The State of New Hampshire DEPARTMENT OF … · The New Hampshire Department of Environmental...

The State of New Hampshire

DEPARTMENT OF ENVIRONMENTAL SERVICES ____________

Thomas S. Burack, Commissioner

DES Web site: www.des.nh.gov

P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095

Telephone: (603) 271-1270 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964

December 9, 2013

William Dannhauer

Operations Manager

Kalwall Corporation

PO Box 237

Manchester, NH 03105

RE: On-Site Full Compliance Evaluation Report

Dear Mr. Dannhauer:

The New Hampshire Department of Environmental Services, Air Resources Division

(“DES”) has completed a Full Compliance Evaluation of Kalwall Corporation – Bow Flat Sheet

Division (“Kalwall”) in Bow. The compliance evaluation included an on-site inspection

completed on November 8, 2013. This is a copy of the On-Site Full Compliance Evaluation

Report for your review and records.

DES identified deficiencies during this compliance evaluation, as detailed in this report.

The results of this compliance evaluation may be forwarded to the Enforcement Section for

further review. If you have any questions, please contact Daniel Hrobak at (603) 271-1987 or

email at [email protected].

Sincerely,

Greg Helve

Compliance Assessment Section Supervisor

Air Resources Division

cc: Chairman, Board of Selectmen, Town of Bow, 10 Grandview Road Bow, NH 03304

Kalwall Corporation - Bow Inspection Date: November 8, 2013

On-Site Full Compliance Evaluation Report Date: December 9, 2013

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Abbreviations and Acronyms AAL Ambient Air Limit

acf Actual cubic foot

ags Above ground surface

ASTM American Society of Testing and Materials

Btu British thermal units

CAS Chemical Abstracts Service

cfm Cubic feet per minute

CFR Code of Federal Regulations

CO Carbon Monoxide

CO2e Carbon dioxide equivalent

DER Discrete Emission Reduction

DES New Hampshire Department of Environmental Services

Env-A New Hampshire Code of Administrative Rules – Air Resources Division

ERC Emission Reduction Credit

FGD Flue Gas Desulphurization

ft Foot or feet

ft3 Cubic feet

gal Gallon

HAP Hazardous Air Pollutant

hp Horsepower

hr Hour

lb Pound

LPG Liquefied Petroleum Gas

MM Million

MSDS Material Safety Data Sheet

MSW Municipal Solid Waste

MW Megawatt

MWC Municipal Waste Combustor

N/A Not applicable

NAAQS National Ambient Air Quality Standard

NG Natural Gas

NOx Oxides of Nitrogen

NPV Notice of Past Violation

NSPS New Source Performance Standard

PM10 Particulate Matter < 10 microns

ppm Parts per million

PSD Prevention of Significant Deterioration

psi Pounds per square inch

RACT Reasonably Available Control Technology

R&D Research and Development

RSA Revised Statues Annotated

RTAP Regulated Toxic Air Pollutant

scf Standard cubic foot

SO2 Sulfur Dioxide

TSP Total Suspended Particulate

tpy Tons per consecutive 12-month period

USEPA United States Environmental Protection Agency

VOC Volatile Organic Compound



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I. Facility Description

DES conducted an On-Site Full Compliance Evaluation of Kalwall and the results are presented

herein. The compliance evaluation covers the period of 2012 to November 8, 2013.

Kalwall operates a continuous lamination manufacturing process for making flat reinforced

plastic (fiberglass) sheet or panels. The sheets may be opaque or translucent depending on

customer specifications. Among the most common applications of the sheet product are

construction panels, glazing panels, truck trailer paneling, refrigerator liners, sanitary paneling,

solar collector covers, road signs, and other similar products.

Resin is gravity fed to the applicator bath from a mezzanine mixing tank area onto a carrier

surface. Rolls of fiberglass roving are chopped and mechanically distributed onto the resin to

produce a uniform mat. The impregnated mat runs through a squeeze roll to remove excess resin

compacting the fiber bundles into the mat and controlling the sheet thickness. A second film is

applied from above to sandwich the resin-impregnated fiberglass between the two sheets. The

sheet then passes through a curing oven, which accelerates the chemical reaction, to cure and

harden the finished material. The resulting “fiberglass” sheet is cooled before stripping away the

top carrier film. The process proceeds without interruption provided that raw materials are

supplied to the feed end of the equipment. In practice, Kalwall “injects” resin supply to the

applicator bath tank in 500-pound batches, which classifies the process as intermittent.

Kalwall is subject to 40 CFR Part 63 subpart WWWW – National Emissions Standards for

Hazardous Air Pollutants: Reinforced Plastic Composites Production and, therefore, requires a

Title V permit. Kalwall is also required to obtain a permit to limit its VOC emissions to less than

50 tpy.

Facility name and address Kalwall Corporation – Bow Flat Sheet Division

40 River Rd

Bow, NH 03304

County Merrimack

Telephone 603-224-6881

AFS# 3301300051

Source Type Title V

Inspection Date/Time November 8, 2013; 9:00 AM

Inspection Type On-Site Full Compliance Evaluation

Inspection Period 2012 – November 8, 2013

Weather 40o F., sunny, wind 5 mph

Inspected by Daniel Hrobak, Senior Compliance Assessment Engineer

Source Contact(s) William Dannhauer, Operations Manager

Kathleen Harvey, Environmental, Health & Safety Manager

Jeff Hicks, Plant Manager

Kenny Welch, Maintenance Supervisor

Last Inspection July 24, 2012

No deficiencies identified



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Permit Number: TV-0027 Issued: October 12, 2012

Expires: October 31, 2017

TV-OP-027 Issued: February 10, 2006

Expired: February 28, 2011

The on-site inspection included an opening meeting to discuss the purpose of the inspection as

well as the rules pertaining to claims of confidentiality and facility safety concerns. Kalwall

agreed to the inspection and authorized access to the facility. Material provided and operations

conducted by the facility at the time of the inspection were not claimed as confidential.

II. Emission Unit Identification and Facility Wide Emissions

Table 1 below, taken from the permit, lists the permitted emission units

Table 1 Significant Activity

Emission

Unit ID Description of Emission Unit or Process Manufacturer

Installation

Date

Maximum Design

Capacity and Permitted

Fuel Types

EU01 Fiberglass Reinforced Plastic Lamination

Process Kalwall 1970 Glass Fiber – 621.5 lb/hr

EU02

Fire Pump Engine

Model # 3208

Serial # 03Z04769

Caterpillar 1986 235 horse power

Diesel – 14.1 gal/hr

DES observed the devices identified in this table and the facility has made no changes to these

devices. During the inspection, neither of the devices was in operation. The facility has made no

changes to these devices and has not added any devices classified as significant activities.

Kalwall has identified the following insignificant activities:

Insignificant Activity List

Item # Insignificant Activity

1 Customer sample preparation

2 Muffler furnace for lab-scale fire tests (0.075 MMBtu/hr)

3 (Six) Oil-fired heating furnaces (0.45 MMBtu/hr each unit)

4 (Four) Dual fuel fired space heating air units (0.625 MMBtu/hr each unit)

5 Storage tanks of such a size and vapor pressure as not to emit VOC or HAP

6 (Eighteen) gas-fired process production line burners (0.50 to 0.80 MMBtu/hr each)

7 (Three) Make-up air gas fired burners (0.5 MMBtu/hr each unit)



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The table below lists the facility-wide reported annual emissions for the review period.

Facility-Wide Emissions (tons)

TSP SO2 NOx CO VOC HAPs/RTAPs

Permitted Limits — — — — 48.5 —

2012 0.02 0.24 0.83 0.45 1.49 20.41

Note: There are no permit limits for HAPs. The RTAP limits are identified in Env-A 1450. The

facility did not exceed any RTAP limits.

III. Control Equipment

Table 3 below, taken from TV-0027, lists the relevant required control equipment for the

facility’s devices.

Table 3- Operational and Emission Limitations

Pollution Control

Equipment ID Description Purpose

Emission Unit

Controlled

PCE01 Regenerative Thermal Oxidizer

CCM Group, LLC Model: 1300-M-95 For control of HAPs EU01

IV. Stack Criteria

Table 2 below, taken from TV-0027, lists the permitted stack requirements for the facility’s

devices.

During the inspection, DES observed the stacks were oriented as specified below, with Stack 1

and Stack 5 being above the roofline and unobstructed.

Table 2- Stack Criteria

Stack

Number Emission Unit ID

Maximum Height

(feet above ground surface)

Maximum Exit

Diameter (feet) Stack Orientation

1 Regenerative Thermal

Oxidizer [RTO] 31 2.83 Vertical

2 West Wall Fan 16 3.0 Horizontal

3 West Roof Fan 27.9 4.65 Vertical

4 Recovery Room 12 1.5 Horizontal

5 RTO By-pass 31 2.83 Vertical



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V. Compliance with Operating and Emission Limitations

Table 4, below lists the state only operational and emission limitations requirements for the

facility from TV-0027 and any deficiencies noted during the evaluation.

Table 4- State-only Operational and Emission Limitations

Item

# Applicable Requirement

Applicable

Emission Unit

Regulatory

Citation Compliant

1.

24-hour and Annual Ambient Air Limit

The emissions of any regulated toxic air pollutant (RTAP)

shall not cause an exceedance of its associated 24-hour or

annual ambient air limit as set forth in Env-A 1450.01, Table

Containing the List Naming All Regulated Toxic Air

Pollutants.

Facility Wide Env-A 1400 Yes

2.

Revisions of the List of RTAPs

In accordance with RSA 125-I:5, IV, if DES revises the list of

RTAPs or their respective AALs or classifications under RSA

125-I:4, II and III, and as a result of such revision the Owner

or Operator is required to obtain or modify the permit under

the provisions of RSA 125-I or RSA 125-C, the Owner or

Operator shall have 90 days following publication of notice of

such final revision in the New Hampshire Rulemaking

Register to file a complete application for such permit or

permit modification.

Facility Wide RSA 125-I:5 IV Yes

Table 5, below lists the federally enforceable operational and emission limitations requirements

for the facility from TV-0027 and any deficiencies noted during the evaluation.

Table 5- Federally Enforceable Operational and Emission Limitations

Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

1.

Facility-Wide VOC Emission Limitation

The total VOC emissions from the Facility shall not exceed 48.5

tons per calendar year.

Facility Wide

Temporary

Permit

FP-T-0052

Yes

2.

Particulate Emission Standards

The maximum allowable particulate matter emission rate shall not

exceed the maximum allowable particulate matter emission rate as

calculated in a) or b) below:

A process weight rate up to 30 tons/hr: ( )67.005.5 PE ∗=

A process weight rate In excess of 30 tons/hr:

( ) 480.66 11.0−∗= PE

Where:

E = the maximum allowable particulate matter emission rate in

pounds per hour; and

P = the process weight rate in tons per hour.

EU01

Env-A

2102.04(b)

effective

11-24-2004

Unknown

Finding: Compliance with particulate matter emission standards can only be determined through stack testing for

particulate matter, which has not been required for these devices, to date.



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

3.

Visible Emission Standards

The average opacity shall not exceed 20 percent for any

continuous 6-minute period, except for one period of 6 continuous

minutes in any 60-minute period during startup, shutdown, or

malfunction.

EU01

Env-A

2103.02(a)

effective

11-24-2004

Unknown

Finding: Compliance with this permit condition was not determined as the facility was not operating EU01 during the on-

site portion of the compliance evaluation.

4.

Reinforced Plastic Composites Production Emission Limitation

All continuous lamination operations emitting less than 100 tpy of

HAP, and repair operations must meet the following requirements:

a) Reduce total organic HAP emissions by at least 58.5 weight

percent; or

b) Not exceed an organic HAP emissions limit of 15.7 lb of

organic HAP per ton of neat resin plus and neat gel coat plus.

EU01

40 CFR

63.5805(a)(2)

&

63.5805(g)

subpart WWWW

Yes

Finding: The facility has chosen to reduce the total organic HAP emissions by 58.5 % using a RTO. With this control

device, on June 20, 2007, Kalwall demonstrated a HAP removal efficiency of 98 % and on July 24 and 25, 2012, a HAP

removal efficiency of 95%.

5.

Compliance Options

a) Compliant line option - Demonstrate that each continuous

lamination line complies with the limitation specified in Table

5, Item 4; or

b) Add-on control device option - Where the Facility must meet

the emissions limitation specified in Table 5, Item 4.a) above,

the Facility has the option of demonstrating that

PCE01achieves 95% reduction of all wet-out area organic

HAP emissions.

EU01

40 CFR

63.5820(a) & (c)

subpart WWWW

Yes

Finding: See Table 5, Item #4.

General Compliance Requirements

a) Work Practice Standards –

1. Cleaning Operations – Must not use cleaning solvents that

contain HAP, except that styrene may be used as a cleaner

in closed systems, and organic HAP containing cleaners

may be used to clean cured resin from application

equipment;

2. HAP-containing Material Storage – Keep containers that

store HAP-containing material closed or covered except

during the addition or removal of materials. Bulk HAP-

containing material storage tanks may be vented as

necessary for safety.

EU01

40 CFR

63.5835(a)

subpart WWWW

6.

b) Add-on Control Device Compliance –

The Owner or Operator must be in compliance with the emission

limitations specified in Table 5, Item 4 that are met using an add-

on control device, except during startup, shutdown, or

malfunction.

PCE01

40 CFR

63.5835(b)

subpart WWWW

Yes



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

c) Operation and Maintenance - General Duty –

1. At all times, including periods of startup, shutdown, and

malfunction, the Owner or Operator must 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;

2. During a period of startup, shutdown or malfunction, the

Owner or Operator has a general duty to minimize

emissions from the affected source to the greatest extent,

which is consistent with safety and good air pollution

control practices;

3. The general duty to minimize emissions during a period

of startup, shutdown or malfunction does not require the

Owner or Operator to achieve the emission levels in

Table 5, Item 4 at other times if this is not consistent

with safety and good air pollution control practices, nor

does it require the Owner or Operator to further reduce

emissions if levels required in Table 5, Item 4 have been

achieved.

EU01

40 CFR

63.5835(c)

subpart WWWW

&

63.6(e)(1)(i)

subpart A

d) Startup, Shutdown and Malfunction Plan (“SSMP”) –

1. The Owner or Operator shall develop and implement a

written SSMP that describes in detail the following:

i) Procedures for operating and maintaining the

source during periods of startup, shutdown, and

malfunction;

ii) A program of corrective action for malfunctioning

process, air pollution control, and monitoring

equipment used to comply with the emission

limitations specified in Table 5, Item 4;

2. The Owner or operator may use the Facility’s

standard operating procedures (SOP) manual, or an

Occupational Safety and Health Administration or other

plan, provided the alternative plans meet all the

requirements of 40 CFR 63.1111(a), and are made

available for inspection upon request;

6.

cont

3. Periodic revisions to the SSMP may be made as

necessary to reflect changes in equipment or procedures

without prior approval of the Division; and

4. The Owner or Operator must revise the SSMP

within 45 days after an event if the event meets the

characteristics of a malfunction, and the plan fails to

address, or inadequately addresses the malfunction, and

was not included in the SSMP at the time the plan was

developed. The revision must include detailed

procedures for operating and maintaining the source

during similar malfunction events and a program of

corrective action for similar malfunctions of process or

air pollution control and monitoring equipment.

EU01

&

PCE01

40 CFR

63.5835(d)

subpart WWWW

&

63.6(e)(3)

subpart A



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

7.

Equipment and Operating Requirements

The Owner or Operator shall operate PCE01 at all times emissions

from EU01 are vented to it.

PCE01

40 CFR

63.988(a)(2)

subpart SS

Yes

Closed Vent System

Except for closed vent systems operated and maintained under

negative pressure, these provisions apply to the closed vent

system:

a) Equipment and Operating Requirements:

1. Collection of Emissions: Each closed vent system shall

be designed and operated to collect the regulated

material vapors from the emission point, and to route

the collected vapors to PCE01;

2. Period of Operation: Closed vent system shall be

operated at all times when emissions are vented to or

collected by them;

3. Bypass Monitoring: Except for equipment needed for

safety purposes such as pressure relief devices, low leg

drains, high point bleeds, analyzer vents, and open-

ended valves or lines, the Owner or Operator shall

secure the bypass line valve in the non-diverting

position with a car-seal type configuration or a lock-

and-key type configuration.

40 CFR

63.983(a) subpart

SS

b) Leak Repair Provisions:

1. If there are visible, audible, or olfactory indications of

leaks in the closed vent system, at the time of the

annual visual inspection required in Table 6, Item 7:

Eliminate the leak; or

Monitor the closed-vent equipment according to the

procedures in Table 6, Item 7;

40 CFR

63.983(d)

subpart SS

2. Leaks, as indicated by an instrument reading greater

than 500 parts per million by volume above

background or by visual inspections, shall be repaired

as soon as practical, except as provided in 3) below:

i. A first attempt at repair shall be made no later

than 5 days after the leak is detected; and

ii. Repairs shall be completed no later than 15 days

after the leak is detected or at the beginning of

the next introduction of vapors to the system,

whichever is later;

8.

3. Delay of repair of a closed vent system for which leaks

have been detected is allowed if repair within 15 days

after a leak is detected is technically infeasible or

unsafe without a closed vent system shutdown, or if the

Owner or Operator determines that emissions resulting

from immediate repair would be greater than the

emissions likely to result from delay of repair. Repair

of such equipment shall be completed as soon as

practical, but not later than the end of the next closed

vent system shutdown.

EU01

&

PCE01

Yes



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

9.

Operation of the Continuous Parameter Monitoring Systems

(CPMS)

a) Except for system breakdowns, repairs, maintenance periods,

instrument adjustments, or checks to maintain precision and

accuracy, calibration checks, and zero and span adjustments,

the CPMS shall be in continuous operation when emissions

are being routed to PCE01;

b) Data recorded during monitoring malfunctions, associated

repairs, and required quality assurance or control activities,

including data averages and calculations or fulfilling a

minimum data availability requirement, may not be used;

c) At all times, maintain necessary parts for routine repairs of

the monitoring equipment;

d) Maintain, calibrate, and operate the CPMS [PCE01

combustion temperature monitor] according to manufacturer’s

specifications or other written procedures that provide

adequate assurance that the equipment would reasonable be

expected to monitor accurately;

e) Maintain and operate the CPMS in a manner consistent with

good air pollution control practices and ensure the immediate

repair of replacement of CPMS parts to correct “routine” or

otherwise predictable CPMS malfunctions, and the necessary

parts for routine repairs of the affected equipment shall be

readily available;

f) Develop and implement a CPMS quality control program. At

a minimum the written protocol shall include the following

operations:

1) Initial and any subsequent calibration of the CPMS;

2) Preventive maintenance of the CPMS including spare

parts inventory;

3) Data recording, calculations and reporting;

4) Accuracy audit procedures; and

5) Program of corrective action for a malfunction of the

CPMS;

EU01

&

PCE01

40 CFR

63.5895(b)

subpart

WWWW,

63.996(c) subpart

SS

&

40 CFR 63.8(d)

subpart A

Yes

10.

Pollution Control Equipment Operation and Maintenance

a) Operate and maintain PCE01 per the manufacturers’

recommendations to control the emissions from the wet-out

area associated with EU01 to minimize emissions and to meet

the requirements of Table 5, Item 4.

b) The combustion chamber temperature shall be maintained at a

temperature not below the minimum operating temperature

determined during the most recent performance stack test as

required in Table 6, Item 3, based on a 15 minute block

average;

c) At a minimum, PCE01 shall be subject to annual inspection

according to the requirements in Table 6, Item 12.

PCE01 Env-A 604.01 Yes



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

11.

Pollution Control Equipment Operation and Maintenance

a) Calibrate, operate and maintain a temperature monitoring

device located in the fire box or in the ductwork immediately

downstream of the fire box of PCE01;

b) The temperature monitoring device shall:

1) Have a minimum accuracy of ±1 percent of the

temperature being monitored expressed in degrees

Celsius (°C) or ±1.2 °C, whichever is greater; and

2) Provide a continuous temperature record;

c) Calibrate, operate and maintain a flow or pressure differential

gauge in the capture device vent at the wet-out area of EU01

leading to PCE01; and

d) The flow or pressure drop in the process vents leading to

PCE01 from the wet-out area shall be maintained within the

range determined during performance testing required in

Table 6, Item 3.

EU01 &

PCE01

Env-A 604.01

&

40 CFR

63.988(c),

63.981 subpart

SS

&

63.5875 subpart

WWWW

No

Finding: Kalwall did not maintain a flow or differential pressure gauge at the wet-out area of EU01.

12.

Accidental Release Program Requirements

The quantities of regulated chemicals stored at the facility are less

than the applicable threshold quantities established in 40 CFR

68.130. The facility is subject to the Purpose and General Duty

clause of the 1990 Clean Air Act, Section 112(r)(1). General

Duty includes the following responsibilities:

a) Identify potential hazards which result from such releases

using appropriate hazard assessment techniques;

b) Design and maintain a safe facility;

c) Take steps necessary to prevent releases; and

d) Minimize the consequences of accidental releases that do

occur

Facility-

Wide CAAA 112(r)(1) Yes

13.

Permit Deviation

In the event of a permit deviation, the Owner or Operator of the

affected device, process, or air pollution control equipment shall

investigate and take corrective action immediately upon discovery

of the permit deviation to restore the affected device, process, or

air pollution control equipment to within allowable permit levels.

Facility Wide Env-A 911.03 Yes

14.

Sulfur Content Limitations for Liquid Fuels

The sulfur content of No 2 fuel oil and diesel fuel shall not exceed

0.4 percent sulfur by weight.

EU02

40 CFR 52

&

Env-A 402.03

(SIP approved)

Yes

15.

Fire Pump Engine

The fire pump engine shall only operate during normal

maintenance and testing as recommended by the manufacturer,

and to operate the sprinklers in the case of a fire incident at the

facility.

EU02

Env-A 1302.15

(effective 10-31-

2010; formerly

Env-A

1211.02(o))

Yes



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Item


Applicable

Emission

Unit

Regulatory

Citation Compliant

16.

Fire Pump Engine Operating Requirements

After May 2, 2013, the engine shall be operated as follows:

a) Change oil and filter annually;

b) Inspect air cleaner annually;

c) Inspect hoses and belts annually;

d) Minimize idle time during startup and minimize startup time

to a period needed for appropriate and safe loading, not to

exceed 30 minutes; and

e) Operate and maintain the engine according to the

manufacturer’s emission-related operation and maintenance

instructions.

EU02 40 CFR 63.6603

subpart ZZZZ Yes

17.

Emergency Engines Manufactured Prior to June 12, 2006

The emergency engine shall be limited to 500 hours of operation

during any consecutive 12-month period.

Beginning May 3, 2013, the fire pump engine, in addition to the

above limitation, shall be limited as detailed in 40 CFR

63.6640(f)(1)(ii) and (iii).

EU02

40 CFR 63.6640

subpart ZZZZ &

Env-A

1301.02(j)(1)

Yes

Visible Emissions Standard for Fuel Burning Devices Installed

After May 13, 1970

a) The Owner or Operator shall not cause or allow average

opacity from fuel burning devices installed after May 13,

1970 in excess of 20% for any continuous 6-minute period.

Env-A 2002.02

18.

b) The average opacity shall be allowed to be in excess of those

standards specified in a) above for one period of 6 continuous

minutes in any 60-minute period during startup, shutdown, or

malfunction.

EU02

Env-A

2002.04(c)

Unknown

Finding: DES could not verify this permit condition since at the time of the on-site inspection, EU02 was not operating.

19.

Particulate Emission Standards for Fuel Burning Devices

Installed On or After January 1, 1985

The Owner or Operator shall not cause or allow emissions of

particulate matter from fuel burning devices installed on or after

January 1, 1985, to exceed 0.3lb/MMBtu.

EU02 Env-A

2002.08(c)(1) Unknown

Finding: Compliance with particulate matter emission standards can only be determined through stack testing, which has

not been required for this device, to date.

20.

Sulfur Content Limitations for Gaseous Fuels

Gaseous fuel shall contain no more than 5 grains per 100 cubic

feet of sulfur, calculated as H2S at standard conditions.

Facility Wide

40 CFR 52

&

Env-A 402.03

(SIP approved)

Yes

Finding: Kalwall maintains documentation from the fuel supplier that the sulfur content of the propane, as delivered,

does not exceed state or federal standards for the fuel.

21.

Permanent Total Enclosure

a) Install, operate and maintain a gauge to monitor the building

static pressure to assure that the building is maintained as a

permanent total enclosure for the capture of HAP emissions;

and

b) The static pressure of the building shall be greater than or

equal to 0.007 inches of water to demonstrate compliance

with the permanent total enclosure requirements.

EU01 &

PCE01 Env-A 604.01 Yes



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VI. Compliance with Monitoring and Testing Requirements

Table 6, below lists the testing and monitoring requirements for the facility from TV-0027 and

any deficiencies noted during the evaluation.

Table 6 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance Frequency

Applicable

Emission

Unit

Regulatory

Basis Compliant

1. To be

determined

When conditions warrant, the Division may require

the Owner or Operator to conduct stack testing in

accordance with USEPA or other Division approved

methods.

Upon

request by

the Division

Facility

Wide

RSA 125-C:6,

XI Yes

Finding: The facility has conducted stack testing in July 2012. See Table 5, Item #4.

2.

Sulfur

Content of

Liquid

Fuels

Conduct testing in accordance with appropriate

ASTM test methods or retain delivery tickets in

accordance with Table 7, Item 9 in order to

demonstrate compliance with the sulfur content

limitation provisions specified in this permit for

liquid fuels.

For each

delivery of

fuel oil to

the facility

Facility

Wide

Env-A 806.02 &

Env-A 806.05

(effective

10-31-2010)

Yes

a) Performance testing to evaluate compliance

with the emission reduction requirements

specified in Table 5, Item 4 shall be planned

and carried out in accordance with the following

schedule:

1). A pre-test protocol shall be submitted to

the Division at least 30 days prior to the

commencement of testing, and contain the

information required pursuant to Env-A

802.04;

2). The Divisions shall require rescheduling

of any compliance stack test if the staff

necessary to observe the test is not

available; and

3). The Owner or Operator and any contractor

retained by the Owner or Operator to

conduct the test shall meet with a Division

representative at least 15 days prior to the

test date to finalize the details of the

testing.

40 CFR 63.5845

subpart

WWWW,

63.988

subpart SS

&

Env-A 802

(effective

10-31-2010)

b) The compliance test shall not be conducted

during periods of startup, shutdown or

malfunction.

40 CFR

63.5850(d)

subpart

WWWW

3.

HAP

Emissions

Testing

Within 5

years of the

last

performance

stack test

EU01 &

PCE01 Yes



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Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

c) The following test methods, or Division

approved alternatives, shall be used:

1). USEPA Methods 1-4 for volumetric flow

rate, percentage of oxygen, carbon

dioxide and moisture;

2). USEPA Method 25A for total gaseous

organic emissions at the inlet and outlet to

PCE01 to determine HAP destruction

efficiency;

3). A temporary total enclosure must be

constructed and verified for the wet out

area using USEPA Method 204 of

appendix M of 40 CFR part 51 and

capture efficiency testing must be

determined using USEPA Method 204B

through E of Appendix M of 40 CFR part

51 for a duration of at lease 3 hours per

test run; and

4). Measure the mass flow rates of the

organic HAP in the exhaust streams going

to the atmosphere and to the control

device from the wet out area.

40 CFR

63.5850(e)

subpart

WWWW

63.997(e)(2)

subpart SS

&

Env-A 802

40 CFR 63.5875

&

63.5850(a)

subpart

WWWW

d) The performance test shall be conducted at

maximum representative operating conditions

for the process

40 CFR

63.997(e)(1)(i)

subpart SS

e) The performance test must consist of three runs:

1). Each sampling run must last at least one

hour;

2). For grab sampling, a minimum of four

grab samples must be taken at

approximately equal intervals during the

sampling run;

3). Each run must represent normal

production conditions; and

4). Each run must represent maximum

potential emissions with respect to the

organic HAP content of the materials

being applied and the material application

rates;

40 CFR

63.5850(f)

subpart

WWWW

63.998(a)(2)(ii)

&

63.997(e)(2)

subpart SS

f) During the test monitor and record the amounts

of production resin applied inside the enclosure

that is vented to PCE01:.

40 CFR

63.5850(h)

subpart

WWWW

3.

cont

HAP

Emissions

Testing

g) Record the flow or pressure differential [∆P]

measured at the wet-out area of EU01 every 15

minutes during the performance test;

Within 5

years of the

last

performance

stack test

EU01 &

PCE01

40 CFR

70.6(a)(3)

Yes



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

h) The CPMS [PCE01 temperature monitor] shall

be operational and the data verified either prior

to or in conjunction with the performance

testing; and

40 CFR

63.996(c)(3)

subpart SS

i) Record the combustion chamber temperature

averaged over the full period of the performance

test.

40 CFR

63.998(a)(2)(ii)

subpart SS

Finding; Kalwall conducted testing in 2007 and 2012. See Table 5, Item #4.

HAP concentrations shall be calculated as follows:

a) Concentration of either TOC [minus methane

and ethane] or total organic regulated material

shall be calculated using Equation 1:

∑∑

=

==

x

i

n

j

ji

TOCX

C

C1

1 [Eq 1]

Where:

CTOC = concentration of TOC minus methane and

ethane, dry basis, in parts per million by volume

[ppmv];

x = number of samples in the sample run;

n = number of components in the sample;

Cji = concentration of sample components j of

sample i dry basis [ppmv]; 4.

HAP

Emissions

Testing b) Correction of TOC or total organic regulated

species shall be corrected to three percent

oxygen if supplemental combustion air is used

to combust the emissions, using Equation 2:

−=

d

mTOCO

CC2%9.20

9.17 [Eq 2]

Where:

CTOC = concentration of TOC or organic regulated

material corrected to 3% O2, dry basis [ppmv];

Cm = concentration of TOC [minus methane and

ethane] or organic regulated material, dry basis

[ppmv];

%O2d = concentration of oxygen, dry basis, [% by

volume];

Each

emissions

performance

test

EU01 &

PCE01

40 CFR

63.997(e)(2) (iii)

subpart SS

Yes



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

5. HAP

Emissions

Calculate percent reduction as follows – use

Equation 3:

( ) ( )

( )100×

+++

+−+=

uciuci

cococici

OOWAEWAE

OWAEOWAEPR [Eq 3]

Where:

PR = percent reduction

WAEci = wet-out area organic HAP emissions

vented to PCE01 [lb/yr];

Oci = oven organic HAP emissions vented to

PCE01 [lb/yr];

WAEu = wet-out area organic HAP emissions not

controlled [lb/yr];

Ou = oven organic HAP emissions not controlled,

[lb/yr];

WAEco = wet-out area organic HAP emissions

from PCE01 outlet [lb/yr]; and

Oco = oven organic HAP emissions from PCE01

outlet [lb/yr]Error! Bookmark not defined.

;

Annually EU01

40 CFR

63.5885(a)

subpart

WWWW

Yes

6. HAP

Emissions

Calculate an organic HAP emissions factor – use

Equation 4 below:

( )GR

OOWAEWAEE cucu

+

+++= [Eq 4]

Where:

E = HAP emissions factor of resin and gel coat,

[lb/ton];

WAEu = uncontrolled wet-out area organic HAP

emissions, [lb/yr];

WAEc = controlled wet-out area organic HAP

emissions, [lb/yr];

Ou = uncontrolled oven organic HAP emissions,

[lbyr];

Oc = controlled oven organic HAP emissions,

[lb/yr]

R = total usage of neat resin plus, tpy; and

G = total usage of gel coat plus, tpy

Annually EU01

40 CFR

63.5890(a)

subpart

WWWW

Yes



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

7.

Closed

Vent

System

Inspection

Except for any closed vent systems that are

designated as unsafe or difficult to inspect by the

Owner or Operator, the closed vent system

constructed of duct work shall be inspected as

follows:

a) Closed vent system inspections shall be

conducted according to USEPA Method 21 of

40 CFR part 60, appendix A;

b) The detection instrument shall meet the

performance criteria of Method 21 of 40 CFR

part 60, appendix A, except the instrument

response factor criteria in §3.1.2(a) of Method

21 must be for the representative composition of

the process fluid and not of each individual

VOC in the stream. For process streams that

contain nitrogen, air, water or other inerts that

are not organic HAP or VOC, the representative

stream response factor must be determined on

an inert-free basis. The response factor may be

determined at any concentration for which the

monitoring for leaks will be conducted;

c) If no instrument is available at the plant site that

will meet the performance criteria of Method 21

specified in Table 6, Item 7.b) above, the

instrument readings may be adjusted by

multiplying by the representative response

factor of the process fluid, calculated on an

inert-free basis as described in Table 6, Item

7.b) above;

d) The detection instrument shall be calibrated

before use on each day of its use by the

procedures specified in Method 21;

Annually EU01 &

PCE01

40 CFR

63.5895(a) &

(b) subpart

WWWW

63.983(b)(1)(ii)

&

63.983(c)

subpart SS

Yes



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

7.

cont

Closed

Vent

System

Inspection

e) Calibration gases shall be as follows:

1). Zero air [less than 10 ppmv hydrocarbon

in air];

2). Mixtures of methane in air at a

concentration less than 10,000 ppmv. A

calibration gas other than methane in air

may be used if the instrument does not

respond to methane or if the instrument

does not meet the performance criteria

specified in Table 6, Item 7.b) above. In

such cases, the calibration gas may be a

mixture of one or more of the compounds

to be measured in air;

3). If the detection instrument’s design

allows for multiple calibration scales,

then the lower scale shall be calibrated

with a calibration gas that is no higher

than 2,500ppmv;

f) The owner or operator may elect to adjust or not

adjust instrument reading for background. If an

owner or operator elects not to adjust readings

for background, all such instrument readings

shall be compared directly to 500ppmv to

determine whether there is a leak. If an owner

or operator elects to adjust instrument readings

for background, the owner or operator shall

measure background concentration using the

procedures in g) and h) below. The owner or

operator shall subtract the background reading

from the maximum concentration indicated by

the instrument;

g) If the owner or operator elects to adjust for

background, the arithmetic difference between

the maximum concentration indicted by the

instrument and the background level shall be

compared with 500 ppmv for determining

whether there is a leak;

h) To adjust for background, the arithmetic

difference between the maximum concentration

indicated by the instrument and the background

level shall be compared with 500 ppmv for

determining whether there is a leak;

i) The instrument probe shall be traversed around

all potential leak interfaces as described in

Method 21;

j) Inspections shall be performed when the process

equipment is in normal operation or in use with

any other detectable gas or vapor.

Annually EU01 &

PCE01

40 CFR

63.5895(a) &

(b) subpart

WWWW

&

63.983(c)

subpart SS



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

8.

Closed

Vent

System

Inspection

Any parts of the closed vent systems that are

designated as unsafe to inspect as described in Table

7, Item 16.a) and b) are exempt from the inspection

requirements of Table 6, Item 7 if as follows:

a) If the equipment is determined to be unsafe-to-

inspect because the inspecting personnel would

be exposed to an imminent or potential danger

as a consequence of complying with Table 6,

Item 7;

b) A written plan is in place that requires

inspection of the equipment as frequently as

practical during safe-to-inspect times;

c) If the equipment is determined to be difficult-to-

inspect, and the equipment cannot be inspected

without elevating the inspecting personnel more

than 7 feet [2 meters] above the support surface;

and

d) A written plan requires inspection of the

difficult-to-inspect equipment at least once

every 5 years.

Annually EU01 &

PCE01

40 CFR

63.983(b)(2)

subpart SS

Yes

9.

Continuous

Compli-

ance

Monitoring data shall be collected as follows:

a) Conduct all monitoring required in Table 6,

Items 10, 11 and 13.a) in continuous operation

(or collect data at all required intervals) at all

times that the affected source is operating,

except for monitoring malfunctions, associated

repairs, and required quality assurance or

control activities (including, as applicable,

calibration checks and required zero and span

adjustments); and

b) Data recorded during monitoring malfunctions,

associated repairs, and required quality

assurance or control activities, including data

averages and calculations, or fulfilling a

minimum data availability requirement, may not

be used.

Continu-

ously

EU01

&

PCE01

40 CFR

63.5895(b)

subpart

WWWW

No

Finding: The facility did not conduct the monitoring requirements of Table 6, Item 13.a.

10.

By-pass

Vent

Monitoring

For the by-pass line, visually inspect the seal or

closure mechanism at least once every month to

verify that the valve is maintained in the non-

diverting position, and the vent stream is not

diverted through the by-pass line.

Monthly

EU01

&

PCE01

40 CFR

63.983(b)(4)

subpart SS

Yes



of 37


Item


Applicable

Emission

Unit

Regulatory

Basis Compliant

Thermal

Oxidizer

Combus-

tion

Temper-

ature

a) Monitor and record the temperature in the

combustion chamber; Continuous

11.

b) If the block average temperature reading is less

than the minimum specified in Table 5, Item

10.b), then inspect the unit and take corrective

action to raise the temperature.

As noted by

the manufac-

turer

PCE01 Env-A 906 Yes

Conduct a visual external integrity inspection of the

thermal oxidizer which shall:

a) Include an evaluation of whether all emissions

are being vented through the dedicated stack

exit; and

b) Be conducted by plant personnel familiar with

the operation of the oxidizer and associated

equipment.

Annually

and as

conditions

indicate an

inspection is

warranted 12.

Thermal

Oxidizer

Inspection

c) The CPMS [i.e. temperature monitor] located in

the combustion zone of PCE01 shall be

maintained and calibrated according to

manufacturer’s specifications.

As noted by

the

manufacture

r

PCE01 RSA 125-C:6,

XI Yes

a) Monitor and record the flow or pressure

differential reading at the wet-out area; and

Once per

day

40 CFR

70.6(a)(3)

13. Wet-out

Area b) The flow meters and/or pressure gauges shall be

maintained and calibrated according to the

manufacturer’s specifications.

As noted by

the

manufacture

r

EU01 RSA 125-C:6,

XI

No

Finding: The facility has not been monitoring and recording flow or pressure differential at the wet-out area.

14. Hours of

Operation

The fire pump engine shall be equipped with a

non-resettable hour meter. Continuous EU02

40 CFR

63.6625

subpart ZZZZ

Yes

15.

Sulfur content

of gaseous

fuels

Conduct testing to determine the sulfur content in

grains of sulfur per 100 cubic feet of gaseous

fuel.

Upon written

request by

EPA or the

Division

Facility

wide

Env-A 806.03

(effective

10-31-2010)

Not

Applicable

Finding: The facility has not been requested to conduct testing to determine the sulfur content of the gaseous fuel.

a) Monitor and record the static pressure

reading; and Once per day

16.

Total

enclosure

monitoring b) The gauge shall be maintained and

calibrated according to the manufacturer’s

specifications

As noted by

the

manufacturer

Facility

wide

RSA 125-C:6,

XI Yes



of 37

VII. Compliance with Recordkeeping Requirements

Table 7, below lists the recordkeeping requirements for the facility from TV-0027 and any

deficiencies noted during the evaluation.

Table 7- Recordkeeping Requirements

Item

# Recordkeeping Requirement

Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

1.

The Owner or Operator shall retain records of all

required monitoring data, recordkeeping and

reporting requirements, and support information

for a period of at least 5 years from the date of

origination.

Retain for a

minimum of 5 years Facility Wide

40 CFR

70.6(a)(3)(ii)

(B)

Yes

2.

Regulated Toxic Air Pollutants

Maintain records documenting compliance with

Env-A 1400.

Compliance was demonstrated at the time of

permit issuance as described in the Application

Review Summary prepared by the Division for

permit application 10-0134. The compliance

demonstration must be updated if:

a) There is a revision to the list of RTAPs

lowering the AAL for any RTAP emitted at

the facility;

b) The amount of any RTAP emitted is greater

than the amount that was evaluated in the

Application Review Summary (e.g., use of a

resin will increase);

c) An RTAP that was not evaluated in the

Application Review Summary will be emitted

(e.g., a new resin will be used); and

d) Stack conditions (e.g. air flow rate) change.

Update prior to

process changes and

within 90 days of

each revision of

Env-A 1400

Facility Wide

Env-A 902.01

(State-Only

Enforceable)

Yes

3.

Additional Recordkeeping Requirements -

Facility-wide Emission Limitations

Maintain a 12-month running total of Facility-

wide emissions of VOCs, which shall include

emissions from non-permitted devices, for the

purpose of demonstrating that the total emissions

of these pollutants are below the threshold

specified in Table 5, Item 1.

Monthly Facility Wide

Env-A 906

(effective

4-23-1999)

No

Finding: At the time of the inspection, Kalwall was not maintaining a 12-month running total of facility-wide emissions of VOCs.

However, since the time of the inspection, Kalwall generated a spreadsheet to maintain this running total.

4.

Recordkeeping of deviations from Permit

requirements shall be conducted in accordance

with Section XXVIII of this Permit.

Maintain up-to-date

data Facility Wide

Env-A 911

(effective

4-21-2007)

Yes

5.

Maintain records of actual emissions for each

significant and insignificant activity for

determination of emission based fees.

Annually Facility Wide Env-A 705.03 Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

VOC Recordkeeping Requirements

Record and maintain the following information:

a) Identification of each VOC-emitting process

or device except:

1). Process or devices associated

exclusively with non-core activities;

and

2). Processes or devices emitting only

exempt VOCs;

b) Operating schedule for each VOC-emitting

device/process identified in a) above,

including:

1). Days of operation per calendar week

during the normal operating schedule;

2). Hours of operation per calendar day

during the normal operating schedule

and for a typical high ozone season

day, if different from the normal

operating schedule; and

3). Hours of operation per year under

normal operating conditions;

6.

c) VOC emission data from all VOC-emitting

process/device identified in a) above,

including:

1). Actual VOC emissions for the calendar

year, in tons; and a typical high ozone

season day during that calendar year, in

pounds per day; and

2). The emissions factors and the origin of

the emission factors used to calculate

the VOC emissions

On a continuous

basis Facility Wide

Env-A 901.06

(SIP

Approved)

Not

Applicable

Finding: During the inspection period, VOC emissions have not met or exceeded 10 tpy.

7.

General Recordkeeping Requirements for Process

Operations

Maintain records regarding process operations

including the following information for each

process/device:

a) Monthly hours of operation;

b) Quantity of raw materials used per month;

and

c) Distribution of the process discharges if the

process discharges air pollutants through

more than one discharge point.

Monthly EU01

Env-A 901.04

(SIP

Approved)

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

8.

General Recordkeeping Requirements for

Combustion Devices

Maintain the following records of fuel

characteristics and utilization for the fuel used in

the combustion device:

a) Type (e.g. diesel fuel) and amount of fuel

burned in each device, or type of each fuel

burned in multiple devices and hours of

operation of each device to be used to

apportion fuel use between the multiple

devices;

b) Sulfur content of liquid fuel in terms of

percent sulfur by weight.

Monthly EU02

Env-A 903.03

(effective

10-21-2003)

&

FP-T-0052

Yes

9.

Liquid Fuel Oil Recordkeeping Requirements

A written statement from the fuel supplier that the

sulfur content of the fuel as delivered does not

exceed state or federal standards for that fuel.

Whenever there is a

change in fuel

supplier by at least

annually

EU02

Env-A 806.05

(effective

10-31-2010)

Yes

Reinforced Plastic Composites Production

Recordkeeping Requirements

Records of the following information:

a) A copy of each notification and report that

was submitted to the Division and the

documentation supporting each notification

and report;

10.

b) Performance tests as required in Table 6,

Item 3;

c) All data, assumptions and calculations used

to determine organic HAP emissions factors

or average organic HAP contents for EU01;

d) Certified statement that you are in

compliance with the work practice standards

required in Table 5, Item 6.)a);

e) When complying with the percent reduction

and/or lb/ton requirements specified in Table

5, Item 4:

Continuously EU01

40 CFR

63.5915

subpart

WWWW

&

63.10(b)

subpart A

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

1). Keep all data, assumptions, and

calculations used to determine percent

reduction and/or lb/ton as applicable;

2). Keep a brief description of the

rationale for the assignment of an

equation or factor to each formula;

3). When using facility-specific organic

HAP estimation equations, or factors,

you must keep all data, assumptions,

and calculations used to derive the

organic HAP emissions estimation

equations and factors and identification

and rational for the worst-case formula;

and

4). For all organic HAP emissions

estimation equations and organic HAP

emissions factors, you must keep

documentation that the appropriate

permitting authority has approved

them.

40 CFR

63.5915(e)

subpart

WWWW

f) Determine how much neat resin plus and neat

gel coat plus is applied to the line each year:

1). Track formula usage by end

product/thickness combinations;

2). Use in-house records to show usage.

This may be either from automated

systems or manual records;

3). Daily usage of each formula/end

product combination on each line,

recorded at the end of each run (i.e.,

when a changeover in formulation or

product is made), and at the end of the

shift;

4). Sum the amounts from the daily

records collected according to 3) above

to calculate annual usage of each

formula/end product combination by

line;

5). Resin and gel coat use, which may be

based on purchase records if the Owner

or Operator can reasonably estimate

how the resin is applied;

40 CFR

63.5880

&

63.5915(c)

subpart

WWWW

10

cont.

g) Organic HAP content, which may be based

on MSDS or on resin specifications supplied

by the resin supplier; and

h) The operation where the resin is used if you

are meeting any organic HAP emissions

limits based on an organic HAP emissions

limit in Table 5, Item 4.

Continuously EU01

40 CFR

63.5900(c)

subpart

WWWW



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

CPMS Recordkeeping Requirements

Keep the following records for the continuous

monitoring systems (CPMS):

a) All required CPMS measurements, including

monitoring data recorded during unavoidable

CPMS breakdowns and out-of-control

periods;

b) The date and time identifying each period

during which the CPMS was inoperative

except for zero (low-level) and high-level

checks;

c) The date and time identifying each period

during which the CPMS was out of control;

11.

d) The specific identification (i.e., the date and

time of commencement and completion) of

each period of excess emissions and

parameter monitoring exceedances, that

occurs during startups, shutdowns, and

malfunctions;

e) The nature and cause of any malfunction;

f) The corrective action taken or preventative

measures adopted;

g) The nature of the repairs or adjustments to

the CPMS that was inoperative or out of

control;

h) The total process operating time during the

reporting period; and

i) All procedures that are part of a quality

control program developed and implemented

for the CPMS under Table 5, Item 9.

Continuously PCE01

40 CFR

63.10(c)

subpart A

&

63.998(d)(5)

subpart SS

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

Continuous Records and Monitoring System Data

Handling

a) CPMS combustion temperature of PCE01 as

follows:

1). Values measured at least once every 15

minutes or each measured value for

systems which measure more

frequently than once every 15 minutes;

or

2). Block average values for 15-minute or

shorter periods calculated from all

measured data values during each

period or from at least one measured

data value per minute if measured more

frequently than once per minute.

3). Where data is collected from an

automated CPMS, the Owner or

Operator may calculate and retain

block hourly average values from each

15-minute block average period or

from at least one measured value per

minute if measured more frequently

than once per minute, and discard all

but the most recent three valid hours of

continuous (15-minute or shorter)

records, if the hourly averages do not

exclude periods of CPMS breakdown

or malfunction. An automated CPMS

records that measured data and

calculates the hourly averages through

the use of a computerized data

acquisition system.

12.

b) Excluded CPMS data identified below shall

not be included in any average computed to

determine compliance with an emission limit:

1). Monitoring system breakdowns,

repairs, preventive maintenance,

calibration checks, and zero (low-level)

and high-level adjustments;

2). Periods of non-operation of the wet out

area for EU01and PCE01;

3). Startups, shutdowns, and malfunctions,

if the Owner or Operator operates the

source during such periods in

accordance with Table 5, Item 6 and

maintains the records in Table 7, Item

13 below.

Continuously PCE01

40 CFR

63.998(b)(1)

subpart SS

40 CFR

63.998(b)(2)

subpart SS

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

12

cont.

c) Records of daily averages for the combustion

temperature of PCE01 shall:

1). Be calculated from data meeting the

requirements of Table 7, Item 12.a)

and b) above for each operating day;

2). Cover a 24-hour period if operation is

continuous, or the period of operation

per operating day if operation is not

continuous;

3). If all recorded values are greater than

or equal to the temperature in Table 5,

Item 10.b), the Owner or Operator may

record that all values were in

compliance rather than calculating and

recording a daily average for that

operating day, and must retain the

recorded values.

13.

Startup, Shutdown and Malfunction

Recordkeeping Requirements

Keep the following records related to startup,

shutdown, and malfunction:

a) Keep records of each startup, shutdown

and/or malfunction event if the procedures in

the SSMP were followed, including the

occurrence and duration of each startup,

shutdown or malfunction for the air pollution

control equipment;

b) Record the actions taken if an action taken

during a startup, shutdown, or malfunction

(including an action taken to correct a

malfunction) is not consistent with the

procedures specified in the SSMP, and the

source exceeds the applicable emission

limitation specified in Table 5, Item 4; and

c) Keep the written SSMP on record after it is

developed to be made available for inspection

upon request, for the life of the affected

source; and

d) If the SSMP is revised, previous versions of

the SSMP shall be kept for a period of 5

years and be made available for inspection

upon request.

Continuously

EU01

&

PCE01

40 CFR

63.5915(a)

subpart

WWWW,

63.998(d)(3)

subpart SS

&

63.6(e)(3)

subpart A

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

14.

Additional Recordkeeping Requirements -

Pollution Control Equipment

Maintain records of all air pollution control

equipment activities required in Table 6,

including:

a) Pressure differential and/or flow

measurements at the wet out area;

b) Air pollution control equipment inspection

and maintenance activities including

calibration and validation checks as specified

by the manufacturer; and

c) Corrective actions.

As specified in

Table 6 EU01 & PCE01

Env-A 906

&

40 CFR

63.998(b)(1)

subpart SS

No

Finding: Kalwall did not maintain pressure differential and/or flow measurements at the wet out area.

15.

Add-on Pollution Control Equipment

The Owner or Operator of any stationary source

or device with add-on VOC control equipment

shall maintain the following information:

a) The air pollution control device identification

number, type, model number, and

manufacturer;

b) Installation date;

c) Processes or devices controlled;

d) The type and location of the capture system,

capture efficiency percentage, and method of

determining capture efficiency;

e) Information as to whether or not the control

device is always in operation when the

processes or devices are in operation;

f) Pressure differential and/or flow

measurements for each capture

device/enclosure;

g) The destruction or removal efficiency of the

add-on pollution control equipment,

including:

1). Destruction or removal efficiency, in

percent;

2). Date tested;

3). The emission test results, including:

i) The inlet VOC concentration in

ppm;

ii) The outlet VOC concentration in

ppm; and

iii) The method of determination of

the inlet and outlet concentrations

in i) and ii) above; and

iv) The design combustion

temperature in °C.

Continuously

EU01

&

PCE01

Env-A 904.07

(SIP

Approved)

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

Closed Vent System Recordkeeping

a) The identification of all parts of the closed

vent system that are designated as unsafe or

difficult to inspect;

b) An explanation of why the equipment is

unsafe or difficult to inspect;

c) The plan for inspecting the equipment

required in Table 6, Item 7;

d) Leak inspections as required in Table 6, Item

7, record the following:

1). The date of the inspection; and

2). A statement that no leaks were

detected, if no leaks are detected,;

16.

e) When a leak is detected record the following:

1). The instrument and the equipment

identification number and the operator

name, initials or identification number;

2). The date the leak was detected and the

date of the first attempt to repair the

leak;

3). The date of successful repair of the

leak;

4). The maximum instrument reading

measured by the procedures in Table 6,

Item 7; after the leak is successfully

repaired or determined to be non-

repairable; and

5). “Repair delayed” and the reason for the

delay if a leak is not repaired within 15

days after discovery of the leak;

Continuously

EU01

&

PCE01

40 CFR

63.998(d)(1)

subpart SS

Yes

17.

By-pass system Recordkeeping:

a) Hourly records of:

1). Whether the flow indicator was

operating;

2). Whether a diversion was detected at

any time during the hour; and

3). The times of all periods when the vent

stream is diverted from the control

device; or

4). The flow indicator is not operating;

Continuously

EU01

&

PCE01

40 CFR

63.998(d)(1)

(ii) subpart SS

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

17.

cont

Where a seal mechanism is used to comply with

Table 5, Item 3, hourly records of flow are not

required, but record:

1). The monthly visual inspection of the

seals or closure mechanisms has been

done; and

2). Occurrences of all periods when the

seal mechanism is broken, or the

bypass line valve position has changed,

or the key for the lock-and-key type

lock has been checked out, and records

of any car-seal that has been broken.

Continuously

EU01

&

PCE01

40 CFR

63.998(d)(1

)(ii) subpart SS

Equipment Leak Recordkeeping

a) Design specifications and performance

demonstrations as follows:

1). Detained schematics, design

specification of the control

device[PCE01] and piping and

instrumentation diagrams;

2). Dates and descriptions of any changes

in the design specifications; and

3). Description of the parameter or

parameters monitored, as required in

Table 6, to ensure that PCE01 is

operated and maintained in

conformance with its design and an

explanation of why that parameter was

selected for the monitoring;

For the life of the

equipment

40 CFR

63.998(d)(4)(i)

subpart SS

18.

Dates and durations of:

1). When the closed vent systems and

control device required are not

operated as designed as indicated by

the monitored parameters;

2). When the monitoring system or

monitoring device is inoperative; and

3). Startups, shutdowns, and malfunctions

of PCE01.

Retain for 5 years

EU01

&

PCE01

40 CFR

63.998(d)(4)

(ii) subpart SS

Yes

19.

Fire Pump Engine Operation Log

The Owner or Operator shall keep records of the

hours of operation of the engine that is recorded

through the non-resettable hour meter, and must

document:

a) How many hours are spent for emergency

operation, including what classified the

operation as emergency; and

b) How many hours are spent for non-

emergency operation.

Keep a running log EU02

40 CFR

63.6655

subpart ZZZZ

Yes



of 37


Item


Records Retention/

Frequency

Applicable

Emission Unit

Regulatory

Basis Compliant

20.

Gaseous Fuel Recordkeeping

Maintain one of the following:

a) Sulfur content as percent sulfur by weight or

in grains per 100 cubic feet of fuel; or

b) Documentation that the fuel meets state sulfur

limits.

For each delivery of

LPG fuel to the

Facility

Facility wide

Env-A 806.05

&

Env-A 903.03

Yes

21.

Additional Recordkeeping Requirements –

Permanent Total Enclosure

Maintain records of permanent total enclosure as

required in Table 6, Item 16 including:

a) Static pressure reading of the building;

b) Gauge inspection and maintenance activities

including calibration and validation checks as

specified by the manufacturer; and

c) Corrective actions.

As specified in

Table 6 EU01 & PCE01 Env-A 906 Yes

VIII. Compliance with Reporting Requirements

Table 8, below, lists the reporting requirements for the facility from TV-0027 and any

deficiencies noted during the inspection.

Table 8- Reporting Requirements

Item # Requirement Frequency Applicable

Emission Unit

Rule

Citation Compliant

1.

Certification of Accuracy

Any report submitted to the DES and/or EPA shall

include the certification of accuracy statement

outlined in Section XXI.B of this Permit and shall be

signed by the responsible official.

As specified in

Section XXI.B. Facility Wide

40 CFR

70.6(c)(1) Yes

2.

Semi-annual Permit Deviation and Monitoring

Report

The Owner or Operator shall submit a semi-annual

permit deviation and monitoring report, which

contains:

a) Summaries of all monitoring and testing

requirements contained in this Permit; and

b) A summary of all permit deviations and

excursions that have occurred during the

reporting period.

Semiannually

received by DES no

later than July 31st

and January 31st of

each calendar year

Facility Wide

Env-A 911

&

40 CFR

70.6(a)(3)

(iii)(A)

Yes



of 37



Emission Unit

Rule

Citation Compliant

3.

Annual Emissions Report

Submit an annual emissions report which shall

include the following information:

a) Each fuel burning device – Actual calendar year

emissions of NOx, CO, SO2, VOCs, and TSP;

b) Each process device – Actual calendar year

emissions of VOCs (speciated by individual

VOC), HAPs (speciated by individual HAP),

and RTAPs (reported by CAS number);

c) The methods used in calculating such emissions

in accordance with Env-A 705.02,

Determination of Actual Emissions for Use in

Calculating Emission-Based Fees; and

d) The information recorded in accordance with

Table 7, Items 6 and 7 compiled on a monthly

basis.

Annually (received

by DES no later than

April 15th

of the

following year)

Facility Wide Env-A

907.01 Yes

4.

VOC Reporting Requirements

If the actual annual emission for the facility are

greater than or equal to 10 tpy, the Owner or

Operator shall submit each year the following

information:

a) Facility information including:

1). Source name;

2). Standard Industrial Classification (SIC)

Code;

3). North American Industrial Classification

System (NAICS) code;

4). Physical address; and

5). Mailing address.

b) A break down of VOC emissions reported

pursuant to Table 7, Item 6 by month; and

c) All data recorded pursuant to Table 7, Item 7.

Annually (received


April 15th

of the

following year)

Facility Wide

Env-A 908

(effective

4-21-2007)

Not

Applicable

Finding: During the inspection period, VOC emissions have not met or exceeded 10 tpy.

5.

Payment of Emission-Based Fee

Annual reporting of emission based fees shall be

conducted in accordance with Section XXIII of this

Permit.

Annually (received


April 15th

of the

following year)

Significant

&

Insignificant

Activities

Env-A

705.04 Yes

6.

Permit Deviation

Prompt reporting of deviations from Permit

requirements shall be conducted in accordance with

Section XXVIII of this Permit.

Prompt reporting

(within 24 hours of

an occurrence)

Facility Wide

40 CFR

70.6(a)(3)(i

ii) (B)

Yes

7.

Annual Compliance Certification

Annual compliance certification shall be submitted in

accordance with Section XXI of this Permit.

Annually (received


April 15th of the

following year)

Facility Wide 40 CFR

70.6(c)(1) Yes



of 37



Emission Unit

Rule

Citation Compliant

Semiannual Compliance Report

The semiannual compliance report shall contain the

following information:

a) Company name and address;

Statement by a responsible official with that

official’s name, title, and signature, certifying the

truth, accuracy, and completeness of the content of

the report;

b) Date of report and beginning and ending dates of

the reporting period;

c) If there was a startup, shutdown or malfunction

during the reporting period, and the Owner or

Operator took action consistent with the SSMP,

include the information in Table 8, Item 9.a)

below;

8.

d) If there were no deviations, a statement that:

1). There were no deviations from the

emission limitations specified in Table 5,

Item 4 during the reporting period;

2). There were no deviations from the work

practice requirements specified in Table 5,

Item 6.a);

3). There were no periods during which the

CPMS systems were out of control as

specified in Table 6, Item 9 during the

reporting period;

e) If there was a deviation from the emission

limitation specified in Table 5, Item 4 and/or for

each deviation from a work practice requirement

specified in Table 5, Item 6.a):

1). The information contained in Table 8,

Item 8.a), b) and c) above;

2). The total operating time of each affected

source during the reporting period; and

3). Information on the number, duration, and

cause of deviations (including unknown

cause, if applicable), as applicable, and

the corrective action taken.

Semiannually – no


and January 31st of

each calendar year

to DES and EPA

EU01

&

PCE01

40 CFR

63.5910(c)

subpart

WWWW

&

63.999(c)

subpart SS

Yes



of 37



Emission Unit

Rule

Citation Compliant

f) For the CPMS, the information recorded

required in Table 7, Item 12 when:

1). The daily average value is outside the

bounds specified in Table 5, Item 10.b);

or

2). The following data availability

requirements are not met:

i) The daily average value is outside the

permitted range;

ii) When the period of control device

operation is 4 hours or greater in an

operating day and monitoring data are

insufficient to constitute a valid hour

of data for at least 75 percent of the

operating hours;

iii) When the period of control device

operation is less than 4 hours in an

operating day and more than one of

the hours during the period of

operation does not constitute a valid

hour of data due to insufficient

monitoring data; and

iv) Monitoring data are insufficient to

constitute a valid hour of data, if

measured values are unavailable for

any of the 15-minute periods within an

hour;

1). Whether the excursion was excused or

unexcused; and

2). For excursions caused by lack of

monitoring data, specify the duration of

periods when monitoring data were not

collected.

g) For the closed vent system, the information

recorded in Table 7, Item 16.e);

8. cont

h) When emissions bypassed the add-on control

device during the semiannual reporting period:

1). Date and time period of any bypass of the

add-on control device;

2). Date and time period when:

i) When maintenance is performed on

car-seal valves;

ii) When the seal is broken;

iii) When the by-pass lime valve position

is changed; or

iv) The key for the lock-and-key type

configuration has been checked out.

Semiannually – no


and January 31st of

each calendar year

to DES and EPA

EU01

&

PCE01

40 CFR

63.999(c)

subpart SS



of 37



Emission Unit

Rule

Citation Compliant

Startup, Shutdown, Malfunction Report

Submit the following to USEPA Region 1 and the

Division if there was a startup, shutdown or

malfunction during the semiannual reporting period:

a) For actions consistent with the SSMP and if the

startup or shutdown causes the source to exceed

any applicable emission limitations specified in

Table 5, Item 4:

1). Summary of actions taken to minimize

emissions during such startups, shutdowns

and malfunctions;

2). The number, duration and a brief

description for each type of malfunction

which occurred during the reporting

period which caused or may have caused

an exceedance of the emission limits in

Table 5, Item 4;

3). The SSM report shall include the name,

title, and signature of the Owner or

Operator or other responsible official who

is certifying accuracy;

With the

Semiannual Report

40 CFR

63.5910(c)(

4) subpart

WWWW

&

63.10(d)(5)

(i) subpart

A

9. b) For actions inconsistent with the SSMP and the

startup or shutdown or malfunction causes the

source to exceed the applicable emission

limitations specified in Table 5:

1). Summary of actions taken to minimize

emissions during such startups, shutdowns

and malfunctions;

2). The number, duration and a brief

description for each type of malfunction

which occurred during the reporting

period which caused or may have caused

an exceedance of the emission limits in

Table 5, Item 4;

3). The SSM report shall include the name,

title, and signature of the Owner or

Operator or other responsible official who

is certifying accuracy;

4). Explanation of the circumstances of the

event;

5). The reasons for not following the SSM

plan describing all excess emission and/or

parameter monitoring exceedances which

are believed to have occurred; and

6). Actions taken to minimize emissions.

Within 2 working

days after

commencing

inconsistent actions

& a letter within 7

working days after

the end of the event

EU01

&

PCE01

Yes



of 37



Emission Unit

Rule

Citation Compliant

10.

Performance Test Reporting

Submit the performance test report to the Division

within 60 days after the completion of testing

required in Table 6, Item 3, which shall meet the

reporting requirements specified in Env-A 802.11,

including the following:

a) A brief process description;

b) The type and quantity of HAPs emitted, reported

in units and averaging times and in accordance

with the test methods specified in Table 6, Item

3;

c) Sampling site description;

d) Description of sampling and analysis procedures

and any modifications to standard procedures;

e) Quality assurance procedures;

f) Record of operating conditions during the test,;

g) Record of preparation of standards;

h) Record of calibrations;

i) Raw data sheets for field and laboratory

analyses;

j) Description of the air pollution control

equipment, and the control efficiency (percent);

k) Documentation of calculations;

l) Any other information required by the test

method;

m) The specific range of the monitoring parameter

(i.e. PCE01 combustion temperature, and wet-

out area and oven flow) based on parameter

values measured during the performance test

specified in Table 6, Item 3; and

n) Signed by the responsible official certifying the

accuracy and attesting to whether the Facility

has complied with the standard.

Within 60 days after

the completion of

testing

EU01

&

PCE01

Env-

A802.11,

40 CFR

63.999(a)

(2),

63.999(a)

(3)

subpart SS,

63.5905(a)

subpart

WWWW

&

63.9(h)

subpart A

Yes

IX. Permit Deviations

Kalwall is aware of the recordkeeping and reporting requirements for permit deviations.

However, during the inspection period, Kalwall did not report any permit deviations.

X. Other Findings

There were no other findings.



of 37

XI. Enforcement History and Status

During the inspection period, there has been no enforcement action against Kalwall.

XII. Compliance Assistance, Recommendations and Corrective Actions

During the inspection, no compliance assistance was required and the facility made the following

corrective action:

• Kalwall set up a spreadsheet to track its 12-month running total of VOC emissions in order to

comply with Table 7, Item #3.

Based on the findings of this compliance evaluation, DES recommends the following action to

bring the facility into compliance with future reporting requirements:

• Within 30 days of the date of this report, submit to DES a plan to comply with the monitoring

and testing requirements of Table , Item #13.a; and

• Continue to maintain a 12-month running total of VOC emissions.

Report Prepared By: Daniel F Hrobak

Title:

Senior Compliance Assessment Engineer

Signed:

The State of New Hampshire DEPARTMENT OF … · The New Hampshire Department of Environmental...

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