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

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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.

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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

Page 15

(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)

Permit 03387T44

Page 18

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

Page 20

(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

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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;

Permit 03387T44

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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

Permit 03387T44

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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

Permit 03387T44

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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

Permit 03387T44

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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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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).

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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.

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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.

Permit 03387T44

Page 49

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.

Permit 03387T44

Page 52

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;

Permit 03387T44

Page 53

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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Page 54

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