
i. For pressure relief devices in organic HAP service subject to 40 CFR 63.1411, report confirmation that all
monitoring to show compliance was conducted within the reporting period.
ii. For pressure relief devices in organic HAP gas or vapor service subject to 40 CFR 63.1411(b), report any
instrument reading of 500 ppm above background or greater, more than 5 days after the relief device
returns to organic HAP gas or vapor service after a pressure release.
iii. For pressure relief devices in organic HAP service subject to 40 CFR 63.1411(c), report each pressure
release to the atmosphere, including the following information:
(A) The source, nature, and cause of the pressure release.
(B) The date, time, and duration of the pressure release.
(C) An estimate of the quantity of total HAP emitted during the pressure release and the method used for
determining this quantity.
(D) The actions taken to prevent this pressure release.
(E) The measures adopted to prevent future such pressure releases.
cc. Within 60 days after the date of completing each performance test (as defined in 40 CFR 63.2), the Permittee
must submit the results of the performance tests, including any associated fuel analyses, as specified below:
i. For data collected using test methods supported by the EPA-provided software, the Permittee shall submit
the results of the performance test to the EPA by direct computer-to-computer electronic transfer via EPA-
provided software, unless otherwise approved by the Administrator. Owners or operators, who claim that
some of the information being submitted for performance tests is confidential business information (CBI),
must submit a complete file using EPA-provided software that includes information claimed to be CBI on
a compact disc, flash drive, or other commonly used electronic storage media to the EPA. The electronic
media must be clearly marked as CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention:
WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 27703. The same file with the
CBI omitted must be submitted to the EPA by direct computer-to-computer electronic transfer via EPA-
provided software.
ii. For any performance test conducted using test methods that are not compatible with the EPA-provided
software, the Permittee shall submit the results of the performance test to the Administrator at the
appropriate address listed in 40 CFR 60.4.
H. Process Equipment Subject to Equipment Leak Provisions under 40 CFR Part 63, Subpart
OOO/UU
Resin Production Process Area - Pumps, agitators, pressure relief devices, open-ended valves
or lines, valves, connectors, instrumentation systems, compressors, and sampling connection
systems in organic HAP service (ID No. BREQLK)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAPs Equipment Leak Provisions 15A NCAC 02D .1111
40 CFR 63, Subpart OOO/UU
VOC
PSD AVOIDANCE
VOC emissions shall not exceed 100 tons per
consecutive 12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 2 D.1100
Permit 03387T44
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1. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart OOO, NESHAP for Manufacture of Amino/Phenolic Resins
Equipment Leak Provisions [40 CFR 63.1410]
a. In accordance with 40 CFR 63.1410, the Permittee shall comply with the requirements of 40 CFR Part 63,
Subpart UU for all equipment, as defined under 40 CFR 63.1402, that contains or contacts five weight-percent
HAP or greater and operates 300 hours per year or more except 40 CFR 63.1030. The weight-percent HAP is
determined for equipment using the organic HAP concentration measurement methods specified in 40 CFR
63.1414(a).
b. Beginning October 8, 2014, the emission limitations set forth in 40 CFR part 63, subpart UU, as referred to in
40 CFR 63.1410, shall apply at all times except during periods of non-operation of the affected source (or
specific portion thereof) in which the lines are drained and depressurized resulting in cessation of the emissions
to which 40 CFR 63.1410 applies.
2. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Equipment Identification [40 CFR 63.1022]
a. The Permittee shall identify affected equipment. Identification of the equipment does not require physical
tagging of the equipment and may be identified on a plant site plan, in log entries, by designation of process
unit or affected facility boundaries by some form of weatherproof identification, or by other appropriate
methods.
b. In addition to the identification required above, the Permittee shall specifically identify all affected equipment
as follows:
i. Affected connectors (Except for inaccessible, ceramic, or ceramic-lined connectors and affected
instrumentation systems. Connectors need not be individually identified if all connectors in a designated
area or length of pipe subject to the provisions of this subpart are identified as a group, and the number of
connectors subject is indicated.);
ii. Affected pressure relief devices equipped with rupture disks;
iii. Affected instrumentation systems (Individual components in an instrumentation system need not be
identified.); and
iv. Equipment in regulated material service less than 300 hours per calendar year. (The identity, either by list,
location area or group, or other method, of equipment in regulated material service less than 300 hours per
calendar year within an affected process unit or affected facilities shall be recorded.)
c. The Permittee shall record the identity of equipment designated as difficult-to-monitor, the planned schedule
for monitoring this equipment, and an explanation why the equipment is unsafe or difficult-to-monitor. This
record must be kept at the plant and be available for review by an inspector.
i. Valves, pumps, connectors, and agitators may be designated unsafe-to-monitor if the Permittee determines
that monitoring personnel would be exposed to an immediate danger as a consequence of complying with
monitoring requirements. Examples of unsafe-to-monitor equipment include, but are not limited to,
equipment under extreme pressure or heat. The Permittee shall record the identity of equipment designated
as unsafe-to monitor and the planned schedule for monitoring this equipment.
ii. Valves and agitators may be designated difficult-to-monitor if the Permittee determines that the valve
and/or agitator cannot be monitored without elevating the monitoring personnel more than two meters
(seven feet) above a support surface or it is not accessible in a safe manner when it is in regulated material
service.
iii. The Permittee shall have a written plan that requires monitoring of the equipment designated as unsafe-to-
monitor as frequently as practical during safe-to-monitor times, but not more frequently than the periodic
monitoring schedule otherwise applicable, and repair of the equipment if a leak is detected.
iv. The Permittee shall have a written plan that requires monitoring of the equipment designated as difficult-
to-monitor at least once per calendar year and repair of the equipment if a leak is detected.
d. The Permittee may designate affected connectors as unsafe-to-repair if it is determined that repair personnel
would be exposed to an immediate danger as a consequence of complying with repair requirements, and if the
connector will be repaired before the end of the next process unit or affected facility shutdown. The Permittee
shall identity and record the connectors designated as unsafe-to-repair and an explanation why each connector
is unsafe-to-repair.
e. The Permittee shall identify the compressors that are designated as operating with an instrument reading of less
than 500 parts per million above background, under the provisions of Section 2.1 H.12.d.
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f. The Permittee shall comply with the following requirements for equipment determined to be in heavy liquid
service
i. Retain information, data, and analyses used to determine that a piece of equipment is in heavy liquid
service.
ii. Demonstrate that the piece of equipment or process is in heavy liquid service when requested by DAQ.
iii. A determination or demonstration that a piece of equipment or process is in heavy liquid service shall
include an analysis or demonstration that the process fluids do not meet the definition of ‘‘in light liquid
service.’’ Examples of information that could document this include, but are not limited to, records of
chemicals purchased for the process, analyses of process stream composition, engineering calculations, or
process knowledge.
g. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.2 a through f are not met.
3. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Instrument and Sensory Monitoring for Leaks [40 CFR 63.1023]
a. The Permittee shall perform instrument and/or sensory monitoring for leaks from affected equipment as
addressed in each applicable permit provision:
b. Instrument monitoring shall comply with the following requirements:
i. Monitoring shall comply with Method 21 of 40 CFR Part 60, Appendix A, except as otherwise provided.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR Part 60, Appendix
A, except the instrument response factor criteria inspection 3.1.2, paragraph (a) of Method 21 shall be for
the representative composition of the process fluid not each individual VOC in the stream. For process
streams that contain nitrogen, air, water or other inert material that are not HAP or VOC, the
representative stream response factor shall be determined on an inert-free basis. The response factor may
be determined at any concentration for which monitoring for leaks will be conducted. However, if there is
no instrument commercially available that will meet this performance criterion, the instrument readings
may be adjusted by multiplying by the representative response factor of the process fluid, calculated on an
inert-free basis.
iii. The detection instrument shall be calibrated before use on each day of its use by the procedures specified
in Method 21 of 40 CFR Part 60, Appendix A.
iv. Calibration gases shall be zero air (less than 10 parts per million of hydrocarbon in air) and mixtures of
methane in air at a concentration no more than 2,000 parts per million greater than the leak definition
concentration of the equipment monitored. If the monitoring instrument’s design allows for multiple
calibration scales, then the lower scale shall be calibrated with a calibration gas that is no higher than
2,000 parts per million above the concentration specified as a leak, and the highest scale shall be calibrated
with a calibration gas that is approximately equal to 10,000 parts per million. If only one scale on an
instrument will be used during monitoring, the Permittee need not calibrate the scales that will not be used
during that day’s monitoring. However, a calibration gas other than methane in air may be used (e.g., a
mixture of one or more of the compounds to be measured in air) if the instrument does not respond to
methane or if the instrument does not meet the performance criteria specified above.
v. Monitoring shall be performed when the equipment is in regulated material service or is in use with any
other detectable material.
[40 CFR 63.1023(b)]
c. The Permittee may elect to adjust or not to adjust the instrument readings for background. If the Permittee
elects not to adjust instrument readings for background, all instrument readings shall be compared directly to
the applicable leak definition for the monitored equipment to determine whether there is a leak, or to determine
compliance with the pressure relief device compliance standard (less than 500 ppmv). If the Permittee elects to
adjust instrument readings for background, the Permittee shall monitor the equipment according to the
following procedures in addition to those provided above in Section 2.1 H.3.b..
i. The background level shall be determined, using the procedures in Method 21 of 40 CFR Part 60,
Appendix A.
ii. The instrument probe shall be traversed around all potential leak interfaces as close to the interface as
possible as described in Method 21 of 40 CFR Part 60, Appendix A.
iii. The arithmetic difference between the maximum concentration indicated by the instrument and the
background level shall be compared to the applicable leak definition for the monitored equipment to
determine whether there is a leak, or to determine compliance with the pressure relief device compliance
standard (less than 500 ppmv).
Permit 03387T44
Page 45
d. Sensory monitoring consists of visual, audible, olfactory, or any other detection method used to determine a
potential leak to the atmosphere.
e. The Permittee shall attach a weatherproof and readily visible identification to the leaking equipment for each
leak that is detected and generate leak repair records in accordance with applicable permit provisions to be
maintained for five years.
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.3 a through e are not met.
4. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Leak Repair [40 CFR 63.1024]
a. The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar days after it is
detected, except as provided for in delay of repair provisions and provisions for unsafe to repair connectors. A
first attempt at repair shall be made no later than five calendar days after the leak is detected. First attempt at
repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring that the seal
flush is operating at design pressure and temperature. First attempt at repair for valves includes, but is not
limited to, tightening the bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the packing gland
nuts, and/or injecting lubricant into the lubricated packing.
b. A leak identification on a valve in gas/vapor or light liquid service may be removed after it has been monitored
and no leak has been detected during that monitoring. The leak identification on a connector in gas/vapor or
light liquid service may be removed after it has been monitored and no leak has been detected during that
monitoring. The identification that has been placed on all other equipment determined to have a leak may be
removed after it is repaired.
c. The Permittee shall maintain a record of the facts that explain any delay of repairs and, where appropriate, why
the repair was technically infeasible without a process unit shutdown. Delay of repair is allowed for any of the
conditions specified in i. through v. as follows:
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days after a
leak is detected is technically infeasible without a process unit or affected facility shutdown. Repair of this
equipment shall occur as soon as practical, but no later than the end of the next process unit or affected
facility shutdown, except as provided for valves in v.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is isolated
from the process and that does not remain in regulated material service.
iii. Delay of repair for valves, connectors, and agitators is also allowed if the Permittee determines that
emissions of purged material [after the purged material is collected and disposed of in accordance with 40
CFR 63.1024(d)(3)(ii)] resulting from immediate repair would be greater than the fugitive emissions likely
to result from delay of repair
iv. Delay of repair for pumps is also allowed if repair is completed as soon as practical, but not later than six
months after the leak was detected, and
(A) Repair requires replacing the existing seal design with a new system that the Permittee has determined
will provide better performance pursuant to a quality improvement program [40 CFR 63.1035(d)], or
(B) A approved dual mechanical seal system that meets the requirements of 40 CFR 63.1026(e)(1) will be
installed;
(C) A pump with no externally actuated shaft penetrating the pump housing will be installed; or
(D) A system that routes emissions to a process or a fuel gas system or a closed vent system and control
device that meets the requirements of 40 CFR 63.1034 will be installed.
v. Delay of repair beyond a process unit or affected facility shutdown will be allowed for a valve if valve
assembly replacement is necessary during the process unit or affected facility shutdown, and valve
assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before
the supplies were depleted. Delay of repair beyond the second process unit or affected facility shutdown
will not be allowed unless the third process unit or affected facility shutdown occurs sooner than six
months after the first process unit or affected facility shutdown.
d. Any connector that is designated as an unsafe-to repair connector is exempt from leak repair requirements.
e. The following information shall be recorded and maintained for each leak detected:
i. The date of first attempt to repair the leak.
ii. The date of successful repair of the leak.
iii. Maximum instrument reading measured by Method 21 of 40 CFR Part 60, Appendix A at the time the leak
is successfully repaired or determined to be nonrepairable.
Permit 03387T44
Page 46
iv. ‘‘Repair delayed’’ and the reason for the delay if a leak is not repaired within 15 calendar days after
discovery of the leak as specified below in (A) and (B).
(A) The Permittee may develop a written procedure that identifies the conditions that justify a delay of
repair. In such cases, reasons for delay of repair may be documented by citing the relevant sections of
the written procedure.
(B) If delay of repair was caused by depletion of stocked parts, there must be documentation that the spare
parts were sufficiently stocked on-site before depletion and the reason for depletion.
v. Dates of process unit or affected facility shutdowns that occur while the equipment is unrepaired.
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.4 a through e are not met.
5. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Valves in Gas and Vapor Service and in Light Liquid Service [40 CFR 63.1025]
a. The Permittee shall monitor all valves to detect leaks using the instrument monitoring method specified in
Section 2.1 H.3. The instrument reading that defines a leak is 500 parts per million or greater. The Permittee
shall monitor each valve in regulated material service for leaks once each quarter, in accordance with 40 CFR
63.1025(e)(3) for affected facilities with fewer than 250 valves in regulated material service. [40 CFR
63.1025(b) and 40 CFR 63.1025(e)(3)]
b. The Permittee has subdivided the valves in the applicable group of affected process units and shall apply the
provisions of Section 2.1 H.5.a. (above) to each subgroup and the following provisions (i. through viii.) apply.
[40 CFR 63.1025b(4)]
i. The overall performance of total valves in the applicable group of process units to be subdivided shall be
less than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as follows.
(A) The Permittee shall determine which valves are assigned to each subgroup. Valves with less than one
year of monitoring data or valves not monitored within the last twelve months must be placed initially
into the most frequently monitored subgroup until at least one year of monitoring data have been
obtained.
(B) Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a more
frequently monitored subgroup provided that the valves to be reassigned were monitored during the
most recent monitoring period for the less frequently monitored subgroup. The monitoring results
must be included with that less frequently monitored subgroup’s associated percent leaking valves
calculation for that monitoring event.
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to a less
frequently monitored subgroup provided that the valves to be reassigned have not leaked for the
period of the less frequently monitored subgroup (e.g., for the last 12 months, if the valve or group of
valves is to be reassigned to a subgroup being monitored annually). Nonrepairable valves may not be
reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves (i.e., semiannual
performance calculation) in the applicable group of process units is less than two percent leaking valves
and so indicate the performance in the next Periodic Report. If the overall performance of total valves in
the applicable group of process units is two percent leaking valves or greater, the Permittee shall no longer
subgroup and shall revert to the program requirement for total valves as prescribed in Section 2.1 H.5.a.
for that applicable group of process units. The Permittee can again elect to comply with the valve
subgrouping procedures if future overall performance of total valves in the group of process units is again
less than two percent. The overall performance of total valves in the applicable group of process units shall
be calculated as a weighted average of the percent leaking valves of each subgroup according to the
following equation:
n n
%VLO = ∑(%VLi x Vi)/∑Vi
i=1 i=1
where:
%VLO = Overall performance of total valves in the applicable group of process units
%VLi = Percent leaking valves in subgroup i, most recent value calculated according to the procedures in
Section 2.1 H.5.c.i..
Permit 03387T44
Page 47
Vi = Number of valves in subgroup i.
n = Number of subgroups.
iv. The Permittee shall maintain the following records as specified in (A) through (D) below:
(A) Which valves are assigned to each subgroup,
(B) Monitoring results and calculations made for each subgroup for each monitoring period,
(C) Which valves are reassigned, the last monitoring result prior to reassignment, and when they were
reassigned, and
(D) The results of the semiannual overall performance calculation as specified in Section 2.1.H.5.b.iii,
above.
[40 CFR 63.1025(b)(4)(iv)]
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next monitoring
period of the decision to subgroup valves. The notification shall identify the participating process units and
the number of valves assigned to each subgroup, if applicable, and may be included in the next Periodic
Report.
vi. The Permittee shall submit in the periodic reports the following information:
(A) Total number of valves in each subgroup, and
(B) Results of the semiannual overall performance calculation as specified in Section 2.1.H.5.b.iii, above.
[40 CFR 63.1025(b)(4)(vi)]
vii. Except for the overall performance calculations as specified in Sections 2.1.H.5.b.i and iii above, each
subgroup shall be treated as if it were a process unit for the purposes of applying the provisions of this
section.
c. The Permittee has decided to calculate percent leaking valves on a subgroup/single process unit basis (i.e.,
Reactor 2, Reactor 3, and Reactor 4 area). All percentage calculations shall be made on the same basis and this
shall be the basis used for comparison with the subgrouping criteria specified in Section 2.1 H.5.b.i. [40 CFR
63.1025(c)]
i. The percent leaking valves for each monitoring period for each subgroup/single process unit shall be
calculated using the following equation:
%VL = (VL/VT) x 100
where:
%VL = Percent leaking valves.
VL = Number of valves found leaking, excluding nonrepairable valves specified in Section
2.1.H.5.c.ii below and including those valves monitored and found to be leaking after
repair.
VT = The sum of the total number of valves monitored.
ii. Nonrepairable valves that exceed one percent of the total number of valves in regulated material service at each
subgroup/single process unit shall be included in the calculation of percent leaking valves the first time the
valve is identified as leaking and nonrepairable. Otherwise, the number of nonrepairable valves (identified and
included in the percent leaking valves calculation in a previous period) up to a maximum of one percent of the
total number of valves in regulated material service may be excluded from calculation of percent leaking
valves for subsequent monitoring periods. [40 CFR 63.1025(c)(3)]
d. The Permittee shall implement the following procedures for leak repairs: [40 CFR 63.1025(d)]
i. If a leak is determined, including those that are unsafe or difficult to monitor, then the leak shall be
repaired using the procedures in Section 2.1 H.4., as applicable.
ii. After a leak has been repaired, the valve shall be monitored at least once within the first three months after
its repair. The monitoring required by this paragraph is in addition to the monitoring required to satisfy
the definition of repaired and first attempt at repair.
(A) The monitoring shall be conducted using instrument monitoring method, specified in Section 2.1 H.3.,
to determine whether the valve has resumed leaking.
(B) Periodic monitoring required by Section 2.1 H.5.a (above) may be used to satisfy the requirements of
this paragraph, if the timing of the monitoring period coincides with the time specified in this
paragraph. Alternatively, other monitoring may be performed to satisfy the requirements of this
paragraph, regardless of whether the timing of the monitoring period for periodic monitoring
coincides with the time specified in this paragraph.
iii. If a leak is detected by monitoring that is conducted after valve repair, the valve must be counted as a
leaking valve (VL in Section 2.1 H.5.c.i.) in the semiannual determination of total leaking valves unless
monitoring prior to this determination shows the valve not to be leaking.
Permit 03387T44
Page 48
e. Any valve that is designated as unsafe-to-monitor shall be monitored according to the written plan specified in
Section 2.1 H.2.c.iii.. [40 CFR 63.1025(e)(1)]
f. Any valve that is designated as difficult to monitor shall monitored according to the written plan specified in
Section 2.1 H.2.c.iv. [40 CFR 63.1025(e)(2)]
g. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.5 a through f are not met.
6. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Pumps in Light Liquid Service [40 CFR 63.1026]
a. Affected pumps shall be monitored monthly to detect leaks using the instrument monitoring method, specified
in Section 2.1 H.3.. The instrument reading that defines a leak is:
i. 5,000 parts per million or greater for pumps handling polymerizing monomers; and
ii. 1,000 parts per million or greater for all other pumps. For pumps to which a 1,000 parts per million leak
definition applies, repair is not required unless an instrument reading of 2,000 parts per million or greater
is detected.
[40 CFR 63.1026(b)]
b. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping from
the pump seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection, the Permittee shall monitor the pump using the instrument monitoring method, specified in
Section2.1 H.3., and the leak repaired in accordance with Section 2.1 H.4; or the Permittee shall eliminate
the visual indications of liquids dripping. [40 CFR 63.1026(c)]
c. Any pump that is designated as unsafe-to-monitor shall be monitored according to the written plan specified in
Section 2.1 H.2.c.iii . [40 CFR 63.1026(e)(6)]
d. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.6 a through c are not met.
7. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Connectors in Gas and Vapor Service and Light Liquid Service [40 CFR 63.1027]
a. Except as allowed for connectors that are unsafe to monitor, inaccessible, ceramic, and/or ceramic lined, the
Permittee shall monitor all connectors in gas and vapor and light liquid service to detect leaks by the
instrument monitoring method, specified in Section 2.1 H.3.. The required monitoring frequency shall be
determined from the following criteria using the monitoring results from the preceding or initial monitoring
period. [40 CFR 63.1027(b)]
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then monitor
within 12 months (one year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but less than
0.5 percent, then monitor within four years. The Permittee may monitor at least 40 percent of the
connectors within two years of the start of the monitoring period, provided all connectors have been
monitored by the end of the four year monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent, then the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period and
(A) If the percent leaking connectors calculated from the monitoring results of 50 percent of the
connectors is greater than or equal to 0.35 percent of the total process unit connectors that are required
to be monitored, the Permittee shall monitor as soon as practical, but within the next six months, all
connectors that have not yet been monitored during the monitoring period. At the conclusion of
monitoring, a new monitoring period shall be started based on the percent leaking connectors of the
total monitored connectors.
OR
(B) If the percent leaking connectors calculated from the monitoring results of 50 percent of the total
process unit connectors is less than 0.35 percent of the total process unit connectors that are required
to be monitored, the Permittee shall monitor all connectors that have not yet been monitored within
eight years of the start of the monitoring period.
iv. The Permittee shall keep a record of the start date and end date of each monitoring period for each process
unit.
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b. A leak is detected if an instrument reading greater than or equal to 500 parts per million is measured. If a
connector is found to be leaking during the required monitoring, the Permittee shall re-monitored it once within
90 days after repair (Section 2.1 H.4.) to confirm that it is not leaking.[40 CFR 63.1027(b)(iv)]
c. For use in determining the monitoring frequency, the percent leaking connectors shall be calculated by using
the following equation.
%CL = CL/Ct x100
Where:
%CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
Ct = Total number of monitored connectors in the process unit.
d. Any connector that is designated as an unsafe-to-monitor connector shall be monitored according to the written
plan specified in Section 2.1 H.2.c.iii. [40 CFR 63.1027(e)(1)]
e. Any connector that is inaccessible or that is ceramic or ceramic-lined (e.g., porcelain, glass, or glass-lined), is
exempt from the monitoring requirements, from the leak repair requirements, and from the recordkeeping and
reporting requirements. However, if any inaccessible, ceramic or ceramic-lined connector is observed by
visual, audible, olfactory, or other means to be leaking, the visual, audible, olfactory, or other indications of a
leak to the atmosphere shall be eliminated as soon as practical. An inaccessible connector is one that meets
any of the following six provisions:
i. Buried;
ii. Insulated in a manner that prevents access to the connector by a monitor probe;
iii. Obstructed by equipment or piping that prevents access to the connector by a monitor probe;
iv. Unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold that would allow access to
connectors up to 7.6 meters (25 feet) above the ground;
v. Inaccessible because it would require elevating the monitoring personnel more than two meters (seven
feet) above a permanent support surface or would require the erection of scaffold; and/or
vii. Not able to be accessed at any time in a safe manner to perform monitoring. [Unsafe access includes, but
is not limited to, the use of a wheeled scissor-lift on unstable or uneven terrain, the use of a motorized
man-lift basket in areas where an ignition potential exists, or access would require near proximity to
hazards such as electrical lines, or would risk damage to equipment.]
[40 CFR 63.1027(e)(2)]
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.7 a through e are not met.
8. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Agitators in Gas and Vapor Service and Light Liquid Service [40 CFR 63.1028]
a. Each agitator seal shall be monitored monthly to detect leaks using the instrument monitoring method,
specified in Section2.1 H.3. A leak is detected if an instrument reading equivalent of 10,000 parts per million
or greater is measured. [40 CFR 63.1028(c)(1) and (2)]
b. Each agitator seal shall be checked by visual inspection each calendar week for indications of liquids dripping
from the agitator seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the agitator seal, the Permittee shall monitor the
agitator seal using the instrument monitoring method, specified in Section 2.1 H.3., to determine if the leak of
regulated material registers an instrument reading of 10,000 parts per million or greater (i.e., a leak). If a leak
is detected, the Permittee shall repair the leak in accordance with Section 2.1 H.4., or eliminate the indications
of liquids dripping from the agitator seal. [40 CFR 63.1028(c)(3) and 40 CFR 63.1028(d)]
c. Any agitator seal that is designated as a difficult-to-monitor agitator seal is exempt from the above monitoring
requirements and shall be monitored according to the written plan as specified in Section 2.1 H.2.c.iv. [40 CFR
63.1028(e)(5)]
d. Any agitator seal that is obstructed by equipment or piping that prevents access to the agitator by a monitor
probe is exempt from the above monitoring requirements. [40 CFR 63.1028(e)(6)]
e. Any agitator seal that is designated as an unsafe-to-monitor agitator seal is exempt from the above monitoring
requirements and shall be monitored according to the written plan specified in Section 2.1 H.2.c.iii. [40 CFR
63.1028(e)(7)]
f. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.8 a through e are not met.
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9. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Pumps, Valves, Connectors, and Agitators in Heavy Liquid Service, Pressure Relief Devices in Liquid
Service, and Instrumentation Systems [40 CFR 63.1029]
a. Pumps, valves, connectors, and agitators in heavy liquid service; pressure relief devices in light liquid or heavy
liquid service; and instrumentation systems shall be monitored within five calendar days by the instrument
monitoring method, specified in Section 2.1 H.3., if evidence of a potential leak to the atmosphere is found by
visual, audible, olfactory, or any other detection method. However, if the visual, audible, olfactory, or other
indications of a leak to the atmosphere have been eliminated before five days has elapsed such that no bubbles
are observed at potential leak sites during a leak check using soap solution; or that the system will hold a test
pressure, then instrumentation monitoring is not required.
b. If an instrument reading of 10,000 parts per million or greater for agitators, 5,000 parts per million or greater
for pumps handling polymerizing monomers, 2,000 parts per million or greater for all other pumps, or 500
parts per million or greater for valves, connectors, instrumentation systems, and pressure relief devices is
measured, a leak is detected. The Permittee shall repair the leak pursuant to Section 2.1 H.4, as applicable.
c. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.9 a and b are not met.
10. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Pressure Relief Devices in Gas and Vapor Service [40 CFR 63.1030]
a. Except during pressure releases, each pressure relief device in gas and vapor service shall be operated with an
instrument reading of less than 500 parts per million as measured by the instrumentation monitoring method
specified Section 2.1 H.3.
b. After each pressure release, the pressure relief device shall be returned to a condition indicated by an
instrument reading of less than 500 parts per million and monitored, as soon as practical, but no later than five
calendar days after each pressure release, except as provided for delay of repair provisions. The Permittee
shall record the dates and results of the post repair monitoring following a pressure release including the
background level measured and the maximum instrument reading measured during the monitoring.
c. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.10 a and b are not met.
11. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Open-Ended Valves or Lines [40 CFR 63.1033]
a. Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as
provided for emergency shutdown and for handling of certain materials, as specified in Section 2.1.H.11.a.i
and ii. below, respectively. The cap, blind flange, plug, or second valve shall seal the open end at all times
except during operations requiring process fluid flow through the open-ended valve or line, or during
maintenance.
i. Open-ended valves or lines in an emergency shutdown system that are designed to open automatically in
the event of a process upset are exempt.
ii. Open-ended valves or lines containing materials that would autocatalytically polymerize or, would present
an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and
bleed system are exempt.
[40 CFR 63.1033(b)(1), 40 CFR 63.1033(c), and 40 CFR 63.1033(d)]
b. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve
on the process fluid end is closed before the second valve is closed. [40 CFR 63.1033(b)(2)]
c. When a double block and bleed system is being used, the bleed valve or line may remain open during
operations that require venting the line between the block valves but shall at all other times be sealed. [40 CFR
63.1033(b)(3)]
d. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.11 a through c are not met.
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12. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Compressors standards [40 CFR 63.1031]
a. Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents
leakage of process fluid to the atmosphere, except as provided in Section 2.1.H.12.d. below. Each compressor
seal system shall meet the following requirements.
i. Operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure at all
times except during periods of non-operation of the affected source (or specific portion thereof) in which
the lines are drained and depressurized resulting in cessation of the emissions to which 40 CFR 63.1410
applies; or
ii. Equipped with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device; or
iii. Equipped with a closed-loop system that purges the barrier fluid directly into a process stream.
b. The barrier fluid shall not be in light liquid service. Each barrier fluid system shall be equipped with a sensor
that will detect failure of the seal system, barrier fluid system, or both. Each sensor shall be observed daily or
shall be equipped with an alarm unless the compressor is located within the boundary of an unmanned plant
site.
c. The Permittee shall determine, based on design considerations and operating experience, a criterion that
indicates failure of the seal system, the barrier fluid system, or both. If the sensor indicates failure of the seal
system, the barrier fluid system, or both based on the criterion, a leak is detected and shall be repaired. The
Permittee shall keep records of the design criteria and an explanation of the design criteria; and any changes to
these criteria and the reasons for the changes.
d. Any compressor that is designated as operating with an instrument reading of less than 500 parts per million
above background shall operate at all times with an instrument reading of less than 500 parts per million. A
compressor so designated is exempt from the requirements of Sections 2.1 H.12. a. through c. above if the
compressor is demonstrated, initially upon designation, annually, and at other times requested by the DAQ to
be operating with an instrument reading of less than 500 parts per million above background. The Permittee
shall record the dates and results of each compliance test including the background level measured and the
maximum instrument reading measured during each compliance test. [40 CFR 63.1031(f)]
e. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.12 a through d are not met.
13. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Sampling connection systems standards [40 CFR 63.1032]
a. Each sampling connection system shall be equipped with a closed-purge, closed loop, or closed vent system,
except as provided for in-situ sampling systems. Gases displaced during filling of the sample container are not
required to be collected or captured.
b. Each closed-purge, closed-loop, or closed vent system shall:
i. Return the purged process fluid directly to a process line or to a fuel gas system; or
ii. Be designed and operated to capture and transport all the purged process fluid to a control device; or
iii. Collect, store, and transport the purged process fluid to a system or facility that is:
(A) A waste management unit as defined in 40 CFR 63.111 or Subpart G, if the waste management unit is
subject to and operating in compliance with the provisions of 40 CFR Part 63, Subpart G, applicable
to group 1 wastewater streams. If the purged process fluid does not contain any regulated material
listed in Table 9 of 40 CFR Part 63, Subpart G, the waste management unit need not be subject to, and
operated in compliance with the requirements of 40 CFR Part 63, Subpart G, applicable to Group 1
wastewater steams provided the facility has a National Pollution Discharge Elimination System
(NPDES) permit or sends the wastewater to an NPDES-permitted facility.
(B) A treatment, storage, or disposal facility subject to regulation under 40 CFR Parts 262, 264, 265, or
266; or
(C) A facility permitted, licensed, or registered by a State to manage municipal or industrial solid waste, if
the process fluids are not hazardous waste as defined in 40 CFR Part 261.
c. Containers that are part of a closed purge system must be covered or closed when not being filled or emptied.
d. In-situ sampling systems and sampling systems without purges are exempt from the above requirements
Sections 2.1.H. 13.a. and b.
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e. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.13 a through c are not met.
14. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Record Keeping Requirements [40 CFR 63.1038]
a. The Permittee shall maintain the following records pertaining to the requirements of Section 2.1 H.2. for
equipment identification:
i. General and specific equipment identification if the equipment is not physically tagged and the Permittee
is electing to identify affected equipment through written documentation such as a log or other
designation;
ii. A written plan for any equipment that is designated as unsafe or difficult to monitor;
iii. A record of the identity and an explanation for any equipment that is designated as unsafe-to-repair; and
iv. Records associated with the determination that equipment is in heavy liquid service.
b. The Permittee shall maintain the following records pertaining to the requirements of Sections 2.1 H.3 and
H.4.for leak monitoring:
i. Records for leaking equipment as specified in 2.1.H.3.e;
ii. Records for leak repair as specified in Section 2.1.H.4.e; and
iii. Records for delay of repair as specified in Section 2.1.H.4.c.
[40 CFR 63.1038(b)(6) and (7)]
c. The Permittee shall maintain valve sub grouping records according to the requirements of Section 2.1 H.5.for
valves in gas, vapor, and/or light liquid service. [40 CFR 63.1038(c)(1)]
d. The Permittee shall maintain the records documenting pump visual inspections according to the requirements
of Section 2.1 H.6. for pumps in light liquid service. [40 CFR 63.1038(c)(2)]
e. The Permittee shall maintain the records documenting the development of connector monitoring schedules
according to Section 2.1 H.7. for connectors in gas, vapor, and/or light liquid service. [40 CFR 63.1038(c)(3)]
f. The Permittee shall maintain the records of agitator visual seal inspections as required by Section 2.1 H.8. for
agitators in gas, vapor, and/or light liquid service. [40 CFR 63.1038(c)(4)]
g. The Permittee shall maintain the records of the dates and results of monitoring following a pressure release as
required by Section 2.1 H.10. for pressure relief devices in gas and vapor service. [40 CFR 63.1038(c)(5)]
h. The Permittee shall maintain the records for criteria as to failure of the compressor seal system and/or the
barrier fluid system, record the design criteria and explanations and any changes and the reason for the changes
as Required by Section 2.1.H.12.c. [40 CFR 63.1038(c)(6)(i)]
i. The Permittee shall record the dates and results of each compliance test as specified in Section 2.1 H.12.d. for
compressors operating under the alternative compressor standard. [40 CFR 63.1038(c)(6)(ii)]
j. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.H.14 a through i are not met.
15. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart UU, National Emission Standards for Equipment Leaks-Control Level 2 Standards
Reporting Requirements [15A NCAC 02Q .0508(f) and 40 CFR 63.1039(b)]
a. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June.
b Periodic Reports shall include a summary format of equipment type, the number of components for which
leaks were detected, the percent leaking connectors, the total number of components monitored, and the
number of leaking components that were not repaired as required by Section 2.1 H.4. for:
i. Valves in gas and vapor service and in light liquid service pursuant to Section 2.1 H. 5.;
ii. Pumps in light liquid service pursuant to Section 2.1 H.6.;
iii. Connectors in gas and vapor service and in light liquid service pursuant to Section 2.1 H.7.;
iv. Agitators in gas and vapor service and in light liquid service pursuant to Section 2.1 H.8.; and
v. Compressors pursuant to Section 2.1 H.12.
c. The periodic report shall also include the following:
i. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair;
ii. Valve sub grouping information;
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iii. The results of all monitoring to show compliance conducted within the semiannual reporting period for
pressure relief devices in gas and vapor service; and
iv. Any revisions to items reported in an earlier Initial Compliance Status Report if the method of compliance
has changed since the last report.
I. Equipment Subject to 40 CFR Part 63, Subpart G, Group 1 Transfer Operations
Rail car methaform product load out (two loading arms; ID No. RLOAD1)
Rail car formaldehyde product load out (two loading arms; ID No. RLOAD2)
Tank truck formaldehyde mixed product load out (one loading arm; ID No. TLOAD1A)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAP Vapors shall be collected and vented to the formaldehyde
processes at all times
15A NCAC 02D .1111
40 CFR 63, Subpart G
HAP Start Up, Shut Down and Malfunction
(See Section 2.2 A.1. Multiple Emission Sources)
15 A NCAC 02D .1111
40 CFR 63, Subpart A
HAP Leak Inspection Provisions of Vapor Collection and Closed
Vent Systems - 40 CFR 63.148
(See Section 2.2 A.2. Multiple Emission Sources)
15 A NCAC 02D .1111
40 CFR 63, Subpart G
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subpart F
VOC
VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D .0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D .1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 02D .1100
1. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63,
Subpart G, Group 1 Transfer Operation Requirements
a. The Permittee shall equip each group 1 transfer rack with a vapor collection system and route vapors to a
process [40 CFR 63.126(a)].
i. Each vapor collection system (ID No. CSV1) shall be designed and operated to collect the organic
hazardous air pollutants vapors displaced from tank trucks or railcars during loading, and to route the
collected hazardous air pollutants vapors to a formaldehyde process (ID Nos. FORM12, FORM3, or
ES16).
ii. Each vapor collection system shall be designed and operated such that organic HAP vapors collected at
one loading arm will not pass through another loading arm in the rack to the atmosphere.
iii. Whenever organic hazardous air pollutants emissions are vented to a formaldehyde process the process
shall be operating.
b. The Permittee shall route emissions of organic hazardous air pollutants to a process where the organic
hazardous air pollutants in the emissions shall predominantly meet one of, or a combination of, the ends
specified below [40 CFR 63.126(b)(4)]:
i. Emissions are recycled and/or consumed in the same manner as a material that fulfills the same function in
that process;
ii. Emissions are transformed by chemical reaction into materials that are not organic hazardous air
pollutants;
iii. Emissions are incorporated into a product; and/or
iv. Emissions are recovered.
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c. The Permittee shall load organic HAP’s into only tank trucks and railcars which:
i. Have a current certification in accordance with the U. S. Department of Transportation pressure test
requirements of 49 CFR Part 180 for tank trucks and 49 CFR 173.31 for railcars; or
ii. Have been demonstrated to be vapor-tight within the preceding 12 months, as determined by the
procedures specified in Method 27 of 40 CFR60 Appendix A and pressure measurement device which has
a precision of plus or minus 2.5 millimeters of mercury or better and is capable of measuring above the
pressure at which the tank truck or railcar is to be tested for vapor tightness. Vapor-tight means that the
truck or railcar tank will sustain a pressure change of not more than 750 pascals within five minutes after it
is pressurized to a minimum of 4,500 pascals; for each Group 1 transfer rack.
[40 CFR 63.126(e)]
d. The Permittee shall load organic HAP’s to only tank trucks or railcars equipped with vapor collection
equipment that is compatible with the transfer rack’s vapor collection system. [40 CFR 63.126(f)]
e. The Permittee shall load organic HAP’s to only tank trucks or railcars whose collection systems are connected
to the transfer rack’s vapor collection systems. [40 CFR 63.126(g)]
f. The Permittee shall ensure that no pressure-relief device in the transfer rack’s vapor collection system or in the
organic hazardous air pollutants loading equipment of each tank truck or railcar shall begin to open during
loading. Pressure relief devices needed for safety purposes are not subject to this restriction. [40 CFR
63.126(h)]
g. Each valve in the vent system that would divert the vent stream to the atmosphere, either directly or indirectly,
shall be secured in a non-diverting position using a carseal or a lock and key type configuration, or shall be
equipped with a flow indicator. Equipment such as low leg drains, high point bleeds, analyzer vents, open-
ended valves or lines, and pressure relief devices needed for safety purposes are not subject to this requirement.
[40 CFR 63.126(i)]
h. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.I.1.a through g are not met.
Testing [15A NCAC 02Q .0508(f) and 40 CFR 63.128]
i. The Permittee is not required to conduct a performance test to determine emissions reduction when emissions are
recycled to a chemical manufacturing process. [40 CFR 63.128(c)(5)]
j. The Permittee shall inspect the vapor collection system (ID No. CSV1), according to the leak detection and
repair requirements for vapor collection systems of Section 2.2 A.2. unless the system is operated and
maintained under negative pressure. Inspections shall be performed only while a tank truck or railcar is being
loaded. [40 CFR 63.128(e)] The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if
these requirements are not met.
Monitoring [15A NCAC 02Q .0508(f) and 40 CFR 63.127(d)]
k. The Permittee shall comply with Section 2.1 I.1.k.i or ii below for all Group 1 transfer racks using a vent
system that contains by-pass lines that could divert a vent stream flow away from the formaldehyde processes.
Equipment such as low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and pressure
relief valves needed for safety purposes are not subject to this paragraph.
i. Properly install, maintain, and operate a flow indicator that takes a reading at least once every 15 minutes.
Records shall be generated as specified in 40 CFR 63.130(b). The flow indicator shall be installed at the
entrance to any by-pass line that could divert the vent stream away from the formaldehyde process to the
atmosphere; or
ii. Secure the by-pass line valve in the closed position with a car-seal or a lock-and-key type configuration.
l. The Permittee shall visual inspect the seal or closure mechanism at least once every month to ensure that the
valve is maintained in the closed position and the vent stream is not diverted through the by-pass line.
m. If a car-seal has been broken or a valve position changed, the Permittee shall return car-seal or lock-and-key
combination to the secured position as soon as practicable but not later than 15 calendar days after the change
in position is detected
n. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.I.1.k through m are not met.
Recordkeeping [15A NCAC 02Q .0508(f) and 40 CFR 63.129 and 63.130]
o. The Permittee shall keep an up-to-date, readily accessible record that the emission stream is being routed to a
formaldehyde process. [40 CFR 63.129(a)(1) and (a)(8)]
p. The Permittee shall maintain a record describing in detail the vent system used to vent each affected transfer
vent stream to a formaldehyde process. This document shall list all valves and vent pipes that could vent the
stream to the atmosphere, thereby by-passing the control device; identify which valves are secured by car-seals
Permit 03387T44
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or lock-and-key type configurations; and indicate the position (open or closed) of those valves which have car
seals. Equipment leaks such as low leg drains, high point bleeds, analyzer vents, open-ended valves or lines,
and pressure relief valves needed for safety purposes are not subject to this requirement. [40 CFR 63.129(d)]
q. If a vapor collection system containing valves that could divert the emission stream away from the control
device is used, the Permittee shall keep up-to-date, readily accessible records of: [40 CFR 63.130(b)]
i. Hourly records of whether the flow indicator specified under Section 2.1.I.1.k.i. above was operating and
whether a diversion was detected at any time during the hour, as well as records of the times of all periods
when the vent stream is diverted from the control device or the flow indicator is not operating.
ii. Where a seal mechanism is used to comply with Section 2.1.I.1.k.ii. above, hourly records of flow are not
required. In such cases, the Permittee shall record that the monthly visual inspection of the seals or
closure mechanisms has been done, and shall record the occurrence of all periods when the seal
mechanism is broken, the by-pass line valve position has changed, or the key for a lock-and-key type lock
has been checked out, and records of any car-seal that has broken, as listed in Table 7 of 40 CFR Part 63,
Subpart G. [40 CFR 63.127(d)(2) and [40 CFR 63.130(b)(2)]
r. The Permittee shall record that the verification of U.S. Department of Transportation (DOT) tank certification
or Method 27 testing required in Section 2.1 I.1.c. has been performed. Various methods for the record of
verification can be used, such as: a check off on a log sheet; a list of DOT serial numbers or Method 27 data; or
a position description for gate security, showing that the security guard will not allow any trucks on site that do
not have the appropriate documentation. [40 CFR 63.130(e)]
s. The Permittee shall record, update annually, and maintain the information specified below in a readily
accessible location on site.
i. An analysis demonstrating the design and actual annual throughput of the transfer rack;
ii. An analysis documenting the weight-percent organic HAP’s in the liquid loaded. Examples of acceptable
documentation include but are not limited to analyses of the material and engineering calculations.
iii. An analysis documenting the annual rack weighted average HAP partial pressure of the transfer rack. For
racks transferring one or more organic HAP’s with partial pressures greater than 10.3 kilopascals, as well
as one or more organic HAP’s with partial pressures less than 10.3 kilopascals, a rack weighted partial
pressure shall be documented. The rack weighted average HAP partial pressure shall be weighted by the
annual throughput of each chemical transferred.
[40 CFR 63.130(f)]
t. Records required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
u. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.I.1.o through t are not met.
Reporting [15A NCAC 02Q .0508(f) and 40 CFR 63.130]
v. No reporting is required other than that required pursuant to applicable Section 2.2 “Multiple Emissions Source”
requirements (e.g., maintenance waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
J. Equipment Subject to 40 CFR Part 63, Subpart G, Group 1 Storage Vessels
Internal floating roof methanol storage tank (ID No. METH1)
Internal floating roof methanol storage tank (ID No. METH2)
The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant Limits/Standards Applicable Regulation
VOC A Group 1 storage vessel that is also subject to 40 CFR
Part 60, Subpart Kb is required to comply only with 40
CFR Part 63, Subpart G. [40 CFR 63.110(b)]
15A NCAC 02D .0524
40 CFR 60, Subpart Kb
HAP Each tank shall maintain a fixed roof with an internal
floating roof.
15A NCAC 02D .1111
40 CFR 63.119, Subpart G
HAP Maintenance Wastewater Requirements-40 CFR 63.105
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D.1111
40 CFR 63, Subpart F
VOC
PSD AVOIDANCE
VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
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Regulated Pollutant Limits/Standards Applicable Regulation
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 2 D.1100
1. 15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS – 40 CFR Part 60, Subpart Kb,
Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984
a. The Permittee shall comply with the provisions of 40 CFR Part 60, Subpart Kb, in 40 CFR Part 60, Subpart Kb
by complying with 40 CFR Part 63, Subpart G for Group 1 storage vessels as provided in Section 2.1. J.2.
below. [40 CFR 63.110(b)(1)]
2. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart
G, Group 1 Storage Vessel Requirements a. The Permittee shall reduce hazardous air pollutants emissions to the atmosphere by operating and maintaining
a fixed roof and internal floating roof. [40 CFR 63.119(a)(1)]
b. The internal floating roof shall be floating on the liquid surface at all times except when the floating roof must
be supported by the leg supports during the initial fill, after the vessel has been completely emptied and
degassed, or when the vessel is completely emptied before being subsequently refilled. When the floating roof
is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be
accomplished as soon as practical. The intent of this paragraph is to avoid having a vapor space between the
floating roof and the stored liquid for extended periods. Storage vessels may be emptied for purposes such as
routine storage vessel maintenance, inspections, petroleum liquid deliveries, or transfer operations. Storage
vessels where liquid is left on walls, as bottom clingage, or in pools due to floor irregularity are considered
completely empty. [40 CFR 63.119(b)(1) and (b)(2)]
c. Each internal floating roof shall be equipped with a closure device between the wall of the storage vessel and
the roof edge. The closure device shall consist of two seals mounted one above the other so that each forms a
continuous closure that completely covers the space between the wall of the storage vessel and the edge of the
internal floating roof. The lower seal may be vapor-mounted, but both must be continuous seals. [40 CFR
63.119(b)(3)]
d. Automatic bleeder vents are to be closed at all times when the roof is floating, except when the roof is being
floated off or is being landed on the roof leg supports. [40 CFR 63.119(b)(4)]
e. Each internal floating roof shall meet the following specifications.
i. Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker
vents) and rim space vents is to provide a projection below the liquid surface.
ii. Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents,
column wells, ladder wells, sample wells, and stub drains shall be equipped with a cover or lid. The cover
or lid shall be equipped with a gasket.
iii. Each penetration of the internal floating roof for the purposes of sampling shall be a sample well. Each
sample well shall have a slit fabric cover that covers at least 90 percent of the opening.
iv. Each automatic bleeder vent shall be gasketed.
v. Each rim space vent shall be gasketed.
vi. Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed
sliding cover.
vii. Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof
shall have a flexible fabric sleeve seal or a gasketed sliding cover.
[40 CFR 63.119(b)(5)]
f. Each cover or lid on any opening in the internal floating roof shall be closed (i.e., no visible gaps), except
when the cover or lid must be open for access. Covers on each access hatch and each gauge float well shall be
bolted or fastened so as to be air-tight when they are closed. Rim space vents are to be set to open only when
the internal floating roof is not floating or when the pressure beneath the rim seal exceeds the manufacturer’s
recommended setting. [40 CFR 63.119(b)(6)]
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g. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Section
2.1.J.2.a through f are not met.
Compliance Procedures [40 CFR 63.120(a)]
h. The Permittee shall perform one of the following inspection protocols.
i. visually inspect the internal floating roof, the primary seal, the secondary seal, gaskets, slotted membranes,
and sleeve seals (if any) each time the storage vessel is emptied and degassed and at least once every five
years (timeline commencing as of April 22, 1997), or
ii. visually inspect the internal floating roof and the secondary seal through manholes and roof hatches on the
fixed roof at least once every 12 months after initial fill, or at least once every 12 months (timeline
commencing as of April 22, 1997), and visually inspect the internal floating roof, the primary seal, the
secondary seal, gaskets, slotted membranes, and sleeve seals (if any) each time the vessel is emptied and
degassed and at least once every 10 years (timeline commencing as of April 22, 1997).
[40 CFR 63.120(a)(3)]
i. If during the inspections, the internal floating roof is not resting on the surface of the liquid inside the storage
vessel and is not resting on the leg supports; or there is liquid on the floating roof; or the seal is detached; or
there are holes or tears in the seal fabric; or there are visible gaps between the seal and the wall of the storage
vessel, the owner or operator shall repair the items or empty and remove the storage vessel from service within
45 calendar days. If a failure that is detected during inspections cannot be repaired within 45 calendar days and
if the vessel cannot be emptied within 45 calendar days, the Permittee may utilize up to two extensions of up to
30 additional calendar days each. Documentation of a decision to utilize an extension shall include a
description of the failure, shall document that alternate storage capacity is unavailable, and shall specify a
schedule of actions that will ensure that the control equipment will be repaired or the vessel will be emptied as
soon as practical. [40 CFR 63.120(a)(4)]
j. The Permittee shall notify the DAQ in writing at least 30 calendar days prior to the refilling of each storage
vessel to afford the DAQ the opportunity to have an observer present for the inspection. If the inspection is not
planned and the Permittee could not have known about the inspection 30 calendar days in advance of refilling
the vessel, the Permittee shall notify the DAQ at least seven calendar days prior to the refilling of the storage
vessel. Notification may be made by telephone and immediately followed by written documentation
demonstrating why the inspection was unplanned. Alternatively, the notification including the written
documentation may be made in writing and sent so that it is received by the DAQ at least seven calendar days
prior to refilling. [40 CFR 63.120(a)(6)]
k. If the internal floating roof is found to have defects during an inspection; or the primary seal has holes, tears, or
other openings in the seal or the seal fabric; or the secondary seal has holes, tears, or other openings in the seal
or the seal fabric; or the gaskets no longer close off the liquid surface from the atmosphere; or the slotted
membrane has more than 10 percent open area, the Permittee shall repair the items as necessary so that none of
these conditions exist before refilling the storage vessel with organic HAP. . [40 CFR 63.120(a)(7)]
l. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Sections
2.1.J.2.h through k are not met.
Recordkeeping [15A NCAC 02Q .0508(f) and 40 CFR 63.123]
m. The Permittee shall keep readily accessible records showing the dimensions of each storage vessel and an
analysis showing the capacity of the storage vessel. This record shall be kept as long as the storage vessel
retains a Group 1 or Group 2 status and is in operation. [40 CFR 63.123(a)]
n. The Permittee shall keep a record that each required inspection was performed. . [40 CFR 63.123(c)]
o. The Permittee who elects to utilize an inspection extension in emptying a storage vessel in accordance with
Section 2.1.J.2.i shall keep in a readily accessible location a description of the failure, shall document that
alternate storage capacity is unavailable, and shall specify a schedule of actions that will ensure that the control
equipment will be repaired or the vessel will be emptied as soon as practical. [40 CFR 63.123(g)]
p. Records required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
q. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the recordkeeping
requirements in Section 2.1.J.2.m through p are not met.
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Reporting [15A NCAC 02Q .0508(f) and 40 CFR 63.122]
r. The Permittee shall submit a periodic report postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the preceding
six-month period between January and June.
s. The Permittee shall submit the results of each inspection conducted in accordance with Section 2.1.J.2.h. in
which a failure is detected in the control equipment in the periodic report. [40 CFR 63.122(a)(4)]
t. For vessels for which annual inspections are conducted pursuant to Section 2.1.J.2.h.ii. (unless an extension is
provided) each periodic report shall include the date of the inspection, identification of each storage vessel in
which a failure was detected, and a description of the failure. The Periodic Report shall also describe the nature
of and date the repair was made or the date the storage vessel was emptied. A failure is defined as any time in
which the internal floating roof is not resting on the surface of the liquid inside the storage vessel and is not
resting on the leg supports; or there is liquid on the floating roof; or the seal is detached from the internal
floating roof; or there are holes, tears, or other openings in the seal or seal fabric; or there are visible gaps
between the seal and the wall of the storage vessel. [40 CFR 63.122(d)(1)(i) and (d)(1)(ii)]
u. If an extension is utilized, the Permittee shall, in the next periodic report:
i. Identify the vessel;
ii. Provide documentation of the decision to utilize an extension including a description of the failure, proof
that alternate storage capacity was unavailable, and a schedule of actions that ensured that the control
equipment was repaired or the vessel will be emptied as soon as practical; and
iii. Describe the date the storage vessel will be/was emptied and the nature of and date the repair will be/was
made.
[40 CFR 63.122(d)(1)(iii)]
v. For vessels for which inspections are required every five year pursuant to Section 2.1.J.2.h.i., each periodic
report shall include the date of the inspection, identification of each storage vessel in which a failure was
detected, and a description of the failure. The periodic report shall also describe the nature of and date the
repair was made. A failure is defined as any time in which the internal floating roof has defects; or the primary
seal has holes, tears, or other openings in the seal or the seal fabric; or the secondary seal (if one has been
installed) has holes, tears, or other openings in the seal or the seal fabric; or the gaskets no longer close off the
liquid surface from the atmosphere; or the slotted membrane has more than 10 percent open area. [40 CFR
63.122(d)(2)]
w. In order to afford the DAQ the opportunity to have an observer present, the Permittee shall notify the DAQ of
the refilling of a storage vessel that has been emptied and degassed pursuant to Section 2.1.J.2.j. [40 CFR
63.122(h)]
x. Reports required pursuant to applicable Section 2.2 "Multiple Emissions Source" requirements (e.g., maintenance
waste water, start-up/shut-down/malfunction, LDAR for closed vent systems).
K. Other Emission Sources
Other Transfer Operations
Truck load out station for urea formaldehyde resin (ID No. TLOAD6)
Two tank truck urea formaldehyde resin and phenol formaldehyde resin load out stations
(ID Nos. TLOAD1B and TLOAD2B)
Tank truck urea formaldehyde resin and wax load out (ID No. TLOAD3B)
Tank truck phenol formaldehyde resin load out, and receiving for caustic, temulose, beet
molasses, and phenol (ID No. TLOAD4)
Tank truck urea formaldehyde resin and phenol formaldehyde resin load out, and
receiving of aqueous ammonia (ID No. TLOAD5)
Wastewater Treatment Plant (ID No. WWTP)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant Limits/Standards Applicable Regulation
VOC VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
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Regulated Pollutant Limits/Standards Applicable Regulation
VOC Work Practice Standards for Sources of VOC
(See Section 2.2 B.2. Multiple Emission Sources)
15A NCAC 02D.0958
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D.1806
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 2 D.1100
L. Two natural gas/ No. 2 fuel/ No. 4 fuel/ No. 5 fuel oil/ No. 6 fuel-oil fired boilers (ID Nos. ES3
and ES4)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant Limits/Standards Applicable Regulation
PM 0.39 pounds per million Btu heat input 15A NCAC 02D .0503
SO2 Sulfur dioxide emissions shall not exceed 2.3 pounds per
million Btu heat input
15A NCAC 02D .0516
Visible emissions Visible emissions shall not exceed 40 percent opacity. 15A NCAC 02D .0521
Filterable PM
Mercury
Carbon Monoxide
Hazardous Air
Pollutants
(These requirements are applicable until May 19, 2019)
For Nos. 4, 5, & 6 Fuel Oil Firing
0.45 lb/mmBtu
2.0e-05 lb/mmBtu
28 ppmvd at 7% O2
For No. 2 Fuel Oil and Natural Gas Firing
Best Combustion Practices
15A NCAC 02D .1109
Hazardous Air
Pollutants
(These requirements are applicable beginning May 20,
2019.)
40 CFR Part 63 Subpart DDDDD
15A NCAC 02D .1111
SO2
Sulfur dioxide emissions shall not exceed 100 tons per
consecutive 12-month period, rolling monthly total. [This is
a facility wide emission limit. Compliance is based on
boiler emissions from fuel oil as the sole source of SO2
emissions.]
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC VOC emissions shall not exceed100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
1. 15A NCAC 02D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter from the combustion of natural gas, No. 2, No. 4, No. 5, and No. 6 fuel oils that
are discharged from these boilers into the atmosphere shall not exceed 0.39 pounds per million Btu heat input.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 L.1.a above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0503.
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Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of natural gas, No.
2, No. 4, No. 5, and No. 6 fuel oils in these sources.
2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included when
determining compliance with this standard. [15A NCAC 02D .0516]
b. The maximum sulfur content of No. 2, No. 4, No. 5, and No. 6 fuel oil received and burned in the boiler shall
not exceed 2.1 percent by weight. The Permittee shall be deemed in noncompliance with 15A NCAC
02D .0516 if the sulfur content of the fuel oil exceeds this limit. [15A NCAC 02Q .0508(bb)]
Testing [15A NCAC 02Q .0508(f)]
c. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found
in Section 3. If the results of this test are above the limit given in Section 2.1 L.2.a. above, the Permittee shall
be deemed in noncompliance with 15A NCAC 02D .0516.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
d. No monitoring/recordkeeping is required for sulfur dioxide emissions from natural gas or No. 2 fuel oil
combusted in these sources.
e. To assure compliance, the Permittee shall monitor the sulfur content of the No. 4, No. 5, and No. 6 fuel oil by
using fuel oil supplier certification per shipment received. The results of the fuel oil supplier certifications
shall be recorded in a logbook (written or electronic format) on a quarterly basis and include the following
information:
i. The name of the fuel oil supplier;
ii. The maximum sulfur content of the fuel oil received during the quarter;
iii. The method used to determine the maximum sulfur content of the fuel oil; and
iv. A certified statement signed by the responsible official that the records of fuel oil supplier certification
submitted represent all of the No. 4, No. 5, and No. 6 fuel oil fired during the period.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0516 if the sulfur content of the oil is
not monitored and recorded.
Reporting [15A NCAC 02Q .0508(f)]
f. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30
of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers shall not be more than 40 percent opacity when averaged over a six-minute
period. However, six-minute averaging periods may exceed 40 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event shall the six-minute average exceed 90 percent
opacity. [15A NCAC 02D .0521(c)]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the respective limit given in Section 2.1 L.3.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring [15A NCAC 02Q .0508(f)]
c. To assure compliance, once a day the Permittee shall observe the emission points of boilers (ID Nos. ES3 and
ES4) when combusting No. 4, No. 5, or, No. 6 fuel oil for any visible emissions above normal. The daily
observation must be made for each day of the calendar year period to ensure compliance with this requirement.
The Permittee shall be allowed three (3) days of absent observations per semiannual period. If visible
emissions from these sources are observed to be above normal, the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 L.3.a. above.
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If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be
made, the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521.
d. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas or No. 2
fuel oil in these sources.
Recordkeeping [15A NCAC 02Q .0508(f)]
e. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting [15A NCAC 02Q .0508(f)]
f. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
4. 15A NCAC 02Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 02D .0530: PREVENTION OF
SIGNIFICANT DETERIORATION (Sulfur Dioxide)
a. In order to avoid applicability of 15A NCAC 02D .0530(g), the boilers No. 3 and No. 4 (ID Nos. ES3 and
ES4) shall discharge into the atmosphere less than 100 tons of sulfur dioxide per consecutive 12-month period,
rolling monthly total.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition
JJ found in Section 3. If the results of this test are above the limit given in Section 2.1 L.4.a above, the
Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
c. The Permittee shall keep monthly records in a logbook (written or electronic format) of the amount of each
fuel fired and its respective sulfur content. The Permittee shall be deemed in noncompliance with 15A NCAC
02D .0530 if the amount of fuel used and its sulfur content are not monitored.
d. The Permittee shall calculate, each month, the amount of sulfur dioxide emitted based on the amounts of No. 4,
No. 5 and/or No. 6 fuel oil fired in the boilers and US EPA AP-42 emission factors. The Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0530 if the above records are not kept or the sulfur dioxide
emissions exceed the above limit in Section 2.1.L.4.a.
e. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the recordkeeping is not
conducted or maintained or if the sulfur dioxide emissions exceed the limit in Section 2.1 L.4.a above.
Reporting [15A NCAC 02Q .0508(f)]
f. The Permittee shall submit a semiannual summary report postmarked within 30 days after each calendar year
half. The reports are to be post marked on or before January 30 of each calendar year for the preceding six-
month period between July and December, and July 30 for the calendar year for the preceding six-month
period between January and June. The report shall contain the following:
i. The monthly emissions of sulfur dioxide for each of the previous 17 months. The rolling total consecutive
12-month period emissions must be calculated for each of the six months of the calendar half; and
ii. The monthly quantities of each fuel fired in boilers (ID Nos. ES3 and ES4) for each of the17 months.
5. 15A NCAC 02D .1109: CASE-BY-CASE MACT
a. The initial compliance date for the CAA §112(j) emission limitations, work practice standards, and associated
monitoring, recordkeeping, and reporting requirements listed below is January 4, 2014. These conditions
need not be included on the annual compliance certification until after the initial compliance date. These limits
apply except for periods of startup, shutdown, and malfunction. The Permittee shall follow the procedures in
15A NCAC 02D .0535 for any excess emissions that occur during periods of startup, shutdown, or
malfunction.
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b. The Permittee shall comply with this CAA §112(j) standard until May 19, 2019. The initial compliance date
for the applicable CAA §112(d) standard for ‘‘National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers and Process Heaters” is May 20, 2019, as specified in Section
2.1.L.6, below.
c. Emissions from these sources shall not exceed the emissions limitations listed below as a result of firing No. 4,
No. 5, and/or No. 6 fuel oil:
i. Filterable PM: 0.45 lbs/mmBtu
ii. Mercury (Hg): 2.0e-05 lbs/mmBtu
iii. Carbon Monoxide (CO): 28 ppmvd, corrected to 7% oxygen
These emissions shall only apply if the boiler fires at least 10% residual fuel oil (including No. 4 fuel oil) on an
rolling 12-month average heat input basis. If the Permittee fires less than 10% residual fuel oil, these
emissions limitations and the associated compliance testing shall not apply. However, the Permittee shall
retain records of the fuels fired in the boiler in accordance with Section 2.1 L.5.g. of this permit.
Work Practice Standards [15A NCAC 02Q .0508(f)]
d. For emissions from No. 2 fuel oil or natural gas firing at the affected combustion source, the Permittee shall
perform an annual boiler inspection and maintenance as recommended by the manufacturer, or as a minimum,
the inspection and maintenance requirement shall include the following:
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame pattern;
and,
iii. Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning
properly.
The Permittee shall conduct at least one tune-up per calendar year to demonstrate compliance with this
requirement. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if the affected
boilers are not inspected and maintained as required above.
e. The results of any required annual burner inspection and maintenance shall be maintained in a logbook (written
or electronic format) on-site and made available to an authorized representative upon request. The logbook
shall record the following:
i. The date of each recorded action;
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if these records are not
maintained.
Compliance Testing [15A NCAC 02Q .0508(f)]
f. To demonstrate compliance with the standards provided in Section 2.1 L.5.c. above, the Permittee shall
conduct compliance tests for each listed pollutant. The Permittee may chose either of the following methods
for the compliance tests:
i. Initial & Periodic Stack Testing. Stack testing shall be performed in accordance with General Condition
JJ in Section 3 of this permit. Tests may not be conducted during periods of startup, shutdown, or
malfunction. Following the initial compliance test, the Permittee shall test the boiler annually. Each stack
test shall be conducted between 11 and 13 months after the previous stack test. However, if a stack test
shows that the emission rate of any pollutant is less than or equal to 80 percent of the allowable limit, the
stack test frequency shall be reduced to once every five years for that pollutant.
ii. Periodic Fuel Analysis. The Permittee may use a fuel analysis to demonstrate compliance with the
mercury standard. Fuel analyses shall be conducted annually. Following the initial fuel analysis, each
analysis shall be conducted between 11 and 13 months after the previous analysis. If a fuel analysis shows
a potential exceedance of an emission limitation in Section 2.1 L.5.c., the Permittee shall conduct a
follow-up stack test of the affected source within 90 days. If the follow-up stack test shows an exceedance
of the limit, the Permittee shall be deemed in non-compliance with 15A NCAC 02D .1109.
The initial compliance test shall be conducted within 180 days of the initial compliance date. The Permittee
shall be deemed in noncompliance with 15A NCAC 02D .1109 if the required compliance tests are not
conducted, or if the results of a compliance test exceed a limit in Section 2.1 L.5.c.. above.
Recordkeeping [15A NCAC 02Q .0508(f)]
g. If the Permittee limits residual fuel oil (including No. 4 fuel oil) firing to less than 10% on an annual average
heat input basis, it shall create and retain the following records once per calendar month:
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i. Record the fuel use by each affected source, including the type(s) of fuel and amount(s) used, during the
previous calendar month; and,
ii. Calculate the annual average heat input from residual fuel oil for each affected source during the previous
12-month period.
If the annual average heat input is equal to or greater than 10% for any 12-month period, the Permittee shall
conduct an initial compliance test within 60 days following the end of the 12-month period. Monitoring and
recordkeeping requirements associated with residual fuel oil firing shall be implemented as soon as practicable,
and in no case later than 60 days following the end of the 12-month period. The Permittee shall be deemed in
non-compliance with 15A NCAC 02D .1109 if it fails to comply with the recordkeeping requirements.
h. Maintain a copy of each notification and report required by this standard, including all documentation
supporting any Notification of Compliance Status. The Permittee shall be deemed in non-compliance with
15A NCAC 02D .1109 if it fails to comply with the recordkeeping requirements
i. Maintain records of performance tests and fuel analyses. The Permittee shall be deemed in non-compliance
with 15A NCAC 02D .1109 if it fails to comply with the recordkeeping requirements.
Reporting [15A NCAC 02Q .0508(f)]
j. Notification of Compliance Status. The Permittee must submit a Notification of Compliance Status that meets
the requirements of 40 CFR 63.9(h)(2)(ii) before the close of business on the 60th day following the
completion of the final required performance test and/or other initial compliance demonstration. The
Notification of Compliance Status report must contain the following information, as applicable:
i. A description of the affected source(s) including identification of which subcategory the source is in, the
capacity of the source, a description of the add-on controls used on the source description of the fuel(s)
burned, and justification for the fuel(s) burned during the performance test.
ii. Summary of the results of all performance tests and calculations conducted to demonstrate initial
compliance.
iii. A certification signed by the Responsible Official that the facility has met all applicable emission limits
and work practice standards.
k. Semiannual Summary Report. The Permittee shall submit a summary report on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each calendar
year for the preceding six-month period between January and June. The first summary report shall be required
on July 30, 2014. The report shall include the following:
i. Company name and address;
ii. Statement by a responsible official with that official’s name, title, and signature, certifying the truth,
accuracy, and completeness of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. A summary of the results of the annual performance tests;
v. Signed statement indicating that no new types of fuel were fired in the affected sources.
6. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability [40 CFR 63.7485, 40 CFR 63.7490(d), 40 CFR 63.7499(l)]
a. For the boilers (ID Nos. ES3 and ES4) designed to burn gas 1 fuels, the Permittee shall comply with all
applicable provisions, including the monitoring, recordkeeping, and reporting contained in Environmental
Management Commission Standard 15A NCAC 02D .1111 "Maximum Achievable Control Technology"
(MACT) as promulgated in 40 CFR 63, Subpart DDDDD . “National Emission Standards for Hazardous Air
Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters” and
Subpart A “General Provisions.”
b. The Permittee shall be subject to the requirements of this standard starting May 20, 2019.
Definitions and Nomenclature [40 CFR 63.7575]
c. For the purpose of this permit condition, the definitions and nomenclature contained in 40 CFR 63.7575 shall
apply.
d. In order for the boilers (ID Nos. ES3 and ES4) to remain in the units designed to burn gas 1 subcategory, the
Permittee shall only burn liquid fuel for periodic testing of liquid fuel, maintenance, or operator training, not to
exceed a combined total of 48 hours during any calendar year, and during periods of gas curtailment or gas
supply interruptions of any duration. The Permittee shall be deemed in noncompliance with 15A NCAC
02D .1111 if the requirements in this condition are not met.
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40 CFR Part 63 Subpart A General Provisions [40 CFR 63.7565]
e. The Permittee shall comply with the requirements of 40 CFR Part 63 Subpart A General Provisions according
to the applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63, Subpart DDDDD.
Compliance Date [40 CFR 63.7510(e), 40 CFR 63.56(b)]
f. The Permittee shall complete the initial tune up and the one-time energy assessment no later than May 20,
2019.
Notifications [40 CFR 63.7545(e)(8), 40 CFR 63.7530(d),(e),(f)]
g. The Permittee shall submit a Notification of Compliance Status. The notification must be signed by a
responsible official and sent before the close of business on the 60th day following the completion of the initial
tune up and one time energy assessment (whichever is later). The notification shall contain the following:
i. A description of the affected unit(s) including identification of which subcategories the unit is in, the
design heat input capacity of the unit, and description of the fuel(s) burned.
ii. the following certification(s) of compliance, as applicable:
A) “This facility complies with the required initial tune-up according to the procedures in.40 CFR
63.7540(a)(10)(i) through (vi)’ [i.e., Sections 2.1.L.6.j.i. through v. and p.ii.]; and
B) “This facility has had an energy assessment performed according to 40 CFR 63.7530(e)” [ i.e.,
Section 2.1.L.6.o] and is an accurate depiction of the facility at the time of the assessment.
h. The Permittee shall submit a notification of intent to fire an alternative fuel (i.e., fuel oil) within 48 hours of the
declaration of each period of natural gas curtailment or supply interruption. The notification must include the
information in 40 CFR 63.7545(f), as specified below:
i. Company name and address;
ii. Identification of the affected boiler;
iii. Reason the Permittee is unable to use natural gas or equivalent fuel, including the date when the natural
gas curtailment was declared or the natural gas supply interruption began;
iv. The type of alternative fuel the Permittee intends to use; and
v. Dates when the alternative fuel use is expected to begin and end.
[40 CFR 63.7545(f)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the notification of intent to
fire an alternative fuel is not submitted.
General Compliance Requirements [40 CFR 63.7505(a), 40 CFR 63.7500(f)]
i. The Permittee shall be in compliance with the work practice standards in this subpart. These standards apply at
all times the affected unit is operating.
Work Practice Standards [15A NCAC 02Q .0508(f)]
j. The Permittee shall conduct a tune-up of the boiler annually as specified below. The Permittee shall conduct
the tune-up while burning the type of fuel that provided the majority of the heat input to the boiler of the 12
months prior to the tune-up.
i. As applicable, inspect the burner, and clean or replace any components of the burner as necessary. The
Permittee may perform the burner inspection any time prior to the tune-up or delay the burner inspection
until the next scheduled unit shutdown;
ii. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern.
The adjustment should be consistent with the manufacturer's specifications, if available;
iii. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated
and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown);
iv. Optimize total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available, and with any NOX requirement to which the unit is subject; and
v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by volume, and
oxygen in volume percent, before and after the adjustments are made (measurements may be either on a
dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements
may be taken using a portable CO analyzer.
[40 CFR 63.7500(a), (e), 40 CFR 63.7540(a)(10)]
k. Each annual tune-up shall be conducted no more than 13 months after the previous tune-up. [40 CFR
63.7515(d)]
l. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar
days of startup. [40 CFR 63.7540(a)(13), 40 CFR 63.7515(g)]
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m. At all times, the Permittee must operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control
practices for minimizing emissions. Determination of whether such operation and maintenance procedures are
being used will be based on information available to the Administrator that may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and maintenance
records, and inspection of the source. [§63.7500(a)(3)]
n. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements inSections
2.1.L.6.j through m.
Energy Assessment Requirements [15A NCAC 02Q .0508(f)]
o. To demonstrate initial compliance, the Permittee shall also conduct a one-time energy assessment for boilers
(ID Nos. ES3 and ES4) performed by a qualified energy assessor. The energy assessment must be conducted
no later than May 20, 2019. The energy assessment must include the following with extent of the evaluation
appropriate for the 24 on-site technical hours as defined in 40 CFR 63.7575:
i. A visual inspection of the boiler or process heater system.
ii. An evaluation of operating characteristics of the boiler or process heater systems, specifications of energy
using systems, operating and maintenance procedures, and unusual operating constraints.
iii. An inventory of major energy use systems consuming energy from affected boilers and process heaters
and which are under the control of the boiler/process heater owner/operator.
iv. A review of available architectural and engineering plans, facility operation and maintenance procedures
and logs, and fuel usage.
v. A review of the facility's energy management program and provide recommendations for improvements
consistent with the definition of energy management program, if identified.
vi. A list of cost-effective energy conservation measures that are within the facility's control.
vii. A list of the energy savings potential of the energy conservation measures identified.
viii. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements,
benefits, and the time frame for recouping those investments.
ix. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy
assessment requirements in Section 2.1 L.6.o.i through viii., above, satisfies the energy assessment
requirement. If the Permittee operates under an energy management program developed according to the
ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year
between January 1, 2008 and May 20, 2019, that includes the boilers (ID Nos. ES3 and ES4) also satisfies
the energy assessment requirement.
[40 CFR 63.7500(a)(1), Table 3]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if these requirements are not
met.
Recordkeeping Requirements [15A NCAC 02Q .0508(f), 40 CFR 63.7555]
p. The Permittee shall keep the following:
i. A copy of each notification and report submitted to comply with this subpart, including all documentation
supporting any Initial Notification or Notification of Compliance Status, or semiannual compliance report
that has been submitted, according to the requirements in 40 CFR 63.10(b)(2)(xiv).
[40 CFR 63.7555(a)(1)]
ii. Maintain on-site and submit, if requested by the DAQ, a report containing the information in paragraphs
(A) through (C) below:
A) the concentrations of carbon monoxide in the effluent stream in parts per million by volume, and
oxygen in volume percent, measured before and after the adjustments of the source;
B) a description of any corrective actions taken as a part of the combustion adjustment; and
C) the type and amount of fuel used over the 12 months prior to the annual adjustment, but only if the
unit was physically and legally capable of using more than one type of fuel during that period. Units
sharing a fuel meter may estimate the fuel use by each unit.
[40 CFR 63.7540(a)(10)(vi)]
iii. The associated records for Sections 2.1.L.6.i through m. and Section 2.1.L.6.o including:
A) the occurrence and duration of each malfunction of operation (i.e., process equipment) or the required
air pollution control and monitoring equipment.[40 CFR 63.10(b)(2)(ii)]
iv. Records of the calendar date, time, occurrence and duration of each startup and shutdown. [40 CFR
63.7555(i)]
v. Records of the type(s) and amount(s) of fuels used during each startup and shutdown. [40 CFR 63.7555(j)]
vi. The following records, pursuant to 15A NCAC 02Q .0508(f):
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A) types of fuels combusted during periods of gas curtailment, gas supply interruption, periodic testing
maintenance and operator training;
B) date and duration of periods of gas curtailment and gas supply interruption; and
C) date and duration of periods of testing, maintenance and operator training while combusting liquid
fuel.
q. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review;
ii. keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective
action, report, or record; and
iii. keep each record on site for at least 2 years after the date of each occurrence, measurement, maintenance,
corrective action, report, or record. The Permittee can keep the records offsite for the remaining 3 years.
[40 CFR 63.7560, 63.10(b)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if records are not maintained as
described in Sections 2.1.L.6 p and q.
Reporting Requirements [15A NCAC 02Q .0508(f)]
r. The Permittee shall submit compliance reports to the DAQ on an annual basis. The first annual compliance
report shall cover the period beginning on May 20, 2019 and ending on December 31, 2019. Subsequent
annual compliance reports shall cover the periods from January 1 to December 31. The Permittee shall submit
the annual compliance reports postmarked on or before January 30. [40 CFR 63.7550(a), (b), 63.10(a)(4), (5)]
s. The Permittee shall submit the annual compliance report via the CEDRI. (CEDRI can be accessed through the
EPA's Central Data Exchange, CDX.) The Permittee shall use the appropriate electronic report in CEDRI 40
CFR Part 63, Subpart DDDDD. Instead of using the electronic report in CEDRI for this 40 CFR Part 63,
Subpart DDDDD, the Permittee may submit an alternate electronic file consistent with the XML schema listed
on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If
the reporting form specific to 40 CFR Part 63, Subpart DDDDD is not available in CEDRI at the time that the
report is due, the Permittee shall submit the report to DAQ. The Permittee shall begin submitting reports via
CEDRI no later than 90 days after the form becomes available in CEDRI. [40 CFR 63.7550(h)(3)]
t. The compliance report must contain the following information:
i. Company name and address;
ii. Process unit information, emissions limitations, and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. The total operating time during the reporting period;
iv. If there are no deviations from the requirements of the work practice requirements in Section 2.1.L.6.j
above, a statement that there were no deviations from the work practice standards during the reporting
period; and
v. Include the date of the most recent tune-up for each unit required according to Section 2.1.L.6.j. Include
the date of the most recent burner inspection if it was not done as scheduled and was delayed until the next
scheduled or unscheduled unit shutdown.
[40 CFR 63.7550(a) and (c), Table 9]
u. The report must contain a summary of the records required in Section 2.1.L.6.p.vi.
v. If the Permittee has a period of noncompliance with a work practice standard for periods of startup and
shutdown during the reporting period, the compliance report must also contain the following information:
i. A description of the deviation and which emission limit or operating limit from which the Permittee
deviated; and
ii. Information on the number, duration, and cause of deviations (including unknown cause), as applicable,
and the corrective action taken.
[40 CFR 63.7550(a) and (d), 63.7540(b), Table 9]
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M. Temporary,2 back-up boiler (ID No. TB1) with a maximum heat input capacity of less
than 30 million Btu per hour; formaldehyde process tailgas and natural gas-fired.
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter 0.32 pounds per million Btu heat input 15A NCAC 02D .0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
Visible emissions 20 percent opacity 15A NCAC 02D .0521(d)
N/A Monthly recordkeeping requirement, only. 15A NCAC 02D .0524
40 CFR 60, Subpart Dc
HAPs Tail gas shall be used as the primary fuel for any boiler
used to back up the tail gas boilers at the silver catalyst
formaldehyde processes (ID No. FORM12 and
FORM3).
15A NCAC 02D .1111
40 CFR 63, Subpart G
1. 15A NCAC 02D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter from the combustion of tailgas from the formaldehyde process and/or natural
gas from any temporary, back-up boiler (ID No. TB1) shall not exceed 0.32 pounds per million Btu heat input.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 M.1.a above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0503.
Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate matter emissions from the combustion of
tailgas from the formaldehyde process and/or natural gas.
2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from any temporary, back-up boiler (ID No. TB1) shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other
substances shall be included when determining compliance with this standard. [15A NCAC 02D .0516]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. If the results of this test are above the limit given in Section 2.1 M.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the combustion of tailgas
from the formaldehyde process and/or natural gas.
3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from any temporary, back-up boiler (ID No. TB1) shall not be more than 20 percent opacity
when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not
more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity. [15A NCAC 02D .0521(d)]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. If the results of this test are above any limit given in Section 2.1 M.3.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0521.
2 The term “temporary” is descriptive only. The boiler does not meet the definition of a temporary boiler under 40 CFR Part 60,
Subpart Dc.
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Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the combustion of tailgas from the
formaldehyde process and/or natural gas.
4. 15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS – 40 CFR Part 60, Subpart Dc,
Small Industrial-Commercial-Institutional Steam Generating Units
a. For the affected boiler (ID No. TB1), the Permittee shall comply with all applicable provisions, including the
notification, testing, recordkeeping, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 02D .0524 "New Source Performance Standards (NSPS) as promulgated in
40 CFR Part 60, Subpart Dc, including Subpart A "General Provisions."
b. The Permittee shall not operate a temporary, back-up boiler (ID No. TB1) with a maximum heat input capacity
of 30 million Btu per hour or greater.
c. The Permittee is only permitted to fire natural gas and tail gas from the formaldehyde process in the temporary,
back-up boiler (ID No. TB1).
Notifications [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit a written initial notification of the date of actual, initial startup of any NSPS-
affected boiler (ID No. TB1) within 15 days of such date. The notification shall be submitted to the Regional
Supervisor. [40 CFR 60.7(a)(1)]
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
e. In addition to any other recordkeeping required by 40 CFR §60.48c or recordkeeping requirements of the EPA,
the Permittee shall record and maintain records of the amounts of each fuel fired at the affected boiler (ID No.
TB1) during each month. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524 if
these records are not created and maintained.
5. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart
G, National Emission Standards for Organic Hazardous Air Pollutants from the SOCMI for Process Vents,
Storage Vessels, Transfer Operations, and Wastewater
a. If the temporary, back-up boiler (ID No. TB1) is being used to back-up either of the existing tail gas boilers at
the silver catalyst formaldehyde process (ID Nos. FORM12 and FORM3), it shall meet the following
requirements:
i. Tail gas from the formaldehyde process shall be the primary fuel, as defined in 40 CFR 63.111; and,
ii. Tail gas shall be introduced into the flame zone of the back-up boiler.
The Permittee shall be deemed in non-compliance with 15A NCAC 02D .1111 if the back-up boiler does not
comply with these requirements.
b. To demonstrate compliance with this standard, the back-up boiler (ID No. TB1) shall comply with the
requirements of Section 2.1. A.4. of this permit. The Permittee shall be deemed in non-compliance with 15A
NCAC 02D .1111 if the back-up boiler does not comply with these requirements.
N. Wax Emulsion Plant (ID No. WAX)
The following table provides a summary of limits and standards for the emission source(s) describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAP Recordkeeping requirements to demonstrate total HAP
emissions are less than 10,000 lbs/12-month.
15A NCAC 02D .1111
40 CFR 63, Subpart FFFF
HAP Start up, Shut Down and Malfunction
(See Section 2.2 A.1. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subpart A
HAP Maintenance Wastewater Requirements-40 CFR
63.105/Subpart F
(See Section 2.2 A.3. Multiple Emission Sources)
15A NCAC 02D .1111
40 CFR 63, Subparts F and
FFFF
Odor Odor Control
(See Section 2.2 B.3. Multiple Emission Sources)
15A NCAC 02D .1806
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Regulated Pollutant Limits/Standards Applicable Regulation
TAP Toxic Air Pollutants
(See Section 2.2 B.4. Multiple Emission Sources)
15A NCAC 02D .1100
VOC VOC emissions shall not exceed100 tons per consecutive
12-month period, rolling monthly total.
(See Section 2.2 B.1. Multiple Emission Sources)
15A NCAC 02Q .0317
Avoidance of 02D .0530
1. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - 40 CFR 63, Subpart
FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing (MON) a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping,
and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC
02D .1111, "Maximum Achievable Control Technology” as promulgated in 40 CFR 63, Subpart FFFF,
including Subpart A, "General Provisions".
Emission Standards [40 CFR 63.2550, 40 CFR 63.2460(b)(6)]
b. To remain Group 2 batch process vents, the collective uncontrolled organic HAP emissions from batch process
vents in the wax emulsion plant (ID No. WAX) shall be less than 10,000 pounds per year. If the process vents
change from Group 2 to Group 1, the Permittee shall meet the following requirements:
i. If the wax emulsion plant has operated as a Group 2 batch process vent for at least 1 year (i.e., the vent has
shown compliance with the 10,000 lb/yr for at least 365 days), report the switch to a Group 1 batch
process vent in the next semiannual compliance report in accordance with 40 CFR 63.2520(e)(10)(i).
ii. If the wax emulsion plan has not operated as a Group 2 batch process vent for at least 1 year, provide a 60-
day advance notice of the change to a Group 1 batch process vent in accordance with 40 CFR
63.2520(e)(10)(ii).
iii. Submit a test report for the Group 1 batch process vent in the next semiannual compliance report.
Testing [15A NCAC 02Q .0508(f)]
c. If emissions testing is performed in accordance with General Condition JJ and the results do not comply with
the applicable standard(s), the Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The Permittee shall create and maintain record of the following:
i. A record of the amount of HAP material used and calculate the daily rolling annual sum of the amount
used no less frequently than monthly.
ii. If a record indicates usage exceeds 10,000 lb/yr, the Permittee shall estimate emissions for the preceding
12 months based on the number of batches operated and the estimated emissions for a standard batch, and
the Permittee shall begin recordkeeping as specified in 40 CFR 63.2525(e)(4). After 1 year, the Permittee
may revert to recording only usage if the usage during the year is less than 10,000 pounds.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if it fails to create and maintain
the records described above. [40 CFR 63.2525(e)(2)]
e. The Permittee shall retain a record of each operating scenario as follows:
i. A description of the process and the type of process equipment used.
ii. Identification of related process vents, wastewater point of determination (POD), storage tanks, and
transfer racks.
iii. Calculations and engineering analyses required to demonstrate compliance.
iv. Changes to any of the elements listed above which have not been previously reported to the NCDAQ.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if it fails to create and maintain
the records described above. [40 CFR 63.2525(b)]
f. The Permittee shall retain a schedule or log of operating scenarios for the batch operations updated each time a
different operating scenario is put into effect. The Permittee shall be deemed in noncompliance with 15A
NCAC 02D .1111 if it fails to create and maintain a log of the batch operations as described above. [40 CFR
63.2525(c)]
Reporting [15A NCAC 02Q .0508(f)]
g. Advanced Notification of a Process Change. The Permittee shall submit a report 60 days before the scheduled
implementation date of any of the changes identified below:
i. Any change to the information contained in the precompliance report.
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ii. A change in the status of a control device from small to large.
iii. A change from Group 2 to Group 1 for any emission point except for batch process vents that meet the
conditions specified in Section 2.1.N.1.b.i. of this permit.
[40 CFR 63.2520(e)(10)]
h. Semiannual Compliance Report. The Permittee shall submit a semiannual compliance report postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. The periodic
reports shall include the following, as applicable:
i. Company name and address.
ii. Statement by a responsible official with that official's name, title, and signature, certifying the accuracy of
the content of the report.
iii. Date of report and beginning and ending dates of the reporting period.
iv. If uncontrolled HAP emissions exceed the limit 10,000 lbs/yr during any consecutive 365-day period,
include the records associated with the emissions calculations required in Section 2.1.N.1.d. of this permit.
v. Except where advanced notification is required as provided in Section 2.1.N.1.g. of this permit, provide a
notification of any process change, or change to any of the information submitted in the notification of
compliance status report or a previous compliance report that is not within the scope of an existing
operating scenario. A process change does not include moving within a range of conditions identified in
the standard batch, and a nonstandard batch does not constitute a process change. The notification must
include all of the following information:
(A) A description of the process change.
(B) Revisions to any of the information reported in the original notification of compliance status report.
(C) Information required by the notification of compliance status report pursuant to 40 CFR 63.2520(d)
for changes involving the addition of processes or equipment at the affected source.
[40 CFR 63.2520(e)]
O. One Diesel-Fired Emergency Generator; 340 hp (ID No. ES-EG1)
Two Diesel-Fired Fire Water Pumps; 150 hp each (ID Nos. ES-FP1 and ES-FP2)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant Limits/Standards Applicable Regulation
SO2 2.3 pounds per million Btu heat input 15A NCAC 02D .0516
visible emissions 20 percent opacity each 15A NCAC 02D .0521
HAP
Comply with operational limitations and work practices
beginning May 3, 2013.
15A NCAC 02D .1111
40 CFR Part 63, Subpart
ZZZZ
1. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from the emergency engines (ID Nos. ES--EG1, ES-FP1, and ES-FP2) shall not
exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,
wastes, ores, and other substances shall be included when determining compliance with this standard. [15A
NCAC 02D .0516]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found
in Section 3. If the results of this test are above the limit given in Section 2.1 O.1.a above, the Permittee shall
be deemed in noncompliance with 15A NCAC 02D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 02Q .0508(f)]
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from firing diesel fuel.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the emergency engines (ID Nos. ES--EG1, ES-FP1, and ES-FP2) shall not be more
than 20 percent opacity each when averaged over a six-minute period. However, six-minute averaging periods
may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In
no event shall the six-minute average exceed 87 percent opacity. [15A NCAC 02D .0521 (d)]
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Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found
in Section 3. If the results of this test are above the limit provided in Section 2.1.O.2.a above, the Permittee
shall be deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring/Recordkeeping/Reporting c. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of diesel fuel.
3. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability [40 CFR 63.6585, 63.6590(a)(1)(ii)]
a. For these emission source(s) (existing stationary RICE with a site rating of less than or equal to 500 brake HP
located at a major source of HAP emissions), the Permittee shall comply with all applicable provisions,
including the monitoring, recordkeeping, and reporting contained in Environmental Management Commission
Standard 15A NCAC 02D .1111 "Maximum Achievable Control Technology" (MACT) as promulgated in 40
CFR Part 63, Subpart ZZZZ “National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines” and Subpart A “General Provisions.”
Definitions and Nomenclature b. For the purposes of this permit condition, the definitions and nomenclature contained in 40 CFR 63.6675 shall
apply.
Applicability Date [40 CFR 63.6595(a)(1)]
c. The Permittee shall comply with the applicable emission limitations, operating limitations, and other
requirements no later than May 3, 2013.
Notifications [40 CFR 63.6645(a)(5)]
d. The Permittee has no notification requirements.
General Provisions [40 CFR 63.6665]
e. The Permittee shall comply with the General Provisions as applicable pursuant to Table 8 of 40 CFR Part 63,
Subpart ZZZZ
Operating and Maintenance Requirements [15A NCAC 02Q .0508(b)]
f. During periods of startup of the internal combustion (IC) engine, the Permittee shall minimize the engine's
time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe
loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations
apply.[40 CFR 63.6602 and 63.6625(h)]
g. Except during periods of startup of the IC engine, the Permittee shall:
i. Change oil and filter every 500 hours of operation or annually, whichever comes first;
ii. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as
necessary; and
iii. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as
necessary.
[40 CFR 63.6602, Table 2C]
h. The Permittee shall have the option to utilize the oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in condition g. [40 CFR 63.6602, Table 2C, 63.6625(i)]
i. If an emergency engine is operating during an emergency and it is not possible to shut down the engine in
order to perform the management practice requirements on the schedule required in Section 2.1. O.3.g., or if
performing the management practice on the required schedule would otherwise pose an unacceptable risk
under Federal, State, or local law, the management practice can be delayed until the emergency is over or the
unacceptable risk under Federal, State, or local law has abated. The management practice should be performed
as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law
has abated. Sources must report any failure to perform the management practice on the schedule required and
the Federal, State or local law under which the risk was deemed unacceptable. [40 CFR 63.6602, Table 2C]
j. The Permittee shall be in compliance with the emission limitations, operating limitations and other
requirements in this subpart that apply at all times. [40 CFR 63.6605(a)]
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k. The Permittee shall operate and maintain any affected source, including associated air pollution control
equipment and monitoring equipment, in a manner consistent with safety and good air pollution control
practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to
make any further efforts to reduce emissions if levels required by this standard have been achieved.
Determination of whether such operation and maintenance procedures are being used will be based on
information available to the Administrator which may include, but is not limited to, monitoring results, review
of operation and maintenance procedures, review of operation and maintenance records, and inspection of the
source. [40 CFR 63.6605(b)]
l. The Permittee shall operate and maintain the stationary RICE and after-treatment control device (if any)
according to the manufacturer's emission-related written instructions or develop a maintenance plan which
must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions. [40 CFR 63.6625(e) and 63.6640(a), Table
6]
m. In order for the engine to be considered an emergency stationary RICE under this condition, any operation
other than emergency operation, maintenance and testing, emergency demand response, and operation in non-
emergency situations for 50 hours per year, as described in paragraphs (i) through (iii) below, is prohibited.
i. There is no time limit on the use of emergency stationary RICE in emergency situations.
ii. The Permittee may operate the emergency stationary RICE for any combination of the purposes specified
in paragraphs (A) through (C) below for a maximum of 100 hours per calendar year. Any operation for
non-emergency situations as allowed by paragraph (C) below counts as part of the 100 hours per calendar
year allowed by this paragraph ii.
(A) Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided
that the tests are recommended by federal, state or local government, the manufacturer, the vendor,
the regional transmission organization or equivalent balancing authority and transmission operator, or
the insurance company associated with the engine. The owner or operator may petition the
Administrator for approval of additional hours to be used for maintenance checks and readiness
testing, but a petition is not required if the owner or operator maintains records indicating that
federal, state, or local standards require maintenance and testing of emergency RICE beyond 100
hours per calendar year.
(B) Emergency stationary RICE may be operated for emergency demand response for periods in which
the Reliability Coordinator under the North American Electric Reliability Corporation (NERC)
Reliability Standard EOP–002–3, Capacity and Energy Emergencies (incorporated by reference, see
40 CFR 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared
an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP– 002–3.
(C) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or
frequency of 5 percent or greater below standard voltage or frequency.
iii. Emergency stationary RICE located at major sources of HAP may be operated for up to 50 hours per
calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are
counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand
response provided in Section 2.1. O.3.m.ii. The 50 hours per year for non-emergency situations cannot be
used for peak shaving or non-emergency demand response, or to generate income for a facility to supply
power to an electric grid or otherwise supply power as part of a financial arrangement with another entity.
[40 CFR 63.6640(f)]
n. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if Sections 2.1. O.3.e. through m
are not met.
Monitoring [15A NCAC 02Q .0508(f)]
o. The Permittee shall install a non-resettable hour meter on the IC engine if one is not already installed. [40 CFR
63.6625(f)]
Recordkeeping [15A NCAC 02Q .0508(f)]
p. The Permittee shall keep the following:
i. A copy of each notification and report that the Permittee submitted to comply with this subpart, including
all documentation supporting any Initial Notification or Notification of Compliance Status that the
Permittee submitted, according to the requirement in 40 CFR 63.10(b)(2)(xiv).[40 CFR 63.6655(a)(1)]
ii. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the
air pollution control and monitoring equipment. [40 CFR 63.6655(a)(2)]
iii. Records of all required maintenance performed on the air pollution control and monitoring equipment. [40
CFR 63.6655(a)(4)]
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iv. Records of actions taken during periods of malfunction to minimize emissions in accordance with Section
2.1. O.3.k., including corrective actions to restore malfunctioning process and air pollution control and
monitoring equipment to its normal or usual manner of operation. [40 CFR 63.6655(a)(5)]
v. Records of the maintenance conducted on the RICE pursuant to Section 2.1. O.3.l. [40 CFR 63.6655(d)
and (e)]
vi. Records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The
Permittee shall document how many hours are spent for emergency operation, including what classified
the operation as emergency and how many hours are spent for non-emergency operation. If the engine is
used for the purposes specified in Section 2.1.O.3.m.ii.(B) or (C) above, the owner or operator must keep
records of the notification of the emergency situation, and the date, start time, and end time of engine
operation for these purposes.
40 CFR 63.6655(f)]
q. The Permittee shall keep each record in a form suitable and readily accessible in hard copy or electronic form
for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or
record, according to 40 CFR 63.10(b)(1). [40 CFR 63.6660(a), (b), (c)]
r. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if conditions p. and q. are not
met.
Reporting [15A NCAC 02Q .0508(f)]
s. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
noncompliance must be clearly identified. [40 CFR 63.6640(b), (e), and 63.6650(f)]
i. The summary report shall also include any reporting required under Section 2.1. O.3.i., as necessary. [40
CFR 63.6602, Table 2C]
t. If the Permittee owns or operates an emergency stationary RICE with a site rating of more than 100 brake HP
that operates or is contractually obligated to be available for more than 15 hours per calendar year for the
purposes specified in Sections 2.1. O.3.m.ii (B) and (C).above, the Permittee shall submit an annual report
according to the requirements at 40 CFR 63.6650(h). This report must be submitted to the Regional Supervisor
and the EPA. [40 CFR 63.6650(h)]
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2.2- Multiple Emission Sources Specific Limitations and Conditions
A. Affected Facilities Pursuant to 40 CFR 63, Subparts A, F, G, H, OOO/UU/SS and FFFF
The following table provides a summary of limits and standards for the emission source(s) describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
HAP Startup, Shutdown, Malfunction
(Not applicable to emission sources subject to 40 CFR 63
Subparts OOO/UU/SS)
15A NCAC 02D .1111
40 CFR 63, Subpart A
HAP Leak Inspection for vapor collection and closed vent systems
– 40 CFR 63.148/Subpart G and 40 CFR 63.983/Subpart SS
15A NCAC 02D .1111
40 CFR 63, Subparts G
OOO/UU/SS
HAP Maintenance Wastewater Requirements-40 CFR
63.105/Subpart F
15A NCAC 02D.1111
40 CFR 63, Subparts F and
FFFF
1. 15A NCAC 02D .1111 : MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY – 40 CFR Part 63,
Subpart A, General Provisions
Start up, Shut Down and Malfunction Plan [40 CFR 63.6(e)(3)]
a. The Permittee shall develop a written startup, shutdown, and malfunction plan that describes, in detail,
procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction and
a program of corrective action for malfunctioning process and air pollution control equipment used to comply
with the relevant standard. As required pursuant to 40 CFR 63.8(c)(1)(i), the plan shall identify all routine or
otherwise predictable continuous emissions or parametric monitor malfunctions. The purpose of the startup,
shutdown, and malfunction plan is to:
i. Ensure that Permittee is prepared to correct malfunctions as soon as practicable after their occurrence in
order to minimize excess emissions of hazardous air pollutants; and
ii. Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including
corrective action taken to restore malfunctioning process and air pollution control equipment to its normal
or usual manner of operation).
b. When actions taken by the Permittee during a startup or shutdown (and the startup or shutdown causes the
source to exceed any applicable emission limitation in the relevant emission standards), or malfunction
(including actions taken to correct a malfunction) are consistent with the procedures specified in the affected
source's startup, shutdown, and malfunction plan, the Permittee must keep records for that event which
demonstrate that the procedures specified in the plan were followed. In addition, the Permittee must keep
records of these events as specified below in Section 2.2 A.1.b.i. through v. [40 CFR 63.10(b)], including
records of the occurrence and duration of each startup or shutdown (if the startup or shutdown causes the
source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of
operation and each malfunction of the air pollution control and monitoring equipment. Furthermore, the
Permittee shall confirm that actions taken during the relevant reporting period during periods of startup,
shutdown, and malfunction were consistent with the affected source's startup, shutdown and malfunction plan
in the semiannual (or more frequent) startup, shutdown, and malfunction report required in 40 CFR 63.10(d)(5)
and Section 2.1 A.1.h.
i. The occurrence and duration of each startup or shutdown when the startup or shutdown causes the source
to exceed any applicable emission limitation in the relevant emission standards;
ii. The occurrence and duration of each malfunction of operation (i.e., process equipment) or the required air
pollution control and monitoring equipment;
iii. All required maintenance performed on the air pollution control and monitoring equipment;
iv. Actions taken during periods of startup or shutdown when the source exceeded applicable emission
limitations in a relevant standard and when the actions taken are different from the procedures specified in
the affected source's startup, shutdown, and malfunction plan; or Actions taken during periods of
malfunction (including corrective actions to restore malfunctioning process and air pollution control and
monitoring equipment to its normal or usual manner of operation) when the actions taken are different
from the procedures specified in the affected source's startup, shutdown, and malfunction plan;
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v. All information necessary, including actions taken, to demonstrate conformance with the affected source's
startup, shutdown, and malfunction plan when all actions taken during periods of startup or shutdown (and
the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant
emission standards), and malfunction (including corrective actions to restore malfunctioning process and
air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent
with the procedures specified in such plan. (The information needed to demonstrate conformance with the
startup, shutdown, and malfunction plan may be recorded using a “checklist,” or some other effective form
of recordkeeping, in order to minimize the recordkeeping burden for conforming events).
c. If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to
correct a malfunction) is not consistent with the procedures specified in the affected source's startup, shutdown,
and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission
standard, then the Permittee must record the actions taken for that event and must report such actions within 2
working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days
after the end of the event, in accordance with Section 2.2 A.1.h. [40 CFR 63.10(d)(5)] (unless the owner or
operator makes alternative reporting arrangements, in advance, with the DAQ).
d. The Permittee must maintain at the affected source a current startup, shutdown, and malfunction plan and must
make the plan available upon request for inspection and copying by the DAQ. In addition, if the startup,
shutdown, and malfunction plan is subsequently revised as provided in Section 2.1 F.1.c., the Permittee must
maintain at the affected source each previous (i.e., superseded) version of the startup, shutdown, and
malfunction plan, and must make each such previous version available for inspection and copying by the DAQ
for a period of 5 years after revision of the plan. If at any time after adoption of a startup, shutdown, and
malfunction plan the affected source ceases operation or is otherwise no longer subject to the provisions of this
part, the Permittee must retain a copy of the most recent plan for 5 years from the date the source ceases
operation or is no longer subject to this part and must make the plan available upon request for inspection and
copying by the DAQ. The DAQ may at any time request in writing that the Permittee submit a copy of any
startup, shutdown, and malfunction plan (or a portion thereof) which is maintained at the affected source or in
the possession of the Permittee. Upon receipt of such a request, the Permittee must promptly submit a copy of
the requested plan (or a portion thereof) to the DAQ. The Permittee may elect to submit the required copy of
any startup, shutdown, and malfunction plan to the DAQ in an electronic format. If the owner or operator
claims that any portion of such a startup, shutdown, and malfunction plan is confidential business information
entitled to protection from disclosure under section 114(c) of the Act or 40 CFR 2.301, the material which is
claimed as confidential must be clearly designated in the submission.
e. The Permittee may use the affected source's standard operating procedures (SOP) manual, an Occupational
Safety and Health Administration (OSHA) plan, or other plan, provided the alternative plans meet all the
requirements of this section and are made available for inspection when requested by the DAQ.
f. The DAQ may require that the Permittee of an affected source make changes to the startup, shutdown, and
malfunction plan for an affected source based on the review of monitoring data and/or the plan. The DAQ may
require reasonable revisions to a startup, shutdown, and malfunction plan, if the DAQ finds that the plan:
i. Does not address a startup, shutdown, or malfunction event that has occurred;
ii. Fails to provide for the operation of the source (including associated air pollution control equipment)
during a startup, shutdown, or malfunction event in a manner consistent with good air pollution control
practices for minimizing emissions at least to the levels required by all relevant standards; or
iii. Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control
equipment as quickly as practicable.
g. If the startup, shutdown, and malfunction plan fails to address or inadequately addresses an event that meets
the characteristics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the
time the Permittee developed the plan, the Permittee shall revise the startup, shutdown, and malfunction plan
within 45 days after the event to include detailed procedures for operating and maintaining the source during
similar malfunction events and a program of corrective action for similar malfunctions of process or air
pollution control equipment.
Startup, Shutdown, and Malfunction Reports [40 CFR 63.10(d)(5)]
h. Periodic startup, shutdown, and malfunction reports. If actions taken by the Permittee during a startup,
shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are
consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee
shall state such information in a startup, shutdown, and malfunction report. Reports shall only be required if a
startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and
malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee or other
responsible official who is certifying its accuracy, which shall be submitted to the DAQ semiannually. If the
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Permittee is required to submit excess emissions and continuous monitoring system performance (or other
periodic) reports under this part, the startup, shutdown, and malfunction reports may be submitted
simultaneously with the excess emissions and continuous monitoring system performance (or other) reports.
i. Immediate startup, shutdown, and malfunction reports. Any time an action taken by the Permittee during a
startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the
procedures specified in the affected source's startup, shutdown, and malfunction plan, the Permittee shall report
the actions taken for that event within two working days after commencing actions inconsistent with the plan
followed by a letter within seven working days after the end of the event. The immediate report shall consist of
a telephone call (or facsimile (FAX) transmission) to the DAQ within two working days after commencing
actions inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within seven
working days after the end of the event, that contains the name, title, and signature of the responsible official
who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the
startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring
exceedances are believed to have occurred.
2. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Part 63,
Subpart G, NESOHAP from the SOCMI for Process Vents, Storage Vessels, Transfer Operations, and
Wastewater and 40 CFR Part 63, Subpart SS, NESHAP for Closed Vent Systems, Control Devices, Recovery
Devices and Routing to a Fuel Gas System or a Process
Operating Requirements a. The following provisions do not apply to vapor collection and closed vent systems operated and maintained
under negative pressure and the wax emulsion plant (ID No. WAX).
b. Vapor collection and closed vent systems (ID Nos. CVS1, CVS2, CVS3, and NRBV1) shall be designed and
operated to collect the regulated material vapors from the emission point, and to route the collected vapors to a
control device.
c. Vapor collection and closed vent systems (ID Nos. CVS1, CVS2, CVS3, and NRBV1) shall be operated at all
times when emissions are vented to, or collected by, them.
Inspection and Recordkeeping Requirements [15A NCAC 02Q .0508(f)]
d. The following are inspection and recordkeeping requirements for closed vent systems collecting regulated
material from a regulated source. [40 CFR 63.148(i) and 40 CFR 63.998(d)]
i. Identification of all parts of the vapor collection system or closed vent system that are designated as unsafe
and/or difficult to inspect, an explanation of why the equipment is unsafe and/or difficult to inspect, and
the plan for inspecting the equipment. [40 CFR 63.148(i)(1) and (2)]
ii. For a vapor collection or closed vent system collecting regulated material from a regulated source, when a
leak is detected, the following information shall be recorded and kept for five years.
(A) The instrument and the equipment identification number and the operator name, initials, or
identification number.
(B) The date the leak was detected and the date of the first attempt to repair the leak.
(C) The date of successful repair of the leak.
(D) The maximum instrument reading measured after the leak is successfully repaired or determined to be
nonrepairable.
(E) ‘‘Repair delayed’’ and the reason for the delay if a leak is not repaired within 15 calendar days after
discovery of the leak.
(F) For closed vent systems subject to 40 CFR Part 63, Subpart OOO/SS (ID Nos. CVS3 and NRBV1),
the Permittee may develop a written procedure that identifies the conditions that justify a delay of
repair. In such cases, reasons for delay of repair may be documented by citing the relevant sections of
the written procedure. [40 CFR 63.998(d)(1)(iii)(E)]
(G) For closed vent systems subject to 40 CFR Part 63, Subpart OOO/SS (ID Nos. CVS3 and NRBV1)
only, copies of the Periodic Reports if records are not maintained on a computerized database capable
of generating summary reports from the records. [40 CFR 63.998(d)(1)(iii)(F)]
(H) For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, the
name, initials, or other form of identification of the owner or operator (or designee) whose decision it
was that repair could not be effected without a shutdown. [40 CFR 63.148(i)(4)(v)]
(I) For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, the
expected date of successful repair of the leak if a leak is not repaired within 15 calendar days. [40
CFR 63.148(i)(4)(vi)]
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(J) For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, dates
of shutdowns that occur while the equipment is unrepaired. [40 CFR 63.148(i)(4)(vii)]
iii. For each instrumental or visual inspection conducted for vapor collection or closed vent systems collecting
regulated material from a regulated source during which no leaks are detected, the Permittee shall record
that the inspection was performed, the date of the inspection, and a statement that no leaks were detected.
iv. Except for any vapor collection or closed vent systems that are designated as unsafe or difficult to inspect,
each vapor collection or closed vent system shall be inspected as follows.
(A) If the vapor collection or closed vent system is constructed of hard-piping, the Permittee shall conduct
an initial inspection with instrumentation; and conduct annual inspections for visible, audible, or
olfactory indications of leaks. [40 CFR 63.148(b)(1) and 40 CFR 63.938(b)(1)(i)]
(B) If the closed vent system is constructed of ductwork, the Permittee shall conduct an initial and annual
inspection with instrumentation. [40 CFR 63.148(b)(2)(i) and (ii) and 40 CFR 63.938(b)(1)(ii)]
Additionally, visual inspection for visible, audible, or olfactory indications of leaks shall be conducted
for vapor collection and closed vent systems subject to 40 CFR 63, Subpart G monitoring
requirements (ID Nos. CVS1 and CVS2). [40 CFR 63.148(b)(2)(iii)]
v. Any parts of the vapor collection or closed vent system that are designated as unsafe to inspect are exempt
from the inspection requirements if the following conditions are met. [40 CFR 63.148(h) and 40 CFR
63.938(b)(3)]
(A) The Permittee determines that the equipment is unsafe-to-inspect because inspecting personnel would
be exposed to an imminent or potential danger as a consequence of an inspection; and
(B) The Permittee has a written plan that requires inspection of the equipment as frequently as practical
during safe-to-inspect times. Inspection is not required more than once annually.
vi. Any parts of the vapor collection or closed vent system that are designated as difficult-to-inspect are
exempt from the inspection requirements if the following conditions are met. [40 CFR 63.148(g) and 40
CFR 63.938(b)(2)]
(A) The Permittee determines that the equipment cannot be inspected without elevating the inspecting
personnel more than two meters (seven feet) above a support surface; and
(B) The Permittee has a written plan that requires inspection of the equipment at least once every five
years.
The Permittee shall be deemed in noncompliance with 02D .1111 if the requirements in Section 2.2A.2.d are
not met.
Testing Procedures [15A NCAC 02Q .0508(f)] [40 CFR 63.148(c) and 40 CFR 63.938(c)].
e. Inspections of closed vent systems collecting regulated material from a regulated source shall be conducted
according to the following procedures:
i. Inspections shall be conducted in accordance with Method 21 of 40 CFR Part 60, Appendix A, except as
specified otherwise.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR Part 60, Appendix
A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 must be for the
representative composition of the process fluid and not of each individual VOC in the stream. For process
streams that contain nitrogen, air, water, or other inerts that are not organic HAP or VOC, the
representative stream response factor must be determined on an inert-free basis. The response factor may
be determined at any concentration for which the monitoring for leaks will be conducted. However, if no
instrument is available at the plant site that will meet the performance criteria of Method 21, the
instrument readings may be adjusted by multiplying by the representative response factor of the process
fluid, calculated on an inert-free basis.
iii. The detection instrument shall be calibrated before use on each day of its use by the procedures specified
in Method 21 of 40 CFR Part 60, Appendix A.
iv. Calibration gases shall be as specified below.
(A) Zero air (less than 10 parts per million hydrocarbon in air); and
(B) Mixtures of methane in air at a concentration less than 10,000 parts per million. A calibration gas
other than methane in air may be used if the instrument does not respond to methane or if the
instrument does not meet the performance criteria of Method 21. In such cases, the calibration gas
may be a mixture of one or more of the compounds to be measured in air.
(C) For inspection of closed vent systems subject to 40 CFR Part 63, Subpart OOO/SS (ID Nos. CVS3
and NRBV1), if the detection instrument’s design allows for multiple calibration scales, then the
lower scale shall be calibrated with a calibration gas that is no higher than 2,500 parts per million. [40
CFR 63.938(c)(v)(C)]
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v. The Permittee may elect to adjust or not adjust instrument readings for background. If the Permittee elects
not to adjust readings for background, all such instrument readings shall be compared directly to 500 parts
per million to determine whether there is a leak. If the Permittee elects to adjust instrument readings for
background, the Permittee shall measure background concentration using the procedures provided above
(i. through iv.). The Permittee shall subtract the background reading from the maximum concentration
indicated by the instrument.
vi. If the Permittee elects to adjust for background, the arithmetic difference between the maximum
concentration indicated by the instrument and the background level shall be compared with 500 parts per
million for determining whether there is a leak.
vii. In accordance with 40 CFR 63.983(c)(2) for closed vent systems subject to 40 CFR 63, Subpart OOO/SS
(ID Nos. CVS3 and NRBV1) only, the instrument probe shall be traversed around all potential leak
interfaces as described in Method 21 of 40 CFR Part 60, Appendix A. [40 CFR 63.938(c)(vii)(2)]
viii. In accordance with 40 CFR 63.983(c)(3) for closed vent systems subject to 40 CFR Part 63, Subpart
OOO/SS (ID Nos. CVS3 and NRBV1) only, inspections shall be performed when the equipment is in
regulated material service, or in use with any other detectable gas or vapor. [40 CFR 63.938(c)(vii)(3)]
The Permittee shall be deemed in noncompliance with 02D .1111 if the requirements in Section 2.2A.2.e are
not met.
Leak Repair Requirements [15A NCAC 02Q .0508(f)]
f. The following leak repair provisions apply to closed vent systems collecting regulated material from a
regulated source. [40 CFR 63.148(d) and
i. If there are visible, audible, or olfactory indications of leaks at the time of annual visual inspections, the
Permittee shall eliminate the leak or monitor the equipment according to the procedures proscribed in
Section 2.2.A.2.e.
ii. Leaks, as indicated by an instrument reading greater than 500 parts per million by volume above
background or by visual inspections, shall be repaired as soon as practical, except as provided for in delay
of repair.
iii. A first attempt at repair shall be made no later than five days after the leak is detected.
iv. Repairs shall be completed no later than 15 days after the leak is detected or at the beginning of the next
introduction of vapors to the system, whichever is later unless the leak qualifies for a delay of repair.
v. Delay of repair of a closed vent system for which leaks have been detected is allowed if repair within 15
days after a leak is detected is technically infeasible or unsafe without a closed vent system shutdown, or if
the Permittee determines that emissions resulting from immediate repair would be greater than the
emissions likely to result from delay of repair. Repair of such equipment shall be completed as soon as
practical but not later than the end of the next vapor collection system or closed vent system shutdown. [40
CFR 63.938(d)(3)]
The Permittee shall be deemed in noncompliance with 02D .1111 if the requirements in Section 2.2A.2.f are
not met.
Reporting Requirements [15A NCAC 02Q .0508(f), 40 CFR 63.148(j), 40 CFR 63.148(i)(4), 40 CFR
63.999(c) and 40 CFR 63.998(d)(1)(iii)(B) through (E)]
g. The Permittee shall submit a summary report with the following information postmarked on or before January
30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June.
i. Identification of the leak, including the instrument identification numbers; operator name or initials; and
identification of the equipment. If none found, state that no leaks were found.
ii. The date the leak was detected and the date of the first attempt to repair the leak.
iii. The date of successful repair of the leak.
iv. The maximum instrument reading measured after the leak is successfully repaired or determined to be
nonrepairable.
v. “Repair delayed” and the reason for the delay if a leak is not repaired within 15 days after discovery of the
leak. The Permittee may develop a written procedure that identifies the conditions that justify a delay of
repair. In such cases, reasons for delay of repair may be documented by citing the relevant sections of the
written procedure.
vi. For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, the name,
initials, or other form of identification of the owner or operator (or designee) whose decision it was that
repair could not be effected without a shutdown.
vii. For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, the
expected date of successful repair of the leak if a leak is not repaired within 15 calendar days.
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viii. For closed vent systems subject to 40 CFR Part 63, Subpart G (ID Nos. CVS1 and CVS2) only, dates of
shutdowns that occur while the equipment is unrepaired.
3. 15A NCAC 02D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY – 40 CFR Subpart G,
Maintenance Wastewater Requirements
a. The Permittee shall prepare a description of maintenance procedures for management of wastewater containing
those organic HAP's listed in Table 9 of 40 CFR Part 63, Subpart G generated from the emptying and purging
of equipment in the process during temporary shutdowns for inspections, maintenance, and repair (i.e., a
maintenance-turnaround) and during periods which are not shutdowns (i.e., routine maintenance). The
descriptions shall include the following information.
i. The process equipment or maintenance tasks that are anticipated to create wastewater during maintenance
activities.
ii. The procedures that will be followed to properly manage the wastewater and control organic HAP
emissions to the atmosphere.
iii. The procedures to be followed when clearing materials from process equipment.
[40 CFR 63.105(a) and (b)]
b. The Permittee shall modify and update the wastewater management procedures as needed following each
maintenance procedure based on the actions taken and the wastewater generated in the preceding maintenance
procedure. [40 CFR 63.105(c)]
c. The Permittee shall implement the maintenance wastewater procedures as part of the start-up, shutdown, and
malfunction plan. [40 CFR 63.105(d)]
d. The Permittee shall maintain a record of the maintenance wastewater procedures as part of the start-up,
shutdown, and malfunction plan. [40 CFR 63.105(e)]
e. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the requirements in Section
2.2.A.3.a. through d. are not met.
B. Facility-Wide
The following table provides a summary of limits and standards for the emission source(s) describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
VOC
VOC emissions shall not exceed 100 tons per consecutive
12-month period, rolling monthly total.
15A NCAC 02Q .0317
Avoidance of 02D .0530
VOC Work Practice Standards for Sources of VOC 15A NCAC 02D .0958
Odor State Enforceable Only
The Permittee shall prevent odorous emissions
15A NCAC 02D .1806
TAPS State Enforceable Only Facility wide TAP limits for AAL compliance
15A NCAC 02D .1100
TAPS State Enforceable Only Facility wide compliance with TPER
15A NCAC 02Q. 0711
1. 15A NCAC 02Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 02D .0530: PREVENTION OF
SIGNIFICANT DETERIORATION (Volatile Organic Compounds)
a. In order to avoid applicability of 15A NCAC 02D .0530(g), emissions of volatile organic compounds from the
entire facility, including fugitive emissions, shall not exceed 100 tons rolling total per consecutive 12-month
period, calculated each month.
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition
JJ found in Section 3. If the results of this test are above the limit given in Section 2.2 B.1.a above, the
Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
c. The Permittee shall calculate each month the amount of VOC emissions for the facility using one of the two
following methods:
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i. the Permittee may calculate the amount of VOC emissions from the resin reactors and formaldehyde
plants based on production and emission factors contained in the Title V application as may be adjusted or
added to account for emission controls. All other sources of VOC emissions (tankage, equipment leaks,
wastewater, hexamine production, etc.) may conservatively assume a potential emission of volatile organic
compounds equal to 4.25 tons per month (51 tons total for 12 consecutive months): or
ii. the Permittee may calculate actual emissions rather than assuming potential emissions for one or more
emission sources as necessary to demonstrate compliance with the 100 ton rolling total per 12 consecutive
months. In this instance, the Permittee will document which sources were used and the emissions factors.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the recordkeeping is not
conducted or maintained or if the volatile organic compound emissions exceed the limit in Section 2.2 B.1.a
above.
Reporting [15A NCAC 02Q .0508(f)]
d. The Permittee shall submit a semiannual summary report postmarked within 30 days after each calendar year
half. The reports are to be post marked on or before January 30 of each calendar year for the preceding six-
month period between July and December, and July 30 for the calendar year for the preceding six-month
period between January and June. The report shall contain the following.
i. The monthly emissions of volatile organic compounds for each of the previous 17 months.
ii. The rolling total consecutive 12-month period emissions calculated for each of the six months of the
calendar half.
iii. Any change in emission factor used (e.g., emission controls) from those contained in the Title V permit.
iv. All instances (other than for formaldehyde plants and resin reactors) of when actual rather than potential
emissions were used to demonstrate compliance.
2. 15A NCAC 02D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC COMPOUNDS a. Pursuant to 15A NCAC 02D .0958, for all sources that use volatile organic compounds (VOC) as solvents,
carriers, material processing media, or industrial chemical reactants, or in similar uses that mix, blend, or
manufacture volatile organic compounds, or emit volatile organic compounds as a product of chemical
reactions; the Permittee shall:
i. store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, when not in use,
ii. clean up spills of volatile organic compounds as soon as possible following proper safety procedures,
iii. store wipe rags containing volatile organic compounds in closed containers,
iv. not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile organic
compounds,
v. transfer solvents containing volatile organic compounds used to clean supply lines and other coating
equipment into closable containers and close such containers immediately after each use, or transfer such
solvents to closed tanks, or to a treatment facility regulated under section 402 of the Clean Water Act,
vi. clean mixing, blending, and manufacturing vats and containers containing volatile organic compounds by
adding cleaning solvent and close the vat or container before agitating the cleaning solvent. The spent
cleaning solvent shall then be transferred into a closed container, a closed tank or a treatment facility
regulated under section 402 of the Clean Water Act. [15A NCAC 02D .0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound, the Permittee shall:
i. flush parts in the freeboard area,
ii. take precautions to reduce the pooling of solvent on and in the parts,
iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all dripping has
stopped, whichever is longer,
iv. not fill cleaning machines above the fill line,
v. not agitate solvent to the point of causing splashing. [15A NCAC 02D .0958(d)]
Monitoring [15A NCAC 02Q .0508(f)]
c. To assure compliance with Sections 2.2. B.2.a. and b. above, the Permittee shall, at a minimum, perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds. The
inspections shall be conducted during normal operations. If the required inspections are not conducted the
Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0958.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the inspections shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
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i. the date and time of each inspection; and
ii. the results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with 15A
NCAC 02D .0958.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the observations on or before January 30 of each calendar year
for the preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements of
this permit must be clearly identified.
State Enforceable Only
3. 15A NCAC 02D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS The Permittee shall not operate the facility without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
State Enforceable Only
4. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT
Pursuant to 15A NCAC 02D .1100, the approved (December 7, 2006) application for an air toxic compliance
demonstration and the approved Application No.2600009.08A for resin process modifications, modeled emission
rates in the following table shall not be exceeded. Testing, monitoring, recordkeeping and reporting shall be
conducted in accordance with the provisions of applicable regulations pursuant to 40 CFR Part 63; Subparts F, G,
H, and OOO. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .1100 if these tasks as
stated herein are not performed.
Emission Point: Associated Emission Sources Toxic Air
Pollutants
Emission
Limits
Resin Scrubber Stack (CD200A and CD200B):
Three 50% formaldehyde, UFC, and hydrolyzed re-work resin storage tanks
(MOSTORE 1A, MOSTORE 1B, MOSTORE 1C);
Three 50% formaldehyde, UFC, and hydrolyzed re-work resin storage tanks (MOSTORE 1D,
MOSTORE 1E, MOSTORE 2);
Urea/formaldehyde No. 2 batch reactor (BR2);
Distillate receiving tank for batch reactor No. 2 (BR2DRT);
Weigh tank (12,000 gallons) for batch reactors No. 2 and No. 3 (FWTBR2);
Urea/formaldehyde No. 3 batch reactor (BR3);
Distillate receiving tank for No. 3 batch reactor (BR3DRT);
Liquid ring vacuum seal water tank for batch reactors No. 2 and No. 3 vacuum systems
(VST2/3);
PF/UF swing No. 4 batch reactor (BR4);
Liquid ring vacuum seal water tank for No. 4 batch reactor vacuum system (VST4);
Distillate receiving tank for No. 4 batch reactor (BR4DRT);
Railcar urea formaldehyde concentrate product load out (two arms, RLOAD3); and
Tank truck urea formaldehyde concentrate product load out (one arm, TLOAD2A)
formaldehyde
phenol
0.85 lb/hr
0.01 lb/hr
Hexamine Scrubber Stack (CDSC2):
hexamethylenetetramine reactor (HRE)
ammonia
formaldehyde
0.27 lb/hr
0.215 lb/hr
Formaldehyde Production Fugitive Emissions (FORMEQLK) formaldehyde 0.22 lb/hr
Resin Production Fugitive Emissions (BREQLK) phenol 0.1 lb/hr
Methanol Distillate Tank (ES105) formaldehyde 0.00494 lb/hr
Formaldehyde Plants No. 1 and No. 2 (FORM12) formaldehyde 0.0911 lb/hr
Formaldehyde Plant No. 3 (FORM3) formaldehyde 0.049 lb/hr
Formaldehyde Plant No. 4 (ES16) and Plant 4 dilute tank (IDTS) formaldehyde 0.500 lb/hr
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Emission Point: Associated Emission Sources Toxic Air
Pollutants
Emission
Limits
Hexamine distillate, defoamer, catalyst, and wastewater tank (ESDS) ammonia
formaldehyde
0.0018 lb/hr
0.00183 lb/hr
Tank truck phenol/formaldehyde resin load out (TLOAD1B or TLOAD2B)
and
Tank truck urea formaldehyde resin load out (TLOAD2B or TLOAD1B)
formaldehyde
phenol
formaldehyde
0.29 lb/hr
1.42 lb/hr
0.063 lb/hr
Tank truck urea formaldehyde resin and wax product load out (TLOAD3B) formaldehyde 0.158 lb/hr
Tank truck phenol formaldehyde resin load out, and receiving for caustic, temulose, beet
molasses, and phenol (TLOAD4)
formaldehyde
phenol
0.165 lb/hr
0.809 lb/hr
Tank truck urea formaldehyde resin and phenol formaldehyde resin load out, and receiving for
aqueous ammonia (TLOAD5)
formaldehyde
phenol
0.165 lb/hr
0.809lb/hr
Tank truck urea formaldehyde resin load out (TLOAD6) formaldehyde 0.048 lb/hr
Phenol tank (PT1) phenol 0.242 lb/hr
Phenol tank (PT2) phenol 0.242 lb/hr
Hexamine concentrate water, defoamer, catalyst, and wastewater tank(ESCT1) ammonia 0.0041 lb/hr
Hexamine concentrate water, defoamer, catalyst, and wastewater tank (ESCT2) ammonia 0.0041 lb/hr
Hexamine process water, defoamer, catalyst, and wastewater tank (ESOT1) ammonia 0.0041 lb/hr
Hexamine process water, defoamer, catalyst, and wastewater tank (ESOT2) ammonia 0.0041 lb/hr
Hexamine process water, defoamer, catalyst, and wastewater tank (ESOT3) ammonia 0.0041 lb/hr
Wax plant (WAX) ammonia 0.0204 lb/hr
Resin/resin wash water/diethylene glycol / defoamer/catalyst storage (RTF9)
Resin/resin washwater tank farm (RTF11 through RFT40)
formaldehyde
phenol
0.109 lb/hr
0.21 lb/hr
Resin RTU mix tank with filter (ES103) formaldehyde
phenol
0.010 lb/hr
0.100 lb/hr
Waste water treatment plant (WWTP) ammonia
formaldehyde
phenol
4.70 lb/hr
0.0274 lb/hr
0.00282 lb/hr
Anhydrous ammonia leaks ammonia 1.13 lb/hr
Aqueous ammonia leaks ammonia 0.527 /hr
a. The Permittee shall maintain records of production rates and material usage during the previous calendar year
for all applicable toxic air pollutants to verify compliance with the toxic air pollutant limits. These records
shall be retained on-site and made available to DAQ personnel upon request.
b. The Permittee shall submit a semiannual summary report, acceptable to the Regional Air Quality Supervisor,
of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the
preceding six month period between July and December and July 30 of each calendar year for the preceding
six month period between January and June. The report shall identify any deviations with 15A NCAC
02D .1100 during the six month reporting period, including but not limited to:
i. Any exceedance of any hourly emission limitation.
ii. Any exceedance of any maximum production rate used in the approved air toxic compliance
demonstration.
iii. If there were no deviations during the six month reporting period, include a statement as such.
State-enforceable only
5. 15A NCAC 02Q .0711: EMISSION RATES REQUIRING A PERMIT
Pursuant to 15A NCAC 02Q .0711, Emission Rates Requiring a Permit, for each of the toxic air pollutants (TAPs)
listed below, the Permittee has made a demonstration that potential emissions from the facility do not exceed the
Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 02Q .0711
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a. The facility shall be operated and maintained in such a manner that any new, existing or increased actual
emissions of any TAP listed in 15A NCAC 02Q .0711 or in this permit from all sources at the facility
(excluding those sources exempt under 15A NCAC 02Q .0702 "Exemptions"), including fugitive emissions
and emission sources not otherwise required to have a permit, will not exceed its respective TPER listed in
15A NCAC 02Q .0711 without first obtaining an air permit to construct or operate.
b. PRIOR to exceeding any of the TPERs listed in 15A NCAC 02Q .0711, the Permittee shall be responsible for
obtaining an air permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC
02D .1100 "Control of Toxic Air Pollutants".
c. The Permittee shall maintain at the facility records of operational information sufficient for demonstrating to
the Division of Air Quality staff that actual TAPs are less than the rate listed in 15A NCAC 02Q .0711.
TPERs Limitations
Pollutant
(CAS Number)
Carcinogens
(lbs/yr)
Chronic Toxicants
(lbs/day)
Acute Systemic
Toxicants
(lbs/hr)
Acute Irritants
(lbs/hr)
Toluene (108-88-3) 98 14.4
2.3 - Other Applicable Requirements
A. Facility Wide
1. 15A NCAC 02Q .0508(h): PREVENTION OF ACCIDENTAL RELEASES – SECTION 112(r) OF THE
CLEAN AIR ACT
a. The Permittee is subject to Section 112(r) of the Clean Air Act and shall comply with all applicable
requirements in accordance with 40 CFR Part 68.
Recordkeeping/Reporting [15A NCAC 02Q .0508(g)]
b. The Permittee shall submit an update to the Risk Management Plan (RMP) to EPA pursuant to 40 CFR 68.150
no later than June 13, 2019, or as specified in 40 CFR 68.10.
c. The Permittee shall revise and update the RMP submitted under 40 CFR 68.150 no later than June 13, 2019
and at least once every five years after that date or most recent update as required by 40 CFR 68.190(b)(2)
through (b)(7), whichever is later.
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SECTION 3 - GENERAL CONDITIONS (version 4.0 12/17/15) This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A
NCAC 02D and 02Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and
enforceable pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or criminal
penalties. Any unauthorized deviation from the conditions of this permit may constitute grounds for revocation
and/or enforcement action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other
aspects of the facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal
or plant life, or property caused by the construction or operation of this permitted facility, or from penalties
therefore, nor does it allow the Permittee to cause pollution in contravention of state laws or rules, unless
specifically authorized by an order from the North Carolina Environmental Management Commission.
5. Except as identified as state-only requirements in this permit, all terms and conditions contained herein shall be
enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the appropriate
and valid permits issued by the DAQ, unless the source is exempted by rule. The DAQ may issue a permit
only after it receives reasonable assurance that the installation will not cause air pollution in violation of any of
the applicable requirements. A permitted installation may only be operated, maintained, constructed,
expanded, or modified in a manner that is consistent with the terms of this permit.
B. Permit Availability [15A NCAC 02Q .0507(k) and .0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit
term one complete copy of the application and any information submitted in support of the application package. The
permit and application shall be made available to an authorized representative of Department of Environmental
Quality upon request.
C. Severability Clause [15A NCAC 02Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid, the
provisions in this permit are severable so that all requirements contained in the permit, except those held to be invalid,
shall remain valid and must be complied with.
D. Submissions [15A NCAC 02Q .0507(e) and 02Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, notifications,
request for renewal, and any other information required by this permit shall be submitted to the appropriate Regional
Office. Refer to the Regional Office address on the cover page of this permit. For continuous emissions monitoring
systems (CEMS) reports, continuous opacity monitoring systems (COMS) reports, quality assurance (QA)/quality
control (QC) reports, acid rain CEM certification reports, and NOx budget CEM certification reports, one copy shall
be sent to the appropriate Regional Office and one copy shall be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
All submittals shall include the facility name and Facility ID number (refer to the cover page of this permit).
E. Duty to Comply [15A NCAC 02Q .0508(i)(3)]
The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this
permit. Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a
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violation of the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement action,
for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application.
F. Circumvention - STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in
air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent
operation of its associated air pollution control device(s) and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 02Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A
NCAC 02Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q .0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 02Q.0524 and
02Q .0505.
3. Minor Permit Modifications [15A NCAC 02Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC
02Q .0515.
4. Significant Permit Modifications [15A NCAC 02Q .0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC
02Q .0516.
5. Reopening for Cause [15A NCAC 02Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q .0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s) listed in Section
1 must be reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the
permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the
emission limitations specified herein.
2. Section 502(b)(10) Changes [15A NCAC 02Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition. Such
changes do not include changes that would violate applicable requirements or contravene federally
enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping,
reporting, or compliance certification requirements.
b. The Permittee may make Section 502(b)(10) changes without having the permit revised if:
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Permittee notifies the Director and EPA with written notification at least seven days before the
change is made; and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions; and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or renewed,
whichever comes first.
3. Off Permit Changes [15A NCAC 02Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
a. the change affects only insignificant activities and the activities remain insignificant after the change; or
b. the change is not covered under any applicable requirement.
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4. Emissions Trading [15A NCAC 02Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D, including subsequently adopted maximum
achievable control technology standards, emissions trading shall be allowed without permit revision pursuant to
15A NCAC 02Q .0523(c).
I.A Reporting Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D .0535(f) and
02Q .0508(f)(2)]
“Excess Emissions” - means an emission rate that exceeds any applicable emission limitation or standard allowed by
any rule in Sections .0500, .0900, .1200, or .1400 of Subchapter 02D; or by a permit condition; or that exceeds an
emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note: Definitions of excess emissions
under 02D .1110 and 02D .1111 shall apply where defined by rule.)
“Deviations” - for the purposes of this condition, any action or condition not in accordance with the terms and
conditions of this permit including those attributable to upset conditions as well as excess emissions as defined above
lasting less than four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS (15A NCAC 02D .0524), NESHAPS (15A NCAC
02D .1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of excess emissions,
reporting shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 02D .0524), NESHAPS (15A NCAC 02D .1110 or .1111), or
these rules do NOT define "excess emissions," the Permittee shall report excess emissions in accordance with
15A NCAC 02D .0535 as follows:
a. Pursuant to 15A NCAC 02D .0535, if excess emissions last for more than four hours resulting from a
malfunction, a breakdown of process or control equipment, or any other abnormal condition, the owner or
operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern Time of the
Division's next business day of becoming aware of the occurrence and provide:
● name and location of the facility;
● nature and cause of the malfunction or breakdown;
● time when the malfunction or breakdown is first observed;
● expected duration; and
● estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished; and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A
NCAC 02D .0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 02Q .0508(f)(2), the Permittee shall report deviations from permit requirements (terms
and conditions) as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered
under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall include the
probable cause of such deviation and any corrective actions or preventative actions taken. The responsible
official shall certify all deviations from permit requirements.
I.B Other Requirements under 15A NCAC 02D .0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D .0535, including 15A
NCAC 02D .0535(c) as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the
appropriate rule unless the owner or operator of the sources demonstrates to the Director, that the excess
emissions are a result of a malfunction. The Director shall consider, along with any other pertinent information,
the criteria contained in 15A NCAC 02D .0535(c)(1) through (7).
2. 15A NCAC 02D .0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
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J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control
of the facility, including acts of God, which situation requires immediate corrective action to restore normal
operation, and that causes the facility to exceed a technology-based emission limitation under the permit, due to
unavoidable increases in emissions attributable to the emergency. An emergency shall not include
noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless
or improper operation, or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-
based emission limitations if the conditions specified in 3. below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating
logs or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s) of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions
that exceeded the standards or other requirements in the permit; and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when
emission limitations were exceeded due to the emergency. This notice must contain a description of the
emergency, steps taken to mitigate emissions, and corrective actions taken.
4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden
of proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement
specified elsewhere herein.
K. Permit Renewal [15A NCAC 02Q .0508(e) and 02Q .0513(b)]
This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its
term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q .0500 renewal
application is submitted at least nine months before the date of permit expiration. If the Permittee or applicant has
complied with 15A NCAC 02Q .0512(b)(1), this 15A NCAC 02Q .0500 permit shall not expire until the renewal
permit has been issued or denied. Permit expiration under 15A NCAC 02Q .0400 terminates the facility’s right to
operate unless a complete 15A NCAC 02Q .0400 renewal application is submitted at least six months before the date
of permit expiration for facilities subject to 15A NCAC 02Q .0400 requirements. In either of these events, all terms
and conditions of these permits shall remain in effect until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 02Q .0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce
the permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information (submittal of information) [15A NCAC 02Q .0508(i)(9)]
1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the Director may
request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit or to determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are
requested by the Director. For information claimed to be confidential, the Permittee may furnish such records
directly to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement [15A NCAC 02Q .0507(f)]
The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in
the permit application, shall promptly submit such supplementary facts or corrected information to the DAQ. The
Permittee shall also provide additional information as necessary to address any requirement that becomes applicable to
the facility after the date a complete permit application was submitted but prior to the release of the draft permit.
O. Retention of Records [15A NCAC 02Q .0508(f) and 02Q .0508 (l)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least
five years from the date of the monitoring sample, measurement, report, or application. Supporting information
includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring
information, and copies of all reports required by the permit. These records shall be maintained in a form suitable and
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readily available for expeditious inspection and review. Any records required by the conditions of this permit shall be
kept on site and made available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 02Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61
Forsyth Street SW, Atlanta, GA 30303) postmarked on or before March 1 a compliance certification (for the preceding
calendar year) by a responsible official with all federally-enforceable terms and conditions in the permit, including
emissions limitations, standards, or work practices. It shall be the responsibility of the current owner to submit a
compliance certification for the entire year regardless of who owned the facility during the year. The compliance
certification shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the
Federal Clean Air Act. The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status (with the terms and conditions of the permit for the period covered by the certification);
3. whether compliance was continuous or intermittent; and
4. the method(s) used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 02Q .0520]
A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after
reasonable inquiry, the statements and information in the document are true, accurate, and complete.
R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable
requirements, where such applicable requirements are included and specifically identified in the permit as of the
date of permit issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission, Secretary of the Department, or Governor under NCGS 143-215.3(a)(12), or
EPA under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the
effective date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV; or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision
made under 15A NCAC 02Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515.
S. Termination, Modification, and Revocation of the Permit [15A NCAC 02Q .0519]
The Director may terminate, modify, or revoke and reissue this permit if:
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or
5. the Director finds that termination, modification, or revocation and reissuance of the permit is necessary to carry
out the purpose of NCGS Chapter 143, Article 21B.
T. Insignificant Activities [15A NCAC 02Q .0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted
from any applicable requirement or that the owner or operator of the source is exempted from demonstrating
compliance with any applicable requirement. The Permittee shall have available at the facility at all times and made
available to an authorized representative upon request, documentation, including calculations, if necessary, to
demonstrate that an emission source or activity is insignificant.
U. Property Rights [15A NCAC 02Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
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V. Inspection and Entry [15A NCAC 02Q .0508(l) and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law, the Permittee shall allow the
DAQ, or an authorized representative, to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is
conducted, or where records are kept under the conditions of the permit;
b. have access to and copy, at reasonable times, any records that are required to be kept under the conditions of
the permit;
c. inspect at reasonable times and using reasonable safety practices any source, equipment (including
monitoring and air pollution control equipment), practices, or operations regulated or required under the
permit; and
d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under
Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for
purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or
interfere with any such authorized representative while in the process of carrying out his official duties. Refusal
of entry or access may constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment [15A NCAC 02Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C. Department of Environmental
Quality. Annual permit fee payments shall refer to the permit number.
3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate action to
terminate the permit under 15A NCAC 02Q .0519.
X. Annual Emission Inventory Requirements [15A NCAC 02Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC
02Q .0207(a) from each emission source within the facility during the previous calendar year. The report shall be in
or on such form as may be established by the Director. The accuracy of the report shall be certified by a responsible
official of the facility.
Y. Confidential Information [15A NCAC 02Q .0107 and 02Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q .0107, the
Permittee may also submit a copy of all such information and claim directly to the EPA upon request. All requests for
confidentiality must be in accordance with 15A NCAC 02Q .0107.
Z. Construction and Operation Permits [15A NCAC 02Q .0100 and .0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or
emission source which is not exempted from having a permit prior to the beginning of construction or modification, in
accordance with all applicable provisions of 15A NCAC 02Q .0100 and .0300.
AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC
02Q .0505 and .0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q .0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
CC. Refrigerant Requirements (Stratospheric Ozone and Climate Protection) [15A NCAC 02Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which use Class
I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as
refrigerants in 40 CFR Part 82 Subpart A Appendices A and B, the Permittee shall service, repair, and maintain
such equipment according to the work practices, personnel certification requirements, and certified recycling and
recovery equipment specified in 40 CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the environment
during the repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82
Subpart F.
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3.
shall be submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases - Section 112(r) [15A NCAC 02Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r) of
the Clean Air Act, then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
EE. Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) – FEDERALLY-ENFORCEABLE
ONLY
Although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any
amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent
the accidental release of such substance and to minimize the consequences of any release.
FF. Title IV Allowances [15A NCAC 02Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee, but the Permittee may not use
allowances as a defense to noncompliance with any other applicable requirement. The Permittee’s emissions may not
exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG. Air Pollution Emergency Episode [15A NCAC 02D .0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be required to operate
in accordance with the Permittee’s previously approved Emission Reduction Plan or, in the absence of an approved
plan, with the appropriate requirements specified in 15A NCAC 02D .0300.
HH. Registration of Air Pollution Sources [15A NCAC 02D .0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to
register a source of air pollution, this registration and required information will be in accordance with 15A NCAC
02D .0202(b).
II. Ambient Air Quality Standards [15A NCAC 02D .0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any
source of air pollution shall be operated with such control or in such manner that the source shall not cause the
ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on which the
source is located. When controls more stringent than named in the applicable emission standards in this permit are
required to prevent violation of the ambient air quality standards or are required to create an offset, the permit shall
contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q .0508(i)(16)]
Emission compliance testing shall be by the procedures of Section .2600, except as may be otherwise required in
Rules .0524, .0912, .1110, .1111, or .1415 of Subchapter 02D. If emissions testing is required by this permit or the
DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance, the Permittee shall perform
such testing in accordance with 15A NCAC 02D .2600 and follow the procedures outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing. Testing protocols are not required to be pre-approved by the Director
prior to air pollution testing. The Director shall review air emission testing protocols for pre-approval prior to
testing if requested by the owner or operator at least 45 days before conducting the test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard
shall notify the Director at least 15 days before beginning the test so that the Director may at his option
observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates during the
period of air testing. The owner or operator of the source shall ensure that the equipment or process being
tested is operated at the production rate that best fulfills the purpose of the test. The individual conducting the
emission test shall describe the procedures used to obtain accurate process data and include in the test report
the average production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after
sample collection unless otherwise specified in the specific conditions. The owner or operator may request an
extension to submit the final test report. The Director shall approve an extension request if he finds that the
extension request is a result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the validity
of the compliance test. The Director may:
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i. Allow deviations from a method specified under a rule in this Section if the owner or operator of the
source being tested demonstrates to the satisfaction of the Director that the specified method is
inappropriate for the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative method is
necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test
method is specified in this Section if the methods can be demonstrated to determine compliance of
permitted emission sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source subject
to a rule in this Subchapter to determine the compliance status of that source or to verify any test data
submitted relating to that source. Any test conducted by the Division of Air Quality using the appropriate
testing procedures described in Section 02D .2600 has precedence over all other tests.
KK. Reopening for Cause [15A NCAC 02Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three or
more years;
b. additional requirements (including excess emission requirements) become applicable to a source covered by
Title IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made
in establishing the emissions standards or other terms or conditions of the permit; or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable
requirement is promulgated. No reopening is required if the effective date of the requirement is after the
expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q .0513(c).
3. Except for the state-enforceable only portion of the permit, the procedures set out in 15A NCAC
02Q .0507, .0521, or .0522 shall be followed to reissue the permit. If the State-enforceable only portion of the
permit is reopened, the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall affect only
those parts of the permit for which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,
except in cases of imminent threat to public health or safety the notification period may be less than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the EPA
that a permit needs to be terminated, modified, or revoked and reissued, the Director shall send to the EPA a
proposed determination of termination, modification, or revocation and reissuance, as appropriate.
LL. Reporting Requirements for Non-Operating Equipment [15A NCAC 02Q .0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken
from and placed into operation. During operation the monitoring recordkeeping and reporting requirements as
prescribed by the permit shall be implemented within the monitoring period.
MM. Fugitive Dust Control Requirement [15A NCAC 02D .0540] - STATE ENFORCEABLE ONLY
As required by 15A NCAC 02D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not
cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions
beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are
observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR,
Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 02D .0540(f).
"Fugitive dust emissions" means particulate matter from process operations that does not pass through a process stack
or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas,
process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul
roads).
NN. Specific Permit Modifications [15A NCAC 02Q.0501 and .0523]
1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2), the Permittee shall file a Title V Air Quality
Permit Application for the air emission source(s) and associated air pollution control device(s) on or before 12
months after commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2), the Permittee shall not begin operation of the
air emission source(s) and associated air pollution control device(s) until a Title V Air Quality Permit
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Application is filed and a construction and operation permit following the procedures of Section .0500 (except
for Rule .0504 of this Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 02Q .0523(a)(1)(C), the
Permittee shall notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth Street SW, Atlanta, GA
30303) in writing at least seven days before the change is made. The written notification shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit renewal,
the Permittee shall submit a page "E5" of the application forms signed by the responsible official verifying that the
application for the 502(b)(10) change/modification, is true, accurate, and complete. Further note that modifications
made pursuant to 502(b)(10) do not relieve the Permittee from satisfying preconstruction requirements.
OO. Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and .0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency (EPA), EPA’s
decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party
petition, the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit.
The time period available to submit a public petition pursuant to 15A NCAC 02Q .0518 begins at the end of the 45-
day EPA review period.
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ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOX Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
SO2 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound