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 149 Homanit USA Road Mt. Gilead, NC 27306 Guenter Heyen President and CEO (910) 439-6959 149 Homanit USA Road Mount Gilead, NC 27306 Bob Pierce Safety and Env Manager (910) 439-6959 149 Homanit USA Road 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 Unilin Flooring N.V. 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. September 27, 2007 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 Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. February 17, 2009 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. December 20, 2010 Application .10D received. This was for a significant modification. December 22, 2010 Permit T14 issued in response to application .10B. This action added an NG-fired evaporator and made changes to the insignificant activities list. Also, Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. December 2, 2011 Unilin submitted a toxic air pollutant modeling demonstration as part of the SOC negotiations. December 19, 2011 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. September 5, 2013 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. September 5, 2013 The SOC was revised (1st revision). This revision addressed the ability for Unilin to operate the facility without operating the RTO. February 26, 2014 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. December 21, 2014 New SOC issued (2014-001). This new SOC addressed Unilin's ongoing efforts for material reformulation. 4. Application Chronology: Review of applications 6200061.11A, .14A Unilin Flooring N.V. Page 5 of 10 (Some points are repeated from Section 3.) July 29, 2011 Application .11A received. September 13, 2011 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. December 21, 2014 New SOC issued (2014-001). February 2, 2015 Email sent to Dale Overcash regarding clarification of the comments he submitted on the initial draft. He responded by email later that day. February 26, 2015 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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: 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: Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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 Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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 Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. Attachment 1 Change List Section Throughout New Condition Page No. Throughout Changes Permitted Emission Source List 3 2.1.E 2.1.B 2.2.B 2.2.B.2 2.2.C 2.2.D 2.2.D.1 2.2.4 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 Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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. Review of applications 6200061.11A, .14A Unilin Flooring N.V. 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.
© Copyright 2018