Permit Review - Division of Air Quality

Transcription

Region: Fayetteville Regional Office
County: Montgomery
NC Facility ID: 6200061
Inspector’s Name: Gregory Reeves
Date of Last Inspection: 04/22/2014
Compliance Code: B / Violation - emissions
Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date:
Facility Data
Applicant (Facility’s Name): Unilin Flooring N.V.
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
Facility Address:
Unilin Flooring N.V.
149 Homanit USA Road
Mt Gilead, NC
27306
SIC: 2493 / Reconstituted Wood Products
NAICS: 321219 / Reconstituted Wood Product Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Application Data
Facility Contact
Authorized Contact
Technical Contact
Bob Pierce
Safety and Env Manager
(910) 439-6959
Mt. Gilead, NC 27306
Guenter Heyen
President and CEO
(910) 439-6959
Mount Gilead, NC 27306
Bob Pierce
Safety and Env Manager
(910) 439-6959
Mt. Gilead, NC 27306
Application Numbers: 6200061.11A, .14A
Date Received: 07/29/2011 (.11A)
11/14/2014 (.14A)
Application Type: Renewal / Significant Mod.
Application Schedule: TV-Renewal
Existing Permit Data
Existing Permit Number: 08803/T18
Existing Permit Issue Date: 02/26/2014
Existing Permit Expiration Date: 03/31/2018
Total Actual emissions in TONS/YEAR:
CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2013
10.32
130.64
749.02
123.24
90.82
257.47
133.63
[Formaldehyde]
2012
7.69
130.66
631.41
123.17
89.07
219.40
113.53
[Formaldehyde]
2011
7.43
105.63
511.15
99.60
81.75
197.75
93.15
[Methanol (methyl alcohol)]
2010
11.23
112.13
132.45
105.81
113.88
98.63
41.67
[Formaldehyde]
2009
8.47
87.80
61.31
83.06
43.95
47.94
19.14
[Phenol]
Review Engineer: Russell Braswell
Review Engineer’s Signature:
Date:
Comments / Recommendations:
Issue 08803/T19
Permit Issue Date:
Permit Expiration Date:
Review of applications 6200061.11A, .14A
Page 2 of 10
1. Purpose of Application:
Application .11A
At the time of this application, Unilin Flooring N.V. (Unilin) held Air Quality Permit 08803T15, which was
set to expire on April 30, 2012. Since this application was received, subsequent applications and permits have
been issued and the current permit is 08803T18. The current permit is set to expire on March 31, 2018.
Unilin submitted this application in order to renew its permit. Because this renewal application was received
at least nine months before the expiration of the existing permit at that time, the current permit will remain in
effect, regardless of expiration date, until the renewal application is either approved or denied.
In addition to permit renewal, the application also addresses CAM requirements.
Application .14A
The current permit (T18) has a requirement that Unilin develop and submit an appropriate CAM plan for the
scrubber CD-SCRB. The plan was due within 270 days of the issuance of permit T18 (i.e. November 23,
2014). This application was submitted in order to satisfy that requirement.
After the initial review of the draft permit, Dale Overcash, consultant for Unilin, also requested that the
control device CD-SNCR be removed. He also suggested updates to the fabric filter CAM plan proposed in
the .11A application.
2. Facility Description:
According to the most recent inspection report, the facility manufactures high-density fiberboard from pine
chips and either urea-formaldehyde or MDI resin.
3. History/Background Since the 1st Time Title V Permit:
 May 8, 2007
Permit T06 issued. This was a First Time Title V permit.
 June 13, 2007
Application .07A received. This application was for a 2Q .0502(b)(10)
modification.
 September 24, 2007
Application .07B received. This application was for a minor modification.
Permit T07 issued in response to application .07A. This action added additional
board handling sources at the facility.
 December 4, 2007
Application .07C received. This application was for a minor modification.
 February 28, 2008
Permit T08 issued in response to application .07C. This action modified the
wood flake system at the facility.
 May 12, 2008
Application .08A received. This application was for a two-step significant
modification.
 July 3, 2008
Permit T09 issued in response to application .08A. This action allowed for
Page 3 of 10
low-temperature testing for the RTO and required that an additional application
be submitted within 12 months of operating the RTO at low temperatures.
 July 8, 2008
Application .08C received. This was a construction notice.
 July 17, 2008
Application .08C was approved. Unilin was allowed to begin constructing a
mesh-pad eliminator.
 July 18, 2008
Application .08D opened. This began an administrative amendment.
 August 4, 2008
Application .08E received. This application was for a significant modification.
 August 11, 2008
Permit T10 issued in response to application .08D. This administrative
amendment addressed concerns raised by the regional office.
 January 5, 2009
Permit T11 issued in response to applications .07B and .08E. This action
completed the two-step process begun with the T09 permit and incorporated the
mesh-pad eliminator from the .08C application. In addition, this action allowed
for reduced RTO temperatures, revised the 2D .1100 requirements in the permit,
and included the routine control device maintenance exemption (RCDME)
allowed for by MACT Subpart DDDD.
Application .09A received. This application was for a significant modification.
 March 17, 2009
Application .09C received. This application was for a two-step significant
modification.
 March 27, 2009
Permit T12 issued in response to application .09C. This action added a scrubber
to the facility and required that an additional application be submitted within 12
months of operating the new scrubber.
 November 2, 2009
Permit T13 issued in response to application .09A. This action allowed for
alternate monitoring requirements under NSPS Subpart Db and made a change
in PSD avoidance limits.
 March 27, 2009
Application Determination issued. This approved a test of a new operating
method.
 October 18, 2010
Application .10A received. This was a construction notice. The notice was
approved on October 20, 2010.
 October 18, 2010
Application .10B received. This was for a minor modification.
 October 28, 2010
Application .10C received. This was for a PSD-Major modification.
Application .10D received. This was for a significant modification.
Permit T14 issued in response to application .10B. This action added an
NG-fired evaporator and made changes to the insignificant activities list. Also,
Page 4 of 10
this action removed the sources added during the two-step process begun by
Permit T12, therefore removing the requirement to finish the two-step process.
 June 17, 2011
Permit T15 issued in response to application .10D. This action reclassified the
boilers at the facility such that they were no longer subject to NSPS Subpart Db.
 August 1, 2011
Application .11A received. This was for permit renewal.
 October 3, 2011
First Special Order by Consent (SOC) issued in response to Unilin’s difficulty
with complying with MACT Subpart DDDD due to safety issues while
operating the RTO.
Unilin submitted a toxic air pollutant modeling demonstration as part of the SOC
negotiations.
AQAB approved a modeling demonstration showing compliance with the 1-hr
formaldehyde AAL when Unilin was not operating the RTO.
 August 20, 2012
Application .12A received. This requested tax certification for some equipment
at the facility. DAQ responded on October 12, 2012.
 January 9, 2013
Application .13A received. This was for a minor modification.
 April 26, 2013
Permit T16 issued in response to application .13A. This action added another
NG-fired evaporator.
 July 24, 2013
Permit T17 issued in response to application .10C. This action dealt with the
removal of the RTO which triggered a PSD review for VOC emissions. This also
classified the facility as PSD-Major. Additionally, the SOC was incorporated
into the permit.
Permit application (.13B) opened to address compliance with MACT Subpart
DDDD and also to investigate the removal of TAP emission limits per Session
Law 2012-19.
The SOC was revised (1st revision). This revision addressed the ability for
Unilin to operate the facility without operating the RTO.
Permit T18 issued in response to application .13B. This action removed all TAP
limits from the permit and incorporated a compliance schedule into the permit as
part of the SOC.
 May 23, 2014
The SOC was revised (2nd revision). This revision addressed Unilin's plans for
achieving compliance through material reformulation and new control devices.
New SOC issued (2014-001). This new SOC addressed Unilin's ongoing efforts
for material reformulation.
4. Application Chronology:
Page 5 of 10
(Some points are repeated from Section 3.)
 July 29, 2011
Application .11A received.
Gregory Reeves, from the Fayetteville Regional Office, sent comments on the
application.
 October 7, 2014
Responsibility for application .11A transferred to Russell Braswell
 October 7, 2014
FRO submitted updated comments on the application.
 October 13, 2014
Email sent to Unilin regarding the applicability of NSPS Subpart Kb. Bob
Pierce responded by phone call on October 17, 2014.
 October 20, 2014
An initial draft of the permit and review were sent to DAQ staff (Mark Cuilla,
William Willets, Samir Parekh, Steven Vozzo, Jalal Adouli, Greg Reeves),
Unilin staff (Guenter Heyen, Bob Pierce), and Trinity Consultants staff (Dale
Overcash). For a summary of comments received, see Attachment 2.
 October 22, 2014
Due to the ongoing negotiations regarding the facility's SOC, the renewal
process was put on hold.
 November 14, 2014
Application .14A received. This application was submitted in response to
certain permit requirements in the existing permit.
New SOC issued (2014-001).
Email sent to Dale Overcash regarding clarification of the comments he
submitted on the initial draft. He responded by email later that day.
A second draft of the permit and review were sent to DAQ staff, Unilin staff, and
Trinity Consultants. For a summary of comments received, see Attachment 3.
 March 11, 2015
Dale Overcash, in his comments on the second draft, requested that the control
device CD-SNCR be removed from the permit. He also provided updated
pressure drop numbers for the bagfilter CAM plan.

XXXXX
Public notice
5. Permit Modifications/Changes and TVEE Discussion:
The renewal application states that the storage tanks at the facility are no longer subject to NSPS Subpart
Kb due to changes in that regulation. The vapor pressure of the materials stored is below the threshold
listed in 60.110b(b). Bob Peirce, in a phone call on October 17, 2014, confirmed that the information
submitted in 2011 is still accurate. Therefore, NSPS Subpart Kb will be removed from the permit.
The renewal application also includes proposed a proposed CAM plan for several bagfilters associated with
wood-handling sources. The .14A application includes updates to the CAM plan for ES-HP. These updates
are discussed in Section 7.
Page 6 of 10
During the review of the initial draft permit, Dale Overcash requested that CD-SNCR be removed.
According to the comments, the device has not been operated in over ten years, and Unilin has no plans to
reactivate it.
The list of changes to the permit can be found in Attachment 1.
6. Regulatory Review:
Unilin is subject to the following regulations, in addition to the requirements in the General Conditions:
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15A NCAC 2D .0504 "Particulates from Wood Burning Indirect Heat Exchangers"
15A NCAC 2D .0512 "Particulates from Miscellaneous Wood Products Finishing Plants"
15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes"
15A NCAC 2D .0516 "Sulfur Dioxide from Combustion Sources"
15A NCAC 2D .0521 "Control of Visible Emissions"
15A NCAC 2D .0530 "Prevention of Significant Deterioration"
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 Subparts DDDD, ZZZZ)
15A NCAC 2Q .0508(m) "Permit Content"
(Special Order by Consent)
15A NCAC 2Q .0512 "Permit Shield and Application Shield"
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. For some regulations below more discussion is provided
for clarification and background, where necessary. The permit will be updated to reflect the most current
stipulations for all applicable regulations.
For discussions of NSPS, MACT, PSD, and CAM requirements, see Section 7.
a. 15A NCAC 2Q .0508(m) "Permit Content" (Special Order by Consent)
Due to the nature of operations at the facility, Unilin decided it was no longer capable of safely
operating the RTO. Because the RTO was necessary to comply with MACT Subpart DDDD, an SOC
was issued that dealt with Unilin's plans to re-attain compliance with the regulation. After being issued,
the SOC has been revised several times.
The most recent revision to the SOC (2014-001) was issued on December 21, 2014. The SOC requires
that Unilin either convert to MDI-based resins or install additional control technology to control
formaldehyde emissions. The deadline is December 31, 2016. The SOC requires quarterly reporting of
product produced using MDI-based resins, formaldehyde emissions, and progress made towards MDI
conversion.
Compliance with the requirements of the SOC will be evaluated as Unilin submits reports and
approaches the compliance deadline.
7. NSPS, MACT/GACT, PSD/NSR, 112(r), RACT, CAM:
Page 7 of 10
a. NSPS
1. Subpart Db
According to the T15 review (Charlie Yirka, June 17, 2011), the heating plant is a process heater,
not a boiler. Therefore, it is not subject to NSPS Subpart Db.
2. Subpart Kb
The storage tanks at the facility are not subject to NSPS Subpart Kb. 40 CFR 60.110b(b) states that
for tanks with capacities 75 ≤ C < 151 m3 (which is the case for all tanks at the facility), liquids with
a true vapor pressure less than 15 kPa are not subject. Based on the application, the liquids stored at
the facility have a vapor pressure of either 2.93 kPa or 3.17 kPa. Therefore, they are not subject to
the regulation.
b. MACT/GACT
1. Subpart DDDD
This regulation applies to facilities that manufacture composite wood products, such as fiberboard.
Unilin has chosen to comply with the regulation by achieving at least a 90% reduction in
formaldehyde emissions. In order to demonstrate compliance, Unilin must operate a continuous
parameter monitoring system (CPMS) that will monitor control device parameters and compare
them to their allowable values. Those values must be established in testing. Records of
maintenance and monitoring must be kept and regularly reported.
After removing the RTO, Unilin has been unable to comply with the MACT. An SOC was issued
that dealt with Unilin's plans to re-attain compliance. The SOC has been revised based on issues
raised when Unilin began implementing the required changes under the SOC.
According to the T11 review (Joe Voelker, January 5, 2009), there are no emission sources subject
to the work practice requirements because Unilin does not have any processes listed in Table 3 of
the regulation. Therefore, the no references to work practice requirements are included in the
permit.
Unilin currently is not in compliance with MACT Subpart DDDD. After implementing the
changes required by the SOC, it is expected that Unilin will be in compliance with the regulation.
The permit stipulation has been updated to reflect the emission tests that Unilin has recently
performed. No other changes to the stipulation have been made.
2. Subpart ZZZZ
This regulation applies to all stationary reciprocating internal combustion engines (RICE). All of
the RICE at this facility are considered emergency-use.
The only requirements for emergency-use engines that have a capacity less than 500 horsepower
are: regular required maintenance, install a non-resettable hour meter, and keep records of all
maintenance activities. While no reporting for these generators is required by the MACT, 15A
NCAC 2Q .0508(f)(1) requires that all monitoring activities be reported twice per year.
Page 8 of 10
Based on the most recent inspection report, Unilin appears to be complying with the regulation.
The permit has been updated with the most recent wording of the regulation.
3. Subpart DDDDD
According to the T06 permit review (Mark Cuilla, May 8, 2007), the heating plant does not meet
the definition of process heater as listed in the regulation. This is because the exhaust gasses
produced by the heating plant come into direct contact with the material being heated. Therefore,
the heating plant is not subject to MACT Subpart DDDDD.
c. PSD/NSR
The facility has triggered PSD for VOC emissions. The permit includes a BACT limit for combined
VOC emissions from ES-HP, ES-DRY, ES-BP, and ES-RFN. In order to comply with the emission
limit, Unilin must operate the control device CD-SCRB. The permit does not include any other
compliance requirements.
d. 112(r)
According to Unilin, there are no 112(r)-subject materials being stored above their respective
thresholds. Therefore, Unilin does not have any additional requirements under 112(r) of the Clear 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
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 permit renewal application, the following emission sources and control devices are
subject to CAM:
Emission Source(s)
ES-HP, ES-BP, ES-DRY, ES-RFN
ES-21
ES-22
ES-23
ES-31
ES-32
ES-33
ES-34
Control Device(s)
CD-SCRB
CD-CY21, CD-FF21
CD-CY22, CD-FF22
CD-CY23A, CD-CY23B, CD-FF23
CD-FF31
CD-FF32
CD-FF33
CD-CY34, CD-FF34
Pollutant
Particulate
Particulate
Particulate
Particulate
Particulate
Particulate
Particulate
Particulate
Regulation(s)
2D .0504, 2D .0504, 2D .0515
2D .0512
2D .0512
2D .0512
2D .0512
2D .0512
2D .0512
2D .0512
Page 9 of 10
Emission Source(s)
ES-FHS
Control Device(s)
CD-CYFHS, CD-FF-23
Pollutant
Particulate
Regulation(s)
2D .0512
1. ES-HP, ES-BP, ES-DRY, ES-RFN
The T18 permit included a requirement that Unilin submit a CAM plan for the emission sources
ES-HP, ES-BP, ES-DRY, and ES-RFN. For this requirement, Unilin submitted application .14A,
which proposed to use total scrubber flowrate as the monitored parameter. In July 2014, Unilin
established that 270.0 gallons per minute is the minimum acceptable flow rate. Unilin has installed
a flowmeter to measure the parameter and will electronically monitor the flowrate on a continuous
basis. The application states that the monitoring system will average the collected data over an
hour, as allowed by 40 CFR 64.3(b)(4)(ii).
2. ES-21, ES-22, ES-32, ES-31, ES-32, ES-33, ES-34, ES-FHS
The .11A permit application included a proposed CAM plan for the above sources. Unilin plans to
monitor the pressure drop across the fabric filters associated with each emission source. Note that
for each emission source, the fabric filters are the final control devices before exhausting to the
atmosphere. The application bases the acceptable range of pressure drops on manufacturer's
information. Unilin has installed pressure gauges that can monitor the pressure drop on a
continuous basis. The application states that the monitoring system will average the collected data
over a day, as allowed by 40 CFR 64.3(b)(4)(i).
In comments provided on the initial draft permit, Dale Overcash indicated that the information in
the .11A application is now outdated. The acceptable maximum pressure drop for each bagfilter is
actually 10 inches of water.
8. Toxic Air Pollutants
With the T18 permit (see Charlie Yirka's T18 review, dated February 26, 2014), it was determined that no
TAP regulations are required for this facility. This was based on Session Law 2012-91.
9. Facility Emissions Review
This permit renewal will not change potential emissions from the facility. For a record of recent actual
emissions from the facility, see the table on the first page of this review.
10. Compliance Status
1. Notices of Violation/Recommendation for Enforcement since the previous renewal

April 12, 2011
NOV issued for deactivation of the RTO. This action initiated an SOC for
compliance with MACT Subpart DDDD.

December 10, 2012
Complaint regarding fibers falling on neighboring areas. Investigated, but
no NOV issued.

June 10, 2014
NOV issued for failure to comply with the SOC.
2. Inspection status
Page 10 of 10
The facility was most recently inspected on April 23, 2014. The facility was in violation of MACT
Subpart DDDD, but was complying with all other aspects of the permit. The facility was also in
compliance with its SOC at that time.
11. Other Regulatory Concerns
A PE seal was not required for this permit renewal or for the CAM plan modification.
A zoning consistency form was not required for this permit renewal or for the CAM plan modification.
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 08803T19.
Attachment 1
Change List
Section
Throughout
New Condition
Page No.
Throughout
Changes
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Permitted Emission
Source List
3
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2.1.E
2.1.B
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2.2.B
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2.2.B.2
2.2.C
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2.2.D
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2.2.D.1
2.2.4
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Updated dates
Updated permit numbers
Fixed typos
Updated permit wording to latest DAQ-approved
wording.
Removed all references to 15A NCAC 2D .1100, 2Q
.0705, and 2Q .0711.
Removed all references to NSPS Subpart Kb.
Removed references to past-due dates.
Removed references to CD-SNCR
Included CAM callouts in equipment list
Removed control device associations (e.g. "in parallel
with") from control device list. These are included in the
body of the permit.
Removed CD-SNCR per applicant's request.
Updated CD-SCRB's injection rate to 270, per emission
testing.
Updated permit stipulation for MACT Subpart ZZZZ
Removed reference to initial testing because it has been
completed.
Made section 2.2.B. for regulations that apply
specifically to ES-HP, ES-DRY, ES-BP, and ES-RFN
Updated CAM for heating plant.
Made Section 2.2.C. for sources subject to MACT
Subpart DDDD
Removed reference to initial testing because it has been
completed.
Added Section 2.2.D. for wood handling sources subject
to CAM.
Added CAM plant for wood handling sources.
Updated stipulation to reflect the latest SOC
Attachment 2
Comments Received on Initial Draft
Dale Overcash, by email, on October 24, 2014
1. The permit and review list an incorrect "application received" date for application .11A.
Response: Fixed.
2. Mr. Overcash asked why wording such as "in series with" was removed from the control device
descriptions in the Permitted Emission Source List.
Response: The new DAQ format for the equipment list is to only list the control devices and their sizes.
Information such as nature of their connections (e.g. "in series with") is left to the section
headers in the permit.
3. For some section headers, an asterisk was added indicating that additional information regarding
control device operation could be found in specific permit conditions. Mr. Overcash pointed out that
these additional cross-references were confusing and unnecessary.
Response: After reading Mr. Overcash's comments, I agree. I have removed these asterisks and
references.
4. Mr. Overcash suggested rewrites of several paragraphs regarding emission testing schedules. These
sources have completed their initial testing and now only have subsequent biennial testing.
Response: I have updated these testing paragraphs.
5. Mr. Overcash pointed out that the original renewal application included a CAM plan for both the
heating plant and also several wood handling sources. Only the heating plant CAM plan was included
in the permit
Response: I have fixed this oversight. The permit now includes a CAM plan for the subject wood
handling sources.
6. Mr. Overcash pointed out several cross-reference errors throughout the permit.
Response: Fixed.
7. Mr. Overcash stated that Unilin had not installed any control devices for the emergency engines.
Therefore, the permit stipulation for MACT Subpart ZZZZ should not reference "air pollution control
equipment". Furthermore, MACT Subpart ZZZZ does not require reporting for emergency engines.
Response: References to "air pollution control and monitoring equipment" have been removed from
the MACT Subpart ZZZZ stipulation.
While MACT Subpart ZZZZ does not require any regular reporting for emergency engines,
15A NCAC 2D .0508(f)(1) specifically requires that any monitoring be reported twice per
year at a minimum.
Attachment 2, cont.
8. MACT Subpart DDDD should not reference the SOC due to potential future changes to the SOC.
Response: At the time of permit issuance, the SOC is an important aspect of compliance with MACT
Subpart DDDD. Given that Unilin is not in compliance with the MACT permit stipulation,
there should be some indication that Unilin has additional requirements to address
compliance.
9. Unilin is not subject to the work practice requirements in MACT Subpart DDDD. The processes
subject to work practice requirements are listed in Table 3 to the Subpart, and there are no such
processes at the facility.
Response: References to work practices have been removed from the permit stipulation.
10. The SOC section of the permit should not include the revision number, date, and other specifics
regarding the SOC. The SOC may change in the future and the permit could then be inaccurate.
Response: 15A NCAC 2Q .0508(m) requires that the SOC be included in the permit. Rather than
include the entire SOC verbatim, I have instead only included reference to the current SOC
number.
11. In the review, Mr. Overcash suggested several corrections for the Permit History, Application
Chronology, PSD, and NSPS sections.
Response: These corrections have been incorporated.
Attachment 3
Comments Received on Second Draft

Samir Parekh, by email, on February 19, 2015
1. Samir pointed out that that the flowrate of the scrubber had been updated to 270 GPM, but the permit
still had references to the old flowrate.
Response: Fixed.
2. Samir pointed out that the QIP threshold was not properly written into the permit. The permit was
written as though the data will be sampled continuously, when in fact the data will be gathered on an
hourly basis.
Response: When writing the permit, I had misunderstood the requirements of the QIP threshold.
Based on the application, I have decided not to include a QIP threshold in the permit. In a
follow-up conversation, Samir agreed that the QIP threshold did not need to be included in
the permit.
3. Samir pointed out that that the reporting requirement associated with the CAM plans did not explicitly
meet all the requirements of 40 CFR 64.9. He provided additional language to include in those
sections.
Response: Fixed.

Mark Cuilla, by email, on February 26, 2015
1. Mark pointed out minor typos throughout the permit and review.
Response: Fixed.
2. Mark disagreed with the History/Background section in the review. This section indicated that
application .10B (a minor modification) was used to conclude a 2-step permit process.
Response: After a closer look into the permit history, I found that .10B removed all of the sources
added during the first step of the 2-step permit process, removing the need to finish the
process. I have reworded the review to make this clearer.
3. Mark requested that more detail be given to the history of SL 2012-91 and the SOC revisions in the
permit review.
Response: Added.
4. Mark requested that the MACT DDDD section in the permit review be reworded for better clarity.
Response: Added.
Attachment 3, cont.

Dale Overcash, by email, on March 11, 2015
1. Mr. Overcash requested that CD-SNCR be removed from the permit because it has not been operated in
several years.
Response: Done.
2. Mr. Overcash provided updated pressure drop data for the bagfilter CAM plans.
Response: This has been incorporated into the permit.
3. Mr. Overcash requested that CD-SNCR be removed from the permit because it has not been operated in
several years.
Response: Done.
4. Mr. Overcash provided minor corrections to the wording of the CAM plans.
Response: This has been incorporated into the permit.
5. Mr. Overcash again requested that semiannual reporting not be required as part of MACT Subpart
ZZZZ.
Response: DAQ's position remains the same: 15A NCAC 2D .0508(f) requires that any monitoring
activities be reported twice per year, at a minimum.

Permit Review - Division of Air Quality

Transcription

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