Draft Permit Review - Division of Air Quality

Region: Winston-Salem Regional Office
County: Stokes
NC Facility ID: 8500028
Inspector’s Name: Hilary King
Date of Last Inspection: 11/05/2014
Compliance Code: 3 / Compliance - inspection
Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date:
Facility Data
Applicant (Facility’s Name): Wieland Copper Products, LLC
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
Facility Address:
Wieland Copper Products, LLC
3990 US Highway 311 North
Pine Hall, NC
27042
SIC: 3351 / Copper Rolling And Drawing
NAICS: 331421 / Copper Rolling, Drawing, and Extruding
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
Tony Sprinkle
Rick Stehlin
Safety & Environmental
VP of Operations
Supervisor
(336) 445-4567
(336) 445-4526
3990 US 311 Highway N
3990 US Highway 311
Pine Hall, NC 27042
North
Pine Hall, NC 27042
Total Actual emissions in TONS/YEAR:
CY
SO2
NOX
VOC
Application Data
Technical Contact
Tony Sprinkle
Safety & Environmental
Supervisor
(336) 445-4526
3990 US Highway 311
North
Pine Hall, NC 27042
CO
PM10
Application Number: 8500028.15A
Date Received: 01/08/2015
Application Type: Renewal
Application Schedule: TV-Renewal
Existing Permit Data
Existing Permit Number: 02469/T20
Existing Permit Issue Date: 12/06/2010
Existing Permit Expiration Date: 11/30/2015
Total HAP
Largest HAP
2013
6.94
5.21
48.14
101.62
2.49
0.0963
0.0401
[Hydrogen chloride (hydrochlori]
2012
6.89
5.73
48.12
104.75
2.82
0.0764
0.0280
[Hydrogen chloride (hydrochlori]
2011
4.83
5.43
59.61
132.79
3.50
0.1034
0.0403
[Hydrogen chloride (hydrochlori]
2010
4.32
4.92
46.89
142.04
3.53
0.0643
0.0290
[Hydrogen chloride (hydrochlori]
2009
3.61
4.79
60.18
153.35
3.14
0.0808
0.0379
[Hydrogen chloride (hydrochlori]
Review Engineer: Russell Braswell
Review Engineer’s Signature:
Date:
Comments / Recommendations:
Issue 02469/T21
Permit Issue Date:
Permit Expiration Date:
Review of application 8500028.15A
Wieland Copper Products, LLC
Page 2 of 5
1. Purpose of Application:
Wieland Copper Products, LLC (Wieland) currently operates under Air Quality Permit 02469T20, which has
an expiration date of November 30, 2015. Wieland has applied to renew its Air Quality Permit. Because this
renewal application was received at least nine months before the permit expiration date, the existing permit
will remain in effect, regardless of the expiration date, until this permit application is issued or denied.
2. Facility Description:
"The facility is a secondary copper smelter and foundry and manufactures copper piping/tubing for various
customers…The facility operates 24 hours per day for 365 days per year except for selected holidays."1
3. History/Background Since the Previous Renewal:
The permit was renewed on December 6, 2010. No permit actions have been made since then.
4. Application Chronology:

January 8, 2015
Application .15A received in regional office.

January 12, 2015
Application received in central office.

February 18, 2015
Applicability determination request (2573) received regarding a new annealing
furnace.

February 24, 2015
The proposed annealing furnace was determined to be an insignificant source.

XXXX
An initial draft of the permit and review were sent to DAQ staff (Mark Cuilla,
Samir Parekh, Hilary King, Jalal Adouli) and Wieland staff (Tony Sprinkle).
For a summary of comments received, see Attachment 2.
5. Permit Modifications/Changes and TVEE Discussion:
Based on the renewal application and the most recent inspection report, the exothermic generators and
associated oxidizer have been removed from the permit. The PSD avoidance condition associated with
these sources has also been removed.
Per a recent applicability determination, the annealing furnace IAF-3 has been added to the insignificant
list.
The list of changes to the permit can be found in Attachment 1.
6. Regulatory Review:
Wieland is subject to the following regulations, in addition to the requirements in the General Conditions:
a. 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes"
b. 15A NCAC 2D .0516 "Sulfur Dioxide from Combustion Sources"
1
From Hilary King's inspection report, dated November 7, 2014
Review of application 8500028.15A
Wieland Copper Products, LLC
Page 3 of 5
c.
d.
e.
f.
g.
h.
15A NCAC 2D .0521 "Control of Visible Emissions"
15A NCAC 2D .0524 "New Source Performance Standards" (40 CFR Part 60 Subpart IIII)
15A NCAC 2D .0614 "Compliance Assurance Monitoring"
15A NCAC 2D .0958 "Work Practices for Sources of Volatile Organic Compounds"
15A NCAC 2D .1111 "Maximum Achievable Control Technology" (40 CFR Part 63 Subpart ZZZZ)
15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions"
An extensive review for each applicable regulation is not included in this document, as the facility’s status
with respect to these regulations has not changed. The permit will be updated to reflect the most current
stipulations for all applicable regulations.
7. NSPS, MACT/GACT, PSD/NSR, 112(r), RACT, CAM:
a. NSPS
1. Subpart IIII
This regulation applies to the emergency generator ES-EG-2. Because this generator is an
emergency-use engine, the requirements are:
a.
b.
c.
d.
e.
Engine must comply with the model-year standards in 60.4202
Use ultra-low sulfur diesel fuel
Install an hour meter
Operate the engine as instructed by the manufacturer
Operate only under periods allowed by 60.4211(f)
Based on the most recent inspection report, the facility appears to be in compliance with this
regulation. The permit stipulation has been updated to reflect recent revisions in the regulation.
b. MACT/GACT
1. Subpart ZZZZ
This regulation applies to both generators (IES-EG-1 and ES-EG-2) at the facility. IES-EG-1 is
considered existing, and ES-EG-2 is considered new. The facility is an area source (i.e.
HAP-minor).
For new emergency-use engines that are also subject to NSPS Subpart IIII, the only requirement
under Subpart ZZZZ is that they comply with the NSPS.
For existing emergency-use engines of this size and fuel type, the general requirements of Subpart
ZZZZ are:
a. Comply with work practice and maintenance standards
b. Install an hour meter
Based on the most recent inspection report, the facility appears to be in compliance with this
regulation. The permit stipulation has been updated to reflect recent revisions in the regulation.
Note that because IES-EG-1 is considered an insignificant source, it is not referenced in any permit
stipulation.
Review of application 8500028.15A
Wieland Copper Products, LLC
Page 4 of 5
c. PSD/NSR
Previously, Wieland had been avoiding PSD applicability by limiting CO emissions from EXGen1, 2,
and 3. Based on the renewal application, these sources have been removed from the facility. The
sources that replaced EXGen 1, 2, and 3 operate in a different manner and do not emit CO. Therefore,
no PSD avoidance conditions are required.
d. 112(r)
The facility does not store any 112(r)-subject chemicals above their respective thresholds. Therefore,
the facility does not have any increased requirements under Section 112(r) of the Clean Air Act.
e. RACT
The facility is not located in an area of ozone nonattainment. Therefore, RACT does not apply.
f.
CAM
CAM applies to a control device if the following criteria are met:
1. The unit being controlled is subject to a non-exempt emission standard,
2. The control device is being used to comply with the emission standard, and
3. The unit being controlled has potential emissions of the pollutant subject to the emission standard
of greater than major source thresholds.
According to the T20 permit review (Mark Cuilla, December 6, 2010), the only control devices at the
facility subject to CAM are the bagfilters B-1 through B-4.
The current CAM plan requires that the facility monitor the pressure drop across the bagfilters. The
plan specifies monitoring frequency and acceptable pressure drop.
The CAM plan has been updated slightly to include two corrections. First, the plan indicates that the
bagfilters operate in parallel. Second, visible emission limits are not considered a trigger for CAM, and
therefore have been removed from the permit stipulation.
The permit stipulation has been rewritten to better match the standard format.
8. Toxic Air Pollutants
The permit does not include any TAP emission limits or requirements. This renewal application does not
affect this status.
9. Facility Emissions Review
For a historical review of emissions from the facility, see the table on the first page of the review. Note that
this data already accounts for the deactivation of EXGen 1, 2, and 3.
10. Compliance Status
Review of application 8500028.15A
Wieland Copper Products, LLC
Page 5 of 5
1. Notices of Violation/Recommendation for Enforcement since the previous renewal
None.
2. Inspection status
The facility was most recently inspection by Hilary King, on November 7, 2014. The facility appeared
to be in compliance with the permit at that time.
11. Other Regulatory Concerns
A PE seal was not required for this permit renewal.
A zoning consistency form was not required for this permit renewal.
12. Public Notice/EPA and Affected State(s) Review
A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 2Q .0521. The notice will
provide for a 30-day comment period, with an opportunity for a public hearing. Copies of the public notice
shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 2Q .0522, a copy of
each permit application, each proposed permit and each final permit pursuant shall be provided to EPA.
Also pursuant to 2Q .0522, a notice of the DRAFT Title V Permit shall be provided to each affected State at
or before the time notice provided to the public under 2Q .0521 above.
13. Recommendations
Issue permit 02469T21.
Review of application 8500028.15A
Wieland Copper Products, LLC
Attachment 1
Change List
Pages
Throughout
Section
Throughout
Attachment 2
Insignificant List
3
Permitted Emission
Source List
2.1.A.3
2.1.C.
2.1.E.3.
2.1.E.4.
2.2.A.
3
Description of Changes
Updated dates
Updated permit numbers
Updated contact info
Updated permit formatting and template
Added furnace I-AF3 per applicability determination
2573
 Numbered out all equipment IDs
 Removed EXGen1, 2, and 3 and CATOX1 per
application.
 Reformatted CAM stipulation to fit with rest of permit.
 Added specific requirements for CAM reporting.
Removed PSD Avoidance condition because it applied to
sources no longer on the permit.
Updated permit stipulation to reflect changes in NSPS Subpart
IIII
Updated permit stipulation to match DAQ template
Indicated that 2D.0958 and 2D .1806 apply on a facility-wide
basis.
Updated General Condition to v3.6





Review of application 8500028.15A
Wieland Copper Products, LLC
Attachment 2
Comments Received on Initial Draft

Mark Cuilla, by email on March 10, 2015
1. Mark pointed out that the regulation for opacity testing is 15A NCAC 2D .2610, not 2601.
Response: Fixed
2. Mark pointed several minor typos throughout the permit and review.
Response: Fixed