NORTH CAROLINA DIVISION OF 
AIR QUALITY
                              Application Review

Issue Date:  May 9, 2018
Region:  Asheville Regional Office
County:  Caldwell
NC Facility ID:  1400027
Inspector's Name:  Mike Parkin
Date of Last Inspection:  08/16/2017
Compliance Code:  3 / Compliance - inspection
Facility Data

Applicant (Facility's Name):  Heritage Home Group, LLC - Thomasville Furniture Industries, Inc. - Lenoir Plant

Facility Address:
Heritage Home Group, LLC - Thomasville Furniture Industries, Inc. - Lenoir Plant 315 Elizabeth Street NW
Lenoir, NC       28645

SIC: 2511 / Wood Household Furniture 
NAICS:   337122 / Nonupholstered Wood Household Furniture Manufacturing

Facility Classification: Before:  Title V  After:  Title V  
Fee Classification: Before:  Title V  After:  Title V  
Permit Applicability (this application only)

SIP:  02D .0503, .0504, .0512, .0516, .0521, .0530 and .0614.
02Q .0317 Avoidance of 02D .1111: MACT
NSPS:  
NESHAP: Subpart ZZZZ and JJJJJJ
PSD:  
PSD Avoidance:  
NC Toxics:  
112(r):  
Other: 
Remove: 02D .1109, 02D .1111 Subparts JJ and DDDD and 02Q .0705
Contact Data
Application Data

Application Numbers:  1400027.16A and .17A
Dates Received:  12/21/2016 and 03/27/2017
Application Type:  Renewal
Application Schedule:  TV-Renewal
Existing Permit Data
Existing Permit Number:  04172/T25
Existing Permit Issue Date:  02/03/2014
Existing Permit Expiration Date:  10/31/2017
Facility Contact

David Stout
Director of Environmental Compliance
(828) 759-8510
PO Box 640
Lenoir, NC 28645
Authorized Contact

Luke Barger
Plant Manager
(828) 757-2742
PO Box 640
Lenoir, NC 28645
Technical Contact

David Stout
Director of Environmental Compliance
(828) 759-8510
PO Box 640
Lenoir, NC 28645

  Total Actual emissions in TONS/YEAR:
                                      CY
                                      SO2
                                      NOX
                                      VOC
                                      CO
                                     PM10
                                   Total HAP
                                 Largest HAP 
                                     2016
                                        1.26
                                       24.68
                                      179.23
                                       30.22
                                       12.77
                                       13.30
                                        5.55
                                   [Toluene]
                                     2015
                                        1.15
                                       22.72
                                      123.23
                                       27.82
                                       10.39
                                       11.90
                                        5.11
                                   [Toluene]
                                     2014
                                        1.12
                                       21.94
                                      177.26
                                       26.86
                                       10.33
                                       15.29
                                        6.74
                                   [Toluene]
                                     2013
                                       16.05
                                       20.30
                                      158.13
                                       20.90
                                        8.68
                                       14.51
                                        6.37
                                   [Toluene]
                                     2012
                                       20.11
                                       20.17
                                      226.97
                                       20.79
                                        9.35
                                       19.00
                                        8.60
                                   [Toluene]

                                                                               
 Review Engineer:  Brian Bland

 Review Engineer's Signature:                Date:  May 9, 2018



                          Comments / Recommendations:
Issue 04172/T26
Permit Issue Date:  May 9, 2018
Permit Expiration Date: April 30, 2023

   

1.     Purpose of Application

Heritage Home Group, LLC - Thomasville Furniture Industries, Inc. - Lenoir Plant (HHG) manufactures and finishes wooden case goods furniture for the brands of Heritage Home Group.  The primary emission sources at the facility include wood furniture finishing operations, wood dust collection systems, and two Wood/No. 2 fuel oil/Natural Gas/Liquefied Petroleum Gas-fired boilers.  

Application No. 1400027.16A, received on December 21, 2016, was submitted for a renewal of an existing Title V permit.  Application No. 1400027.17A, received on March 27, 2017, was submitted as a signification modification for the purpose of the facility being classified as minor for Hazardous Air Pollutants (HAPs).  The existing Title V permit was scheduled to expire on October 31, 2017.  Because the renewal application was received at least nine months prior to the expiration date, the existing permit shall not expire until the renewal permit has been issued or denied.  All terms and conditions of the existing permit shall remain in effect until the renewal permit has been issued or denied.  

2.     Application Chronology

   December 21, 2016		Application No. 1400027.16A received for renewal of Air Permit No. 04172T25.  
   
   March 27, 2017		Application No. 1400027.17A requesting a modification for the purpose of classifying the facility as minor for HAPs was received.  The facility requested that this application be consolidated with the previously submitted renewal application.
   
   January 22, 2018		Facility submitted a request to move permit item ID No. DFE "One diesel-fired emergency fire pump (190 hp)" to the insignificant activities list.
   
   January 31, 2018		Facility submitted a request to remove MACT applicability based on a January 25, 2018 U.S. Environmental Protection Agency (EPA) memo changing EPA's "once in always in" MACT guidance.
   
   February 26, 2018		Draft permit and review document forwarded to Asheville Regional Office (ARO) and Samir Parekh (SSCB) for comments.
   
   February 26, 2018		Draft permit forwarded to Permittee for comments.
   
   March 9, 2018		Comments received from Permittee that they are fine with the draft permit.
   
   March 12, 2018 		Comments received from ARO.  No changes were necessary.
   
3.     Changes to Existing Permit

The following changes were made to Air Permit No. 04172T25:

                                  New Page(s)
                                    Section
                           Description of Change(s)
                                  Attachment
                           Insignificant Activities
Add note 3 "Specific Permit Conditions Regulatory Guide"  
Move "One diesel-fired emergency fire pump" (now ID No. I-DFE) from permitted items
                                      All
                                      All
Update dates and permit revision number
Correct typographical, grammatical and technical errors
Replace "2D" and "2Q" with "02D" and "02Q"
Update formatting to current template
                                       3
                                Permitted Items
Remove note associated with 15A NCAC 02Q .0515 minor modification (Application No. 1400027.13A) to allow burning of No. 2 fuel oil/natural gas/liquefied petroleum gas in boilers (ID Nos. ES-BL1 and ES-BL2)

Replace Case-by-Case MACT with GACT JJJJJJ for the boilers (ID Nos. ES-BL1 and ES-BL2)

Remove MACT Subpart DDDD and Subpart JJ tags from previously applicable emission sources
                                       9
                                     2.1 B
Replace Case-by-Case MACT with GACT JJJJJJ for the boilers (ID Nos. ES-BL1 and ES-BL2)

Correct alternative operating scenarios requirement citation to 15A NCAC 02Q .0508(j) and move to Section 2.1 B. 1
                                      N/A
                                     2.1 C
Move "One diesel-fired emergency fire pump" (previously ID No. DFE) to Insignificant Activities lists
                                      16
                            2.1 F. (revision T25)/
                             2.1 C (revision T26)
Move section 2.1 F to 2.1 C and correct cross references as needed
                                      19
                                 2. 1 C. 3. d
Remove 15A NCAC 02D .0521 from CAM-applicable regulations 
Add details of required report content
                                      20
                                  2.1 D table
Remove MACT Subpart JJ
                                      23
                                  2.1 E table
Remove MACT Subpart DDDD 
                                      N/A
                             2.2 A (revision T25)
Remove MACT Subpart JJ requirements
                                      24
                                    2.2 A 
Add 15A NCAC 02Q .0317 - Avoidance of 15A NCAC 02D .1111: MACT condition
                                      N/A
                            2.2 B. 1 (revision T25)
Remove 15A NCAC 02Q .0705 as this rule was repealed on May 1, 2014
                                      26
                                       3
Update General Conditions to current version

4.     Compliance History

On August 16, 2017, Mike Parkin of the ARO conducted an onsite compliance inspection at the facility, and determined that "The facility appeared to be operating in compliance with Air Permit No. 04172T25 at the time of inspection."

5.     Regulatory Review

The facility will be subject to the following regulations:
15A NCAC 02D .0503, Particulates from Fuel Burning Indirect Heat Exchangers
15A NCAC 02D .0504, Particulates from Wood Burning Indirect Heat Exchangers
15A NCAC 02D .0512, Particulates from Miscellaneous Wood Products
15A NCAC 02D .0515, Particulates from Miscellaneous Industrial Processes
15A NCAC 02D .0516, Sulfur Dioxide Emissions from Combustion Sources
15A NCAC 02D .0521, Control of Visible Emissions
15A NCAC 02D .0530, Prevention of Significant Deterioration
15A NCAC 02D .0614, Compliance Assurance Monitoring 
15A NCAC 02D .1111, Maximum Achievable Control Technology (40 CFR 63, Subparts ZZZZ and JJJJJJ)
15A NCAC 02Q .0317 Avoidance of 15A NCAC 02D .1111, Maximum Achievable Control Technology


As a result of no longer being major for HAPs, the facility is no longer subject to the following regulations:
15A NCAC 02D .1109, Case-by-Case Maximum Achievable Control Technology
15A NCAC 02D .1111, Maximum Achievable Control Technology (40 CFR 63, Subparts DDDD and JJ)

Removed from the permit because this rule was repealed on May 1, 2014:
15A NCAC 02Q .0705, Existing Sources and SIC Calls

Moved from permit to insignificant activities list 
One diesel-fired emergency fire pump (190 hp, previously ID No. DFE) moved to the insignificant activities list as ID No. I- DFE.

Based on the fire pump's 190 horsepower and 500 hours of maximum operation per year, the potential emissions of each criteria pollutants are less than 5 tpy. This source is still subject to GACT Subpart ZZZZ. 

Background on removal of MACT requirements
In 1995 the EPA issued a policy memorandum commonly referred to as "Once-In-Always-In."  The policy provides that a source can avoid the applicability of an otherwise applicable MACT standard only if the source reduces its potential to emit before the first substantive compliance date of the MACT. The EPA acknowledged at that time that it intended to "follow this guidance memorandum with rulemaking actions to address these issues. The Agency intends to include provisions on potential to emit timing in future MACT rules and amendments to the section 112 general provisions." To date, with limited exception, the EPA has not initiated rulemaking to codify the interpretations contained in the memorandum. Consequently, the "Once-In-Always-In" policy has been inconsistently applied among States and Local agencies, as well as EPA Regional Offices.

However, on January 25, 2018 an EPA memorandum from William L. Wehrum, Assistant Administrator, titled Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act was issued.  This memorandum clarified EPA's position that "...a source that was previously classified as major, and which so limits its PTE, will no longer be subject either to the major source MACT or other major source requirements that were applicable to it as a major source under CAA section 112."

HHG meets this criterion and will no longer be subject to the NESHAPs for: 1) Plywood and Composite Wood Products (40 CFR 63 Subpart DDDD) 2) Wood Furniture Manufacturing Operations (40 CFR 63 Subpart JJ)
upon the issuance of Air Permit No. 04172T26 with a federally enforceable avoidance condition for HAPs.  HHG will also no longer be subject to 15A NCAC 02D .1109, 112(j) Case-by-Case MACT for Boilers & Process Heaters (also referred to as the Case-by-Case MACT in this review). However, as a minor source of HAPs, HHG will be subject to the National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers (40 CFR 63 Subpart JJJJJJ).

Note: Emissions of N. C. air toxics are not increased, and are not being reviewed, with this permitting action.  However, future modifications that result in an increase in N. C. air toxics emissions may trigger a review of previously exempt sources.
	
15A NCAC 02Q .0317 Avoidance Conditions  -  Limitation to Avoid being Major for HAPs  -  The facility has requested to be a minor (or area) source for HAPs.  Limits be placed in their permit for HAPs of less than 10 tons per year (tpy) and less than 25 tpy of any combination of HAPs or total HAPs on a facility-wide basis.  

As shown in the table below, the facility's actual HAP emissions reported in their three most recent (2014-2016) emissions inventory are well below the 10/25 tpy threshold.  Therefore, with the appropriate 15A NCAC 02Q .0317 monitoring, recording and record keeping added to the permit, no exceedance of the HAP minor limitations is expected.


                                 Calendar Year
                                  Largest HAP
                               Total HAPs (tpy)
                                     2014
                               Toluene: 6.74 tpy
                                     15.29
                                     2015
                               Toluene: 5.11 tpy
                                     11.90
                                     2016
                               Toluene: 5.55 tpy
                                     13.30

6.     NSPS, NESHAPS/MACT, NSR/PSD, 112(r), CAM

NSPS
 The Permittee is not currently subject to any New Source Performance Standards.  This permit modification does not affect this status.
 
 NESHAP/MACT/GACT
The Permittee will remain subject to NESHAP ZZZZ (Stationary Reciprocating Internal Combustion Engines), and will become subject to NESHAP JJJJJJ (Industrial, Commercial, and Institutional Boilers). 

As a result of no longer being major for HAPs, the facility is no longer subject to the following regulations:
15A NCAC 02D .1109, Case-by-Case Maximum Achievable Control Technology
15A NCAC 02D .1111, NESHAP for Plywood and Composite Wood Products (40 CFR 63, DDDD)
15A NCAC 02D .1111: NESHAP for Wood Furniture Manufacturing Operations (40 CFR 63, Subpart JJ)

As a minor source of HAPs, HHG will now be subject to NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers (40 CFR 63 Subpart JJJJJJ).

15A NCAC 02D .1111-  NESHAP (GACT JJJJJJ) for Area Sources: Industrial, Commercial, and Institutional Boilers

Boilers ID Nos. ESBL1 and ESBL2:
This Subpart applies to new, reconstructed, or existing industrial, commercial, and institutional boilers located at an area source [§63.11194(a)(1)].  These affected sources are classified as existing sources. [§63.11194(c)]

As part of this modification, the 112j case-by-case MACT condition in the permit was replaced the language with GACT JJJJJJ template language.  

Compliance Dates
For an existing boiler subject to a biennial tune-up requirement, the first biennial tune-up must be completed upon issuance of permit.  [40 CFR 63.11196(a)(1), 63.11210(c), (j)].  

The Permittee shall comply with the energy assessment requirement upon issuance of permit.  [40 CFR 63.11196(a)(3), 63.11210(c), (j)]

Recent ARO inspection reports indicate that the facility "...forwarded a copy of an energy assessment done on June 10, 2013 on the boilers at the facility.  The assessment was performed by personnel from NC State University."  On February 14, 2018, ARO confirmed via e-mail that they did get a copy of the energy assessment and it does meet the requirements of JJJJJJ.

The Permittee shall submit a Notification of Compliance Status within 120 days of the source becomes subject to the standard. [§63.11225(a)(4)] 

Performance Tune-up Requirements 
Each biennial tune-up shall be conducted no more than 25 months after the previous tune-up.

The Permittee shall conduct the tune-ups while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up.

Tune-up shall meet the items requirements of §63.11223(b).

Recordkeeping 
The Permittee shall maintain on-site and submit if requested by the Administrator, a report containing the following information:

 As required in 40 CFR 63.10(b)(2)(xiv), the Permittee shall keep a copy of each notification and report that was submitted to comply with this rule and all documentation supporting any Notification of Compliance Status that was submitted.
 The Permittee shall keep a copy of each boiler energy assessment report.
 Records of the occurrence and duration of each malfunction of the boiler or of the associated air pollution control and monitoring equipment.
 Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions, including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. 
 For operating units that combust non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR 241.3(b)(1), the Permittee shall keep a record which documents how the secondary material meets each of the legitimacy criteria under 40 CFR 241.3(d)(1). If you combust a fuel that has been processed from a discarded non-hazardous secondary material pursuant to 40 CFR 241.3(b)(4), you must keep records as to how the operations that produced the fuel satisfies the definition of processing in 40 CFR 241.2 and each of the legitimacy criteria in 40 CFR 241.3(d)(1). If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR 241.3(c), you must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary materials as fuel per 40 CFR 241.4, you must keep records documenting that the material is a listed non-waste under 40 CFR 241.4(a).

The Permittee shall keep the following records to document conformance with the performance tune-ups:
 Records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned.
 The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler.
 A description of any corrective actions taken as a part of the tune-up of the boiler.
 The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, 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.
  
The records must be in a form suitable and readily available for expeditious review. The Permittee shall keep each record for 5 years following the date of each recorded action. The Permittee shall keep each record on-site or be accessible from a central location by computer or other means that instantly provide access at the site for at least 2 years after the date of each recorded action. The Permittee may keep the records off site for the remaining 3 years. 

Reporting
The reporting requirements of 40 CFR 63.11225(b) shall be met by complying with General Condition P of Section 3 (Compliance Certification) of the air permit.

NSR/PSD
 The facility is a major stationary source for PSD. This permit modification does not affect this status.

112(r)
The facility is not subject to Section 112(r) of the Clean Air Act requirements because it does not store any of the regulated substances in quantities above the thresholds in the Rule.  This permit renewal does not affect this status.

CAM
40 CFR 64 requires that a continuous compliance assurance monitoring plan be developed for all equipment located at a major facility, that have pre-controlled emissions above the major source threshold, and use a control device to meet an applicable standard.  As part of this permit renewal, 15A NCAC 02D .0521 was removed from the applicable regulations, and the cyclone (ID No. CDCY18) preceding the bagfilter (ID No. CDBF18) was removed from the control technology list.  The following table indicates the current equipment/control device linkages:
                                Emission Source
                                    ID No.
                          Emission Source Description
                                Control Device
                                    ID No.
                          Control Device Description
ESDS1
Wood working operation
CDCY1
CDBF1

CDCY2
CDBF2

CDCY3
CDBF3

CDCY4
CDBF4

CDCY5
CDBF5

CDCY6
CDBF6

CDCY7
CDBF7

CDBF8

CDCY8
CDBF8

CDCY11
CDBF11

CDCY12
CDBF12
CDBF9
CDCY13
CDBF13
One cyclone (192 inches in diameter)
One bagfilter (4,800 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (4,800 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (5,700 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (4,800 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (3,825 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (3,825 square feet in filter area)
One cyclone (192 inches in diameter)
One bagfilter (3,825 square feet in filter area)
One bagfilter (3,225 square feet in filter area)
One cyclone (96 inches in diameter)
One bagfilter (3,225 square feet in filter area)
One cyclone (96 inches in diameter)
One bagfilter (1,155 square feet in filter area)
One cyclone (96 inches in diameter)
Two bagfilters (1,155 square feet in filter area, each)
One cyclone (96 inches in diameter)
One bagfilter (1,902 square feet in filter area)
ESDS2
Wood working operation
CDCY10
CDBF10
One cyclone (160 inches in diameter)
One bagfilter (3,825 square feet in filter area)
ESBL1
GACT JJJJJJ
Wood/No. 2 fuel oil/Natural Gas/Liquefied Petroleum Gas-fired boiler (35 million Btu per hour maximum permitted heat input rate, no flyash reinjection)
CDMC1a
CDMC1b
Two multicyclones (20 nine-inch diameter tubes)
ESBL2
GACT JJJJJJ
Wood/ Wood/No. 2 fuel oil/Natural Gas/Liquefied Petroleum Gas-fired boiler (35 million Btu per hour maximum permitted heat input rate, no flyash reinjection)
CDMC2a
CDMC2b
Two multicyclones (20 nine-inch diameter tubes)
ESDST
Dust trailer unloading station
CDCY18
CDBF18
One cyclone (64 inches in diameter)
One bagfilter (3,048 square feet in filter area)

CAM was previously determined not to be applicable to the control devices associated with the wood-working operations and the two wood/coal-fired boilers because potential uncontrolled PM10 emissions were determined to be less than the CAM applicability threshold of 100 tons per year (See Jenny Sheppard's permit review dated October 12, 2007 for Permit No. 04172T17).  This permit renewal does not affect this status.  

Dust trailer unloading station (ID No. ESDST) and its associated control devices (ID Nos. CDCY18 and CDBF18) were reviewed for CAM applicability as part of the previous permit renewal (See Mark Cuilla's permit review dated November 26, 2012 for Permit No. 04172T23).  CAM was determined to be applicable to this source and a 15A NCAC 02D .0614 permit condition was added.

The Dust trailer unloading station is subject to 15A NCAC 02D .0515 (Particulates from Miscellaneous Industrial Processes). Compliance with this emission standard will be achieved using a cyclone (ID No. CDCY18) and a fabric filter (ID No. CDBF18).
 
Visible emissions observations were selected as the performance indicator because it is a good indicator of the proper operation and maintenance of the fabric filters.  When the filter units are operating properly, there should not be any visible emissions at the bagfilter outlet. Any visible emissions indicate reduced performance of the fabric filters, therefore, the presence of visible emissions is used as a performance indicator. An excursion triggers inspection, corrective action, and a reporting requirement.  An indicator range of no visible emissions was selected because: (1) an increase in visible emissions is indicative of an increase in particulate emissions; and (2) a monitoring technique which does not require a Method 9 certified observer is desired.  Although Reference Method 22 applies to fugitive sources, the visible/no visible emissions observation technique of Reference Method 22 can be applied to ducted emissions; i.e., Method 22-like observations.

The selected QIP threshold for fabric filter visible emissions is five excursions in a 6-month reporting period.  This level is 3 percent of the total visible emissions observations.  If the QIP threshold is exceeded in a semiannual reporting period, a QIP will be developed and implemented.  The following updated condition will be included in the renewed permit.

3.	15A NCAC 02D .0614:  COMPLIANCE ASSURANCE MONITORING

      a.	Per 40 CFR 64 and 15A NCAC 02D .0614, the Permittee shall comply with the following.
      
      b.	Background
         i.	Emission Unit(s).  Dust trailer unloading station (ID No. ESDST)
         ii.	Applicable Regulation, Emission Limit, and Monitoring Requirements.
            (A)	Regulation.  15A NCAC 02D .0515: Particulates from Miscellaneous Industrial Processes
            (B)	Emission limit (particulate matter)
            E = 4.10 x P[0.67] for P < 30 tons per hour, or
            E = 55.0 x P[0.11]  -  40 for P > 30 tons per hour
            Where:	E = allowable emission rate in pounds per hour
                  P = process weight in tons per hour
            (C)	Control Technology.  One bagfilter (ID No. CDBF18)
            
      c.	Monitoring Approach.  The key elements of the monitoring approach for particulate matter, including parameters to be monitored, parameter ranges and performance criteria are presented in the following table.
      
                                    Measure
                                   Indicator
I.  Indicator

Measurement Approach
Visible emissions

Visible emissions from the bagfilter will be monitored daily while unloading is taking place using EPA Reference Method 22-like procedures
II.  Indicator Range


QIP Threshold
An excursion is defined as the presence of visible emissions.  Excursions trigger an inspection, corrective action, and a reporting requirement.

The QIP threshold is five excursions in a 6-month reporting period.
III.  Performance Criteria

A.  Data Representativeness

B.  Verification of Operational Status

C.  QA/QC Practices


D.  Monitoring Frequency

Data Collection Procedures

Averaging Periods



Measurements are being made at the emission point bagfilter outlet)


NA


The observer will be familiar with Reference Method 22 and follow Method 22-like procedures.

Observations are done daily while unloading is taking place.


VE observations are documented by the observer.


NA
      
      Reporting [15A NCAC 02Q .0508(f), 40 CFR 60.9]
   d.	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.

      The report shall also include the following information, as applicable:
      i.      Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken;
      ii.     Summary information on the number, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable); and
      iii.    A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR 64.8. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring.

7.     Increment Tracking and Avoidance Conditions

Increment Tracking
Caldwell County has not been triggered for any pollutants, so no PSD increment tracking is required.

15A NCAC 02Q .0317 - Avoidance Conditions 
MACT
The facility has requested an avoidance condition in order to avoid classification as a major source for MACT applicability.  The facility-wide emission sources shall discharge into the atmosphere less than 10 tons of any single hazardous air pollutant (HAP) per consecutive 12-month period and less than 25 tons of any combination of HAPs per consecutive 12-month period.
 
 8.	Other Regulatory Concerns
 
A P.E. seal was not required for the permit renewal or significant modification.

A zoning consistency form was not required for the permit renewal or significant modification.

No application fee was required for this permit renewal.
An application fee of $929 was required and received for the significant modification.

9.     Public Notice/EPA and Affected State(s) Review

A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521.  The notice will provide for a 30-day comment period, with an opportunity for a public hearing.  Consistent with 15A NCAC 02Q .0525, the EPA will have a concurrent 45-day review period.  Copies of the public notice shall be sent to persons on the Title V mailing list and EPA.  Pursuant to 15A NCAC 02Q .0522, a copy of each permit application, each proposed permit and each final permit pursuant shall be provided to EPA.  Also, pursuant to 02Q .0522, a notice of the DRAFT Title V Permit shall be provided to each affected State at or before the time notice is provided to the public under 02Q .0521 above.

