AVA NCDENR. North Carolina Department of Environment and Natural Resources. November 26,2014

Transcription

1 AVA NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor John E. Skvarla, ll 8Hcretary November 26,2014 Mr. Michael Kraszeski President Atlantic Veneer Corporation P. 0. Box 660 Beaufort, NC Subject: Air Permit No R22 Atlantic Veneer Corporation Beaufort, Carteret County, North Carolina Permit Class: Synthetic Minor Facility D# Dear Mr. Kraszeski: n accordance with your completed application received August 28, 2014, we are forwarding herewith Permit No R22 to Atlantic Veneer Corporation, Beaufort, Carteret County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q.0102 have been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. f any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 ofthe North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. 150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become Wilmington Regional Office - Division of Air Quality 127 Cardinal Drive Extension, Wilmington, North Carolina Phone: / FAX: nternet: An Equal Opportunity Affirmative Action Employer - Made in part by recycled paper

2 Michael Kraszeski November 26,2014 Page 2 final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 150B-23. Unless exempted by a condition of1liis permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S and may subject the Permittee to civil or criminal penalties as described in G.S A and B. This permit shall be effective from November 26, 2014 until January 1, 2017, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. This permit revision is the result o{a request {or a permit modification {or the addition of one sawmill and veneer mill wood waste transport system (ES-6B) and one simple cyclone (CD- 6B). and the addition of one existing emission source; one hammermill (ES-17) with control device CD-6B. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Should you have any questions concerning this matter, please contact Linda Willis at Sincerely, Brad Newland, Wilmington R wnal Supervisor Division of Air Quality Enclosures c: Wilmington Regional Office WiRO Permit Coordinator!Beam Doc Mod

3 NORTH CAROLNA ENVRONMENTAL MANAGEMENT COMMSSON DEPARTMENT OF ENVRONMENT AND NATURAL RESOURCES DVSON OF AR QUALTY AR PERMT NO R22 ssue Date: November 26, 2014 Expiration Date: January 1, 2017 Effective Date: November 26, 2014 Replaces Permit: 03453R21 To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes ofnorth Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations, Atlantic Veneer Corporation 2457 Lennoxville Road Beaufort, Carteret County, North Carolina Permit Class: Synthetic Minor Facility D# (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: ES-Boiler (NSPS, one wood-fired boiler (28.7 million 1-cD-1 ~ - one multicyclone with a dual chambe< NESHAP) Btu per hotir maximum heat input, (primary has 16 tubes with 9 inch 1998 model) diameters and secondary has 44 tubes with 6 inch diameters) ES-Boiler 2 (NSPS, one No. 6 low-sulfur fuel oil-fired NESHAP) boiler (27.2 million Btu per hour maximum heat input, 1996 model) F l N/A ES-Boiler 3 (NSPS, one wood waste-fired boiler ( ~- ~ one dual multicyclone with (10) nine- NESHAP) million Btu per hour maximum heat inch diameter tubes each input, 1989 model) ~ Emission Emission Source Control Control System Source D Description System D Description ES-6A ES-4 ES-5 ES-6B one clipper line one clipper line one sawmill hog one sawmill and veneer mill wood waste transport system CD-4 CD-5 one simple cyclone (72 inches in diameter) one simple cyclone (72 inches in diameter) CD-5 one simple cyclone (72 inches in diameter) CD-6A in series with CD-6B, one simple cyclone (96 inches in diameter) one simple cyclone (96 inches in diameter) CD-6B follows CD-6A one simple cyclone (72 inches in diameter)

4 Page 2 Emission -~ Emission Sourc~- --r-- Control -~- ----C ontrol System Source D Description F System D Description F ES [ ciiqper room wood waste tra~j;;rt CD-7 --T~n~ b~gtl lte~(j,600_s_qu-a-re-fi-ee_t _of_fi_lter system area) CD-7 r --ES-8 - planer wood waste transp ~ rt system CD-8 lone simple cyclone (72 inches i~- - diameter) CD-8 ES-17 one hammermill. ----~CD-6B n-e -si_m_p-le-c-yc-lone (96 inches in diameter) CD-6B follows CD-6A one simple cyclone (72 inches in diameter) in accordance with the completed application B received August 28, 2014 including any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of Environment and Natural Resources, Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTNG, REPORTNG, OR MONTORNG REQUREMENTS: A. SPECFC CONDTONS AND LMTATONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), 2D.0202, 2D.0503, 2D.0504, 2D.0512, 2D.0515, 2D.0516, 2D.0521, 2D.0524 (40 CFR 60, Subpart De), 2D.0535, 2D.0540, 2D.0611, 2D.1111 (40 CFR 63, Subpart JJJJJJ), and 2Q PERMT RENEWAL AND EMSSON NVENTORY REQUREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q.0304( d) and (f). Pursuant to 15A NCAC 2Q.0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A NCAC 2D.0202, pursuant to N.C. General Statute The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2015 calendar year. 3. PARTCULATE CONTROL REQUREMENT- As required by 15A NCAC 2D.0503 "Particulates from Fuel Burning ndirect Heat Exchangers," particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below:

5 Page 3 Source Emission Limit (lbs/million Btu) 4. PARTCULATE CONTROL REQUREMENT- As required by 15A NCAC 2D.0504 "Particulates from Wood Burning ndirect Heat Exchangers," particulate matter emissions from the wood burning indirect heat exchangers shall not exceed the allowable emission rates listed below: Source one wood-fired boiler (28.7 million Btu per hour maximum heat input, 1998 model, D No. ES-Boiler 1) F oohdwaste/n?. Emission Limit (lbs/million Btu) 6 fuehl oil:fired bidoinler (1E7S.4B8 ~ 1 illi 3 o)n Btu per ~ ~.; our maximum eat mput, o er v ~ PARTCULATE CONTROL REQUREMENT- As required by 15A NCAC 2D.0512 "Particulates from Wood Products Finishing Plants," the Permittee shall not discharge pmiiculate matter caused by the working, sanding, or finishing of wood without providing, as a minimum for its collection, adequate duct work and properly designed collectors, or other such devices as approved by the Commission. 6. PARTCULATE CONTROL REQUREMENT- As required by 15A NCAC 2D.0515 "Pmiiculates from Miscellaneous ndustrial Processes," pmiiculate matter emissions from the emission sources shall not exceed allowable emission rates. The allowable emission rates are, as defined in 15A NCAC 2D.0515, a function ofthe process weight rate and shall be determined by the following equation(s), where Pis the process throughput rate in tons per hour (tons/hr) and E is the allowable emission rate in pounds per hour (lbs/hr) E = 4.10 * (P) 0 67 E=55 * (P) for P.:::; 30 tons/hr, or for P > 30 tons/hr. 7. The collected flyash shall not be re-injected into any of the Boilers (D Nos. Boiler 1, Boiler 2, or Boiler 3). 8. SULFUR DOXDE CONTROL REQUREMENT- As required by 15A NCAC 2D.0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the boilers shall not exceed 2.3 pounds per million Btu heat input. 9. VSBLE EMSSONS CONTROL REQUREMENT- As required by 15A NCAC 2D.0521 "Control ofvisible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged

6 Page 4 over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour eriod. However, sources which must comply with 15A NCAC 2D.0524 "New Source Performance Standards" or.1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein A NCAC 2D.0524 "NEW SOURCE PERFORMANCE STANDARDS"- For one woodfired boiler (28.7 MM Btu/hr maximum heat input, 1998 model, D No. ES-Boiler 1), one No. 6 low-sulfur fuel oil-fired boiler (27.2 million Btu per hour maximum heat input, 1996 model, D No. ES-Boiler 2), and one woodwaste-fired boiler (17.48 MM Btu/hr maximum heat input, 1989 model, D No. ES-Boiler 3), the Permittee shall comply with all applicable provisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart De, including Subpart A "General Provisions." a. NSPS Recordkeeping Requirements - n addition to any other recordkeeping requirements ofthe EPA, the Permittee is required to maintain records as follows: 1. The amounts of each fuel combusted during each month; and u. All records required under this section shall be maintained for a period of two years following the date of such record. b. NSPS Reporting Requirements - n addition to any other notification requirements to the Environmental Protection Agency (EPA), the Permittee is required to NOTFY the Regional Supervisor, DAQ, in WRTNG, ofthe following: 1. The sulfur content of the residual oil com busted in an affected source shall not exceed 0.5 percent by weight. Within 30 days after each six-month period of the calendar year (by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June), the Permittee must submit in writing to the Regional Superv~sor, DAQ, the sulfur content of the residual oil combusted in an affected source. f fuel supplier certification is used to demonstrate compliance, fuel supplier certification shall include the following information: A. The name of the oil supplier; B. The location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically including whether the oil was sampled as delivered to an affected facility, or whether the sample was drawn from the oil in storage at the oil supplier's or oil refiner's facility, or other location; C. The sulfur content ofthe oil from which the shipment came (or ofthe shipment itself);

7 Page 5 D. The method used to determine the sulfur content of the oil; and E. A certified statement signed by the owner or operator of an affected source-that-the-recerds-of-fuel-suppl-ier-eerti-fieat-ien-subm-itted, represent all of the fuel com busted during the reporting period. 11. NOTFCATON REQUREMENT- As required by 15A NCAC 2D.0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00a.m. Eastern time of the Division's next business day ofbecoming aware ofthe occurrence and describe: 1. the name and location of the facility, 11. the nature and cause of the malfunction or breakdown, 111. the time when the malfunction or breakdown is first observed, 1v. the expected duration, and v. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 12. FUGTVE DUST CONTROL REQUREMENT- As required by 15A NCAC 2D.0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. f substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D.0540(f). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads). 13. CYCLONE REQUREMENTS- As required by 15A NCAC 2D.0611, particulate matter emissions shall be controlled as described in the permitted equipment list.

8 Page 6 a. nspection and Maintenance Requirements- To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform an annual (for each 12 month period following the initial inspection) ; :c.. n"' sp"'e=cflon oflne cyclone system. n aaailion, fl:1e Permittee snall perform perioqi=c ' inspections and maintenance (&M) as recommended by the manufacturer. b. Recordkeeping Requirements - The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a cyclone logbook. Records of all maintenance activities shall be recorded in the logbook. The cyclone logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request. 14. FABRC FLTER REQUREMENTS including cartridge filters, baghouses, and other dry filter particulate collection devices- As required by 15A NCAC 2D.0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. nspection and Maintenance Requirements- To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform, at a minimum, an annual (for each 12 month period following the initial inspection) internal inspection of each bagfilter system. n addition, the Permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. b. Recordkeeping Requirements - The results of all inspections and any variance from manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request. 15. MULT-CYCLONE REQUREMENTS- As required by 15A NCAC 2D.0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. nspection and Maintenance Requirements- To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform an annual (for each 12 month period following the initial inspection) internal inspection of the multi-cyclone system. n addition, the Permittee shall perform periodic inspections and maintenance (&M) as recommended by the manufacturer. b. Recordkeeping Requirements - The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a multi-cyclone logbook. Records of all maintenance activities shall be recorded in the logbook. The multi-cyclone logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request.

9 Page 7., =mc=- 16. GENERALLY AVALABLE CONTROL TECHNOLOGY- For the one wood-fired boiler (28.7 million Btu per hour maximum heat input, 1998 model, D No. ES-Boiler 1), one No. 6low-sulfur fuel oil-fired boiler (27.2 million Btu per hour maximum heat input, 1996 octet;-n-n-o.--es~boiler2), and one woodwaste-fi.red-ljoiteri -1/ -:-48-mitliorrBnrper-h-our,----- maximum heat input, 1989 model, D No. ES-Boiler 3), the Permittee shall comply with all applicable provisions, including the notification, testing, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.1111, as promulgated in 40 CFR 63, Subpart JJJJJJ, "National Emission Standards for Hazardous Air Pollutants for Area Sources: ndustrial, Commercial, and nstitutional Boilers", including Subpart A "General Provisions." a. Compliance Dates ( 40 CFR ) - The owner or operator of an existing source is required to comply with the tune-up and the energy assessment requirements no later than March 21, b. Compliance Requirements - As required by 15A NCAC 2D.1111, the Permittee shall comply with the following requirements: 1. General Duty Clause (40 CFR (a))- At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. n. Boiler Tune-up (40 CFR )- An initial boiler tune-up is required by March 21, fthe unit is not operating on the required date for a tuneup, the tune-up must be conducted within thirty days of startup. The Permittee shall comply with the following with respect to the tune-up: A. Periodic tune-ups: A biennial tune-up is required and shall be conducted no more than 25 months after the previous tune-up. The following units are only required to conduct a tune-up every five years: seasonal boilers (shutdown for 7 consecutive months or 210 consecutive days each 12-month period due to seasonal conditions; only biomass or oil), limited-use boilers, and units with oxygen trim systems, as defined in 40 CFR Each five-year tune-up must be conducted within 61 months ofthe previous tune-up. B. Fuel required for the tune-up: The Permittee shall conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely bum 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. C. As applicable, inspect the burner, and clean or replace any components of the burner as necessary. The Permittee may delay the burner inspection until the next scheduled unit shutdown, but must inspect each burner at least once every 36 months (72 months for 5- year tune-ups).

10 Page 8 D. nspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. E. nspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. The Permittee may delay the air to fuel ratio inspection until the next scheduled unit shutdown, but must conduct the inspection at least once every 36 months (72 months for 5-year tune-ups). F. Optimize total emissions of carbon monoxide. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. G. Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken with a portable CO analyzer. m. Energy Assessment (40 CFR (c))- A one-time initial energy assessment is required by March 21, The energy assessment must be performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this section satisfies the energy assessment requirement. This energy assessment requirement does not apply to limited use boilers as defined in 40 CFR A facility that operates under an energy management program compatible with SO that includes the affected units satisfies the energy assessment requirement. The energy assessment must include: A. A visual inspection of the boiler system. B. An evaluation of operating characteristics of the facility, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. C. nventory of major systems consuming energy from affected boilers and which are under control of the boiler owner or operator. D. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. E. A list of major energy conservation measures that are within the facility's control.

11 Page 9 F. A list of the energy savings potential of the energy conservation measures identified. ; f-ir-a- eomprehens-ive-reptlrt-cletaijing-the-wa-ys-t<timpreve-ef-fieiene-y-,---the cost of specific improvements, benefits, and the time frame for recouping those investments. c. Notification and Reporting Requirements- n addition to the notification and reporting requirements of the Environmental Protection Agency (EPA), the Permittee is required to NOTFY the Regional Supervisor, DAQ, in WRTNG, of the following: 1. nitial Notification (per 40 CFR 63.9(b) and 40 CFR (a)(2)) is required by January 20, Notification of Compliance Status (40 CFR (a)(4)) is required by July 19, Compliance Report must be prepared by March 1 of every other year (or every five years depending on the frequency of the tune-up requirements) starting March 1 the year following the first periodic tune-up, and submitted upon request. f the source experiences any deviations from the applicable requirements then the report must be submitted by March 15. The report must meet the requirements of 40 CFR (b )( 1-4 ). d. Recordkeeping Requirements - n addition to any other recordkeeping requirements of the EPA, the Permittee shall maintain the following records as defined under 40 CFR (c): 1. Copies of all required notifications. 11. Maintain the following records to document conformance with the work practices, emission reduction measures, and management practices: A. Tune-up records- records must identify each boiler, the date of tuneup, the procedures followed for tune-up, the manufacturer's specifications to which the boiler was tuned, and the following:. 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 tuneup ofthe 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 ofthe boiler but only if the unit was physically and legally capable of using more than one type of fuel during

12 Page 10 that period. Units sharing a fuel meter may estimate the fuel use by each unit. C. Seasonal boilers- For each boiler that meets the definition of seasonal boiler, you must keep records of days of operation per year. D. Records of non-waste determinations per 40 CFR (c)(2)(ii) Malfunction Records - 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 in 40 CFR (a), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. V. Record Retention- You must keep each record for 5 years following the date of each recorded action. 17. LMTATON TO AVOD 15A NCAC Pursuant to 15A NCAC 2Q.0315 "Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q.0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than the following: Emission Limit!Pollutant (Tons per consecutive 12-month period) PM S NOx 100 co 100 To comply with this limit, the Permittee shall follow the reqmrements listed below. A. PM-10 LMT BOLER HOURS OF OPERATON LMTS - n addition to the above control device requirements of 2D.0611, for the fabric filter, cyclones, and multicyclones, in order to maintain PM-10 actual emissions less than 100 tons per year, as requested by the Permittee, the hours of operation of the two wood boilers (D Nos. ES Boiler-1 andes Boiler-3) shall be limited as follows: (a) (b) Boiler D No. ES-1 shall not operate more than 8,736 hours per year. Boiler D No. ES-3 shall not operate more than 4,904 hours per year.

13 Page 11 B. SO~LMT To ensure that facility-wide S02 actual emissions are less than 100 tons per year, the amount ~or-mel oil consumed-d-8nit~rljj-no-:-es=l-shaltnorproduc-e-s0z-emissions-greater--than : ton/yr. The following equation shall be used to determine S02 actual emissions: ES = [gallons oil in Boiler 2 per year] X [159] X [%Sulfur]/ 2,000,000, where C. NOY LMT and CO LMT ES =the actual S02 emissions in tons per year, and % Sulfur = the weight percent of sulfur in the fuel. The NOx and CO synthetic minor limits (actual emissions less than 100 tons per year) will be satisfied by the above limits S02 for Boilers ES-1, ES-2, and ES-3. D. Synthetic Minor Recordkeeping and Reporting Reguirements For compliance purposes, the Permittee shall record the following: (a) (b) The hours of operation of Boiler ES-1 and Boiler ES-3 shall be recorded on a daily basis (not to exceed 8,736 and 4,904 hours per year, respectively). The actual emissions of S02 from Boiler ES-2 shall be calculated on a monthly basis (not to exceed 57 ton per year; so2 emissions shall be calculated in batches based on the fuel weight percent sulfur). The hours of operation and the S02 actual emissions from items D.(a) and D.(b) above shall be totaled on a monthly and annual basis and recorded in a logbook (in written or electronic format) and made available to DAQ personnel upon request. n addition, the annual hours of operation and the S02 actual annual emissions shall be reported to the Regional Supervisor annually by March 1 of every calendar year. B. GENERAL CONDTONS AND LMTATONS 1. n accordance with G.S (c)(l), TWO COPES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONTORNG DATA. NOTFCATONS, REQUESTS FOR RENEWAL, AND ANY OTHER NFORMATON REQURED BY THS PERMT shall be submitted to the: Regional Supervisor North Carolina Division of Air Quality Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number.

14 Page RECORDS RETENTON REQUREMENT- n accordance with 15A NCAC 2D.0605, any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form ~ s=u~taole ana reaally avafla51e for expealfiotsinspectwn ana review. Tfiese records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q.0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUPMENT RELOCATON- n accordance with 15A NCAC 2Q.0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTNG REQUREMENT- n accordance with 15A NCAC 2Q.0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or c. changes in the quantity or quality of materials processed. f appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions. n no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. n accordance with 15A NCAC 2Q.0309, this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. n accordance with G.S (c)(1), the facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device( s) and appurtenances. 7. n accordance with G.S (c)(1), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. n accordance with G.S (c)(l), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. 9. n accordance with G.S (c)(l), this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority.

15 Page n accordance with 15A NCAC 2D.0605, reports on the operation and maintenance of the faciltty shah-be submitted-by tne Permittee tother.:egtnmrl-sup-etvisur,.)*(tatsuch ; intervals and in such form and detail as may be required by the DAQ. nformation required in such reports may include, but is not limited to, process weight rates, firing rates, hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S A, B, and C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute (a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. n accordance with G.S (c)(1), the Permittee must comply with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Waste Management. 14. PERMT RETENTON REQUREMENT- n accordance with 15A NCAC 2Q.0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site. 15. CLEAN AR ACT SECTON 112(r) REQUREMENTS- Pursuant to 15A NCAC 2D.2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part PREVENTON OF ACCDENTAL RELEASES - GENERAL DUTY - Pursuant to Title Part A Section 112(r)(l) of the Clean Air Act "Hazardous Air Pollutants- Prevention of Accidental Releases- Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only.

16 Page GENERAL EMSSONS TESTNG AND REPORTNG REQUREMENTS- f emissions testmg S reqmroooytliis permit, or theda:q, or fthel>ermittee submits emissions rest!=n=g : to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D.2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Permit issued this the 26 1 h day ofnovember, NORTH CAROLNA ENVRONMENTAL MANAGEMENT COMMSSON -:t /djjl Brad Newland Wilmington Regional Supervisor Division of Air Quality. ' ~ :. By Authority of the Environmental Management Commission Air Permit No R22

17 ATTACHMENT to Permit No R22, November 26,2014 nsignificant Exempt Activities l Exemption l Source of Source of Title V Source Regulation TAPs? Pollutants? [ES five (5) steam-heat~ d -~ 2Q ~ - ~-:- -~----- No!veneer dryers ( c )(2)(E)(i) Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D.1100 "Control oftoxic Air Pollutants" or 2Q.0711 "Emission Rates Requiring a Permit."

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