COUNCf.L~-;:-::;:-;:::-;~-::-::~---. 0 lE©lED~lE n

THE NEW HAMPSHIRE AIR RESOURCES COUNCf.L~-;:-::;:-;:::-;~-::-::~---.

0 lE©lED~lE n IN THE MATTER OF

NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES TEMPORARY PERMIT TP-0256 GRANTED FEBRUARY 11,2020 TO SAINT GOBAIN PERFORMANCE PLASTICS FACILITY ID: #3301100165

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MAR 1 0 2020 u TOWN OF MERRIMACK, NH APPEAL

The Town of Merrimack hereby submits, by and through its attorneys, Drummond Woodsum, an appeal of the February II, 2020 Temporary Permit (No. TP-0256) issued by the New Hampshire Department of Environmental Services (NHDES) to Saint-Gobain Performance Plastics Corporation (SGPP) pursuant to RSA 125-C: 12, (III) and 12-0:14, I-a(a) and (I-h) ("Permit").

I. Appellant Parties:

Eileen Cabanel Town Manager Town of Merrimack

6 Baboosic Lake Road Merrimack, NH 03054 (603) 424-2331 ecabanel @merrimacknh.gov

Sarita Croce Assistant Director Public Works Department/Wastewater

Town of Merrimack 6 Baboosic Lake Road Merrimack, NH 03054 (603) 420-1620 scroce@ merrimacknh. gov

II. Appellant Appeal Representation:

Joanna Tourangeau, Esq.

P~tition for Appeal ofTP-0256 Air Resources Council

Drummond Woodsum 84 Marginal Way, Suite 600 Portland, ME 0410 I-2480 (207) 772-I94I [email protected]

III. Appellate Jurisdiction:

March 10, 2020 Page 2 of 10

The New Hampshire Air Resources Council (Council) has jurisdiction to hear all administrative appeals from department decisions relative to the functions and responsibilities of the division of air resources and shall decide all disputed issues of fact in such appeals, in accordance with RSA 2I-O: I4, RSA 2I-O: I I, IV.

IV. Laws Supporting the Requested Relief:

I25-C: I 0-e Requirements for Air Emissions of Perfluorinated Compounds Impacting Soil and Water: I. For the purposes of this section: (a) "Best available control technology" means "best available control technology" as defined in RSA I25-C: 10-b, I( a). (b) "Ambient groundwater quality standard" means "ambient groundwater quality standard" as defined in RSA 485-C:2, I. (c) "Surface water quality standard" means "surface water quality standard" established in or pursuant to RSA 485-A. (d) "Perfluorinated compounds" or "PFCs" means the list of compounds identified in paragraph I .1 of Environmental Protection Agency Document#: EP A/600/R-08/092 Method 537. "Determination of Selected Perfluorinated Alkyl Acids in Drinking Water by Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS)", Version 1.1 (September 2009). (e) "Precursor" means any substance that has been shown by sound science to be transformed into a PFC under ambient conditions reasonably expected to occur in New Hampshire. II. A device that emits to the air any PFCs or precursors that have caused or contributed to an exceedance of an ambient groundwater quality standard or surface water quality standard as a result of the deposition of any such PFCs or precursors from the air, shall be subject to the determination and application of best available control technology. Within 6 months of the department determining that the device is subject to such control technology, the owner of the device shall submit to the department an application for a permit. Within I 2 months of permit issuance, the applicant shall complete construction and installation of controls consistent with the permit. Operation of the source may continue through the permitting, construction, and installation time period. A source which can demonstrate to the department that its device no longer contributes to an exceedance of an ambient groundwater quality standard or surface water quality standard shall be exempt from this section. III. The construction, installation, or modification of any device that has the potential,

Peiition for Appeal ofTP-0256 Air Resources Council


based on an applicability threshold adopted by the department, to cause or contribute to an exceedance of an ambient groundwater quality standard or surface water quality standard as a result of the deposition of any PFCs or precursors from the air, shall be prohibited without first applying for and obtaining a permit from the department that establishes emission limitations for such device based on best available control technology. IV. Part of the initial application for a permit under this section shall include an analysis of best available control technology for controlling emissions.Any-permit-isslled-&haU-- -----------contain inspection, testing, and reporting requirements, as applicable, to ensure the conditions of the permit are met. V. Any determination of best available control technology under this section shall be subject to the following: (a) In no event shall application of best available control technology result in: (I) Emission of any air contaminant that would exceed the emissions allowed by any applicable standard under RSA 125-C or RSA 125-I or rules adopted pursuant to either chapter. (2) Emission of any air contaminant subject to this section in an amount disproportionate to the emissions of such air contaminant from other similar air pollution control devices for that air contaminant at facilities using similar technology. (3) Emission of any air contaminant subject to this section which causes or contributes to or has the potential to cause or contribute to an exceedance of an ambient groundwater quality standard or surface water quality standard, as a result of the deposition of the contaminant from the air. (b) If the department determines that the facility has more than one device that emits air contaminants subject to this section, the department shall determine best available control technology emission limitations for each such device.

125-C: 10-b Best Available Control Technology: For the purposes of this section: (a) "Best available control technology" means an emission limitation based on the maximum degree of reduction for each air contaminant that would be emitted from any device that the department, on a case-by-case basis, taking into account energy, environmental, public health, and economic impacts and other costs, determines is achievable for such device through application of production processes or available equipment, methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such air contaminant.

125-C: II Permit Reguired: I. The construction, installation, operation, or modification of any device or non-Title V source as defined under RSA 125-C:2, and as further defined by rules adopted by the commissioner shall be prohibited unless the source possesses a temporary permit or operating permit whether a permit-by-notification, general permit, or an individual operating permit issued by the commissioner. The commissioner may by rule exempt certain devices or non-Title V sources from the requirements of this section. I-a. The construction, installation, operation, or modification of an affected source shall

Petition for Appeal ofTP-0256 Air Resources Council

March 10, 2020 Page4 of 10

be prohibited unless the affected source possesses and complies with a temporary permit, general permit, or individual operating permit issued by the commissioner in accordance with the requirements of the Clean Air Act. The term of the general permit or permit to operate shall not exceed 5 years. II. A temporary permit, which may contain conditions, shall be required prior to commencement of construction or installation of any new or modified device or non-Title V source except for those devices or non-Title V sources which are authorized to

______ u ________ construct and operate pursuant to a permit-by-notification or a general permit. A temporary permit shall be in effect until it expires, an operating permit is issued, or until sooner revoked by the commissioner. Such permit shall contain the emission limits the device or non-Title V source is required to meet, and shall be issued by the commissioner upon a finding that the device or non-Title V source will meet such limits and will not result in a violation of any air quality standard or regulation in force under this chapter.

125-1:5 Compliance; Permit Required: (entirety of 125-I applicable but not reproduced here) I. No person shall operate any device or process at a stationary source that emits a regulated toxic air pollutant without a temporary or operating permit issued by the department in accordance with this chapter or RSA 125-C, provided, however, that no permit or permit application shall be required for any device or process at a stationary source exempted under RSA 125-1:3, III, or whose uncontrolled emissions of regulated toxic air pollutants do not exceed ambient air limits at or beyond the compliance boundary and for which no other permit is required under RSA 125-C. New Hampshire Code of Administrative Rules Env-A 1400 implements RSA 125-I relative to preventing, controlling, abating, and limiting the emissions of toxic air pollutants into the ambient air. The ambient air limits ("AALs") established in this chapter are intended to promote public health by reducing human exposure to toxic air pollutants as required by RSA 125-I: 1.

Chapter Env-A 1400 REGULATED TOXIC AIR POLLUTANTS

V. Statement of Appeal

The Permit impermissibly allows SGPP operation of sources of perfluorinated

compounds and their precursors (including PFOA) within the Town of Merrimack, NH' ("Town") without controls (i.e. uncontrolled emissions) in violation of the Clean Air Act, and multiple New Hampshire statutes including RSA 125-C:10-e; 125-C:11; and 125 I:5. 2 In addition to this fundamental failure, the Permit does not apply the best av~ilable

1 The Town has standing as the municipal body charged with preserving the health, safety and welfare of persons and property within its boundaries. health, safety and welfare of persons and property 2 Section III of the Permit specifies that "operation of the source may continue through the construction and installation period." This period is "within 12 months of permit issuance." RSA 125-C: 10-e became effective in 2018. In other words, SGPP has emitted PFCs for years, in violation of the law. Those PFCs contaminated groundwater and drinking water. The Permit allows SGPP to continue to violate while it constructs a control device that will reduce the magnitude of-but not clirninatc~its violation of applicable limits for groundwater.

P~titionfor Appeal ofTP-0256 Air Resources Council

March 10, 2020 PageS of 10

control technology ("BACT") for SGPP perfluorinated compounds and precursors ("PFCs") emissions. Nor does the Permit require implementation of BACT to prevent SGPP PFCs emissions from causing or continuing to contribute to exceedances of ambient groundwater quality standards (AGQS) resulting from deposition of PFCs. Further, the Permit and supporting documentation fail to calculate SGPP's potential to emit HF. As such, the Permit allows SGPP to underestimate HF emissions in order to avoid demonstrated noncompliance with ENV -A 1400 regulation of Regional Toxic Air Pollutants ("RT AP"). The Town respectfully requests that the Air Council amend the Permit:

1. To prohibit uncontrolled emissions of PFCs from SGPP; 2. to apply the emissions limits for PFCs set forth in the February 11, 2020 Permit

Application Review Summary prepared by NHDES ("Permit Summary") at 10, with continuous optimization requirements because of the existing contamination of groundwater caused by SGPP operations; and

3. require installation of a HF scrubber simultaneous with construction of the RTO. 3

A. The Permit does not Implement BACT to Prevent SGPP emission of PFCs from Violating New Hampshire's Groundwater Quality Standards.

NHDES "determined that devices operated at SGPP have emitted and continue to emit to

the air PFCs." Permit at 3. PFC emissions must be controlled by BACT. RSA 125-C:IO

e. Therefore, SGPP devices emitting PFCs are subject to the application of BACT. Specifically, BACT is defined as "an emission limitation based on the maximum degree of reduction for each air contaminant that would be emitted from any device that the [ ... NHDES ... ], to on a case-by-case basis, taking into account energy environmental public health, and economic impacts and other costs, determined is achievable for such device through application of production processes or available equipment, methods,

systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such in identifying all control options, eliminating

technically infeasible options, ranking the remaining options by control effectiveness, then selecting the most effective control as BACT. RSA 125-C: 10-b, I( a).

The Permit identifies a Regenerative Thermal Oxidizer ("RTO") as BACT. The Town agrees with the conclusion that an RTO is the preferred technology for BACT for PFCs. Contrary to statute, the Permit does not require implementation of sufficient BACT

3 The Town does not appeal identification of the RTO as the preferred BACT technology. As such, the Town respectfully requests that the Permit's twelve month timeline for completion of construction and installation of the RTO continue to run from the February II, 2020 issuance of the Permit and not be delayed by this Appeal. The RTO design should not require changes as the PFCs emissions limits sought by the Town were in the Draft Permit and the Permit Summary indicates that SGPP should be completing simultaneous design for a HF scrubber.



limitations to avoid exceedances of AGQS for PFCs because it eliminated and altered

emissions limits for PFCs. Further, the Permit fails to require continuous optimization of operation of the RTO in order to achieve minimal PFCs emissions.

I. The Permit does not Include the Emissions Limits for PFCs that NHDES Concluded were Necessary to meet the Cause or Contribute Standard.

After selection of BACT, the implernentation of BACT cannot cause, or contribute to, or have the potential to cause or contribute to an exceedance of an ambient groundwater quality standard ("AGQS") or surface water quality as a result of the deposition of the contaminant from the air. RSA 125-C: 10-e ("Cause or Contribute Standard").

The Permit does not comply with BACT because it inexplicably increased emission rates for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) and deleted emissions limits for PFNA and PFHxS from those established by NHDES in its Cause or Contribute determination, without any explanation or justification.4 Permit Summary at 10.

Specifically, the Permit Summary states that "[t]o address the issue of "Cause or

Contribute", the permit also contains limit on annual maximum allowable PFC emissions which were developed for each of the PFCs for which an AGQS currently exists.[ ... ]

The maximum annual PFC emission limits are 0.075 lbs per year PFOA, 0.048 lbs/yr PFOS, 0.024lbs/yr PFNA, and 0.015 lbs/yr PFHxS." /d.

However, the Permit states: "[f]or the purpose of ensuring that the application of BACT will not cause or contribute to an exceedance of an AGQS or SWQS, the maximum

annual controlled PFC emission limits shall be less than or equal to 0.45 lbs/yr PFOA and 0.57 lbs/yr PFOS." Permit Table 5, Item 5(f)5• These Permit emissions limits for PFOA and PFOS are significantly higher than those in the Permit Summary (in the case of PFOA nearly an order of magnitude larger) and the Permit contains no other emissions

limits for PFCs or emissions limit reopeners to address soon-to-be revised and updated AGQS.6

4 In addition to having no explanation or justification in the Permit Summary, the Permit limits for PFOA and PFOS and Permit elimination of emissions limits PFNA and PFHxS were never available for comment or review in the Draft Permit or otherwise and thus these changes do not comply with the required NHDES process or provide fundamental due process. 5 Every reference to the PFCs emissions limits in the Permit incorrectly references Table 5, Item 5(g) instead of 5(1). 6 NHDES is currently enjoined from enforcing lowered AGQS for PFCs (including PFNA and PFHxS) presented in its Final Rules regarding PFCs issued in June, 2019. While there are not currently AGQS applicable to all PFCs, it is reasonable to expect that there will be AGQS for additional PFCs during the one year life of the Permit and during SGPP operation of the RTO. The Permit should include a provision authorizing reopener for such AGQS for additional PFCs.



Failure to include the emissions limits for PFCs calculated by NHDES under the Cause and Contribute Standard is clear error.

2. RTO Operations must be Continually Optimized to Comply with the Cause or Contribute Standard.

SGPP operations resulted in groundwater that is already above AGQS for PFCs. As such, any emissions of PFCs violate the Cause or Contribute Standard. To comply with the Cause or Contribute Standard, RTO operation must be continuously optimized to minimize emissions of PFCs to the greatest extent possible.

The Permit modified the requirement for PFCs emissions testing in the draft to eliminate testing at the RTO inlet and to only require PFCs emissions testing at the RTO outlet. Permit at Table 7, Item 8(f)(3). Testing at the RTO inlet and the outlet paired with combustion temperature information, is data that is invaluable to determining the effectivity of the RTO at combusting PFCs.7 This is the very heart of the implementation of BACT- the RTO shall effectively address emissions of PFCs. The failure to monitor the effectiveness of the RTO (by requiring testing at both the inlet and the outlet) prevents any evaluation of whether the RTO is serving its intended regulatory purpose as BACT. Given the unique and novel nature of PFCs (which should be obvious given that there are nearly 200 PCFs in SGPP emissions and the EPA can only quantify/identify 89 of them), it is important to obtain information about the RTO destruction efficiencies for different PFCs, depending on the functional groups embodied in the structure of the compound. These differences, if any, should be better understood to ensure that the RTO compliance efficiency is appropriate for all PFCs.

Additional technical enhancements to the RTO optimization program are provided in the attached technical letter from CAAssociates and are incorporated to this appeal including, but not limited to:

1. PFC/PFAS capture and destruction efficiency monitoring. 2. RTO Test Program- testing the inlet and outlet of the RTO for each PFC/PFAS. 3. Outlet Sample Run Times- use longer run times to improve the detection of

PFC/PFAS at the inlet and outlet.

B. SGPP Potential to Emit Hydrogen Fluoride Does not Justify Permit Exclusion of a HF Scrubber.

7 Attached is a copy of an Alabama Title V Major Source Operating Permit for Daikin America, Inc. This permit requires 99.99% destruction removal efficiency for operation of a thermal oxidizer for VOCs. In contrast, the Permit improperly implements a much lower capture rate as BACT.

Petition for Appeal of TP-0256 Air Resources Council


Combustion of PFCs generates hydrogen fluoride ("HF"), a toxic gas which forms corrosive and penetrating hydrofluoric acid upon contact with moisture. The gas is extremely toxic. For example, exposure to HF can cause blindness by rapid destruction of the corneas.

The purpose of the State of New Hampshire Code of Administrative Rules Env-A 1400 is to implement RSA 125-I relative to preventing, controlling, abating, and limiting the

. . f .. II . l b. . 'fl b" . I" . E'"'b") etntsstons o toxic an po utants Illto t 1e ant tent an.1:ese ant teflt atrtmits rHt s are developed based on health-based risk factors.

Stack testing was conducted at SGPP in April and May 2018 by Barr Engineering Co. ("Barr") with analysis conducted by SGS Laboratories. Barr conducted stack testing on the MA and MS Tower exhausts as well as on the QX Tower. Samples from this stack test were sent to the Environmental Protection Agency Office of Research and Development ("EPA ORD"). On June 20, 2019, NHDES received a report of the stack test results from EPA ORD.8 This report stated that the stack testing detected 190 PFAS compounds and tentatively identified 89 of the compounds. Calculation of the potential to emit HF (as fluoride) was based solely on the 89 PFAS compounds identified by EPA ORD and excluded the 101 unidentified PFCs.

Despite accounting for less than half of the PFCs known to be present in SGPP's emissions and with the knowledge that "[i]nstallation and operation of an RTO for PFCs destruction will result in additional HF emissions," Permit Summary at fn. 30, NHDES estimated post-RTO HF emissions of 1,550 lbs/yr versus SGPP's estimate of 146lbs/yr and total post-RTO fluoride ("F") emissions of 1,472lbs/yr versus SGPP's estimate of 138 lbs/yr. The Permit Summary recognized that the methodology for estimating HF and F emissions would underestimate emissions. Permit Summary at 14-15.

The EPA ORD data also provided the basis for developing an emission rate for HF. The maximum predicted 24-hr impact for HF was calculated by the permittee and approved by NHDES at 83% of the 24-Hr ambient air limit (AAL) for HF.

Instead of requiring calculation of SGPP's potential to emit HF inclusive of the I 0 I unidentified addition, the Permit Summary states that the permittee should proceed with the design of an HF scrubber as part of the RTO design process to ensure the facility is ready to implement the HF scrubber as expeditiously as possible should stack testing after installation of the RTO demonstrate noncompliance. This requirement is not in the Permit.

Instead, the Permit requires that within 60 days of start up of the RTO, SGPP shall conduct initial stack testing for HF emissions. Permit at Table 6, Item 14(b). The Permit then provides an additional 30 days after this stack testing to demonstrate compliance with AALs for HF or to provide a "compliance plan and schedule." Permit at Table 8, Item 5.

8 The Permit Summary identifies this as Report #6.

P~tition for Appeal ofTP-0256 Air Resources Council


This approach provides SGPP with an end run around the Env-A 1400 implementation of RSA 125-I. Instead of requiring that SGPP calculate its potential to emit PFCs and to ensure compliance by implementing control technologies for a reduced percentage of the calculated potential emissions, the Permit allows SGPP to avoid installing a HF scrubber based on an underestimate of potential HF emissions. The Permit then allows SGPP months, if not years,9 to implement cost effective control technologies that are known and maclily available to address emissions that the NHDES identifies as underestimated and likely to require a HF scrubber. Permit Summary at 13. There is no basis for NHDES concluding that SGPP will comply with the Permit requirement of 83% of the 24-Hr ambient air limit (AAL) for HF.

The Town undertook calculations to account for the 10 I PFCs that EPA ORD detected but not could not identify. The Town understands the difficulty in determining exactly what factor to use to account for these 10 I compounds. But, doing otherwise results in impermissible exclusion of these compounds from the ~potential to emi( calculation. A low predictive default would be to assume that these compounds are present at their detection level (i.e. that all 101 PFCs detected by EPA ORD were only present at the minimum level necessary for the laboratory to be able to detect them). Use of this low prediction methodology to include the 101 excluded PFCs would result in SGPP potential to emit HF that has not been addressed and could exceed the AAL. Exceedance of the AAL would require either production restrictions or add-on controls to ensure SGPP HF emissions do not exceed the ambient air limit for HF. There is no basis for Permit elimination of a HF scrubber to control HF emissions.

VI. Relief Sought:

Prohibit SGPP uncontrolled emissions.

Amend the Permit emissions limits for PFCs to match those in the Permit Summary and

include emissions limit reopeners should PFC AGQS become effective over the life of the Permit.

Amend the Permit to include optimization requirements for RTO operations in order to comply with the Cause or Contribute Standard.

Amend the Permit to require a HF scrubber to ensure that SGPP emissions do not have the potential to exceed the 24-Hr AAL for HF.

VII. Additional Information Supporting the Appeal:

9 SGPP has twelve months to construct and install the RTO, two more months to conduct initial stack testing (there is no deadline for submission of the report of this initial stack testing) and then another month after submission of the initial stack testing report to NHDES to complete a compliance determination for HF and PFC emissions.

' Petition for Appeal ofTP-0256 March 10, 2020 Page 10 of 10 Air Resources Council

The following information is attached to this appeal:

I. CAAssociates Technical Evaluation dated March 9, 2020; 2. Temporary Permit TP-0256 issued February 11, 2020; 3. NHDES Petmit Application Review Summary issued February 11, 2020; and 4. Title V Major Source Operating Permit for Daikin America, Inc.

Dated: March 10, 2020

_;--

Joanna Tourangeau, NH Bar No. 15180 Counsel for the Town of Merrimack, NH DRUMMOND WOODSUM 84 Marginal Way, Suite 600 Portland, ME 04101-2480 jtourangeau@ dwmlaw .com (207) 772-1941

Paula.M.Scott

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CAAssociates

March 9, 2020

Sarita Croce Assistant Director of Public Works/Wastewater Merrimack Wastewater Treatment Facility 36 Mast Rd Merrimack, NH 03054

Re: Review of Saint-Gobain Performance Plastics Temporary Permit (TP-0256), dated February 11, 2020.

Dear Ms. Croce:

As you requested, I have reviewed several documents relative to the above-referenced Temporary Permit issued to Saint-Gobain Performance Plastics Corporation (the Permittee). The focus of the review was to identify issues that warrant adjustment or revision of the permit requirements to comply with best available control technology (BACT) for the emission of perand polyfuorinated compounds (PFC) and/or polyfluorinated substances (PFAS). Other issues related to the permit are also noted. Although other documents related to the permit were reviewed, the items below are specific to the permit or the accompanying Review Summary.

Please note that several requirements of the permit that relate to the maximum annual allowable controlled PFC emission limitations refer to Table 5, Item 5j[ (Table 6, Item 14.a, Table 6, Item 17.a, and Table 8, Item 5.d). It appears that these references are typographical errors and should instead refer to Table 5, Item 5J

The items of concern are discussed below.

BACT

The BACT emission rates for PFOA and PFOS in the above-referenced perrnit were dramatically higher than the BACT rates presented in the application. These changes appear to have been negotiated and do not appear to have a basis relative to production levels or potential to ernit. NHDES cites RSA 125-C:10-e, stating that" ... the application of BACT cannot cause or contribute to or have the potential to cause or contribute to an exceedance of an AGQS [ambient groundwater quality standard] or SWQS {surface water quality standard] as the result of the deposition of the contaminant from the air." As the groundwater already exceeds the AGQS for both PFOA and PFOS, any detectable emission of either pollutant will contribute to that exceedance. The only way to avoid contribution to an exceedance of an AGQS is to ensure that the emission of PFOA and PFOS are below the detection levels at all times.

By allowing the permit limits of 0.45 Lb/yr (PFOA) and 0.57 Lb/Yr (PFOS), which is significantly higher than the limits set in the draft permit, the NHDES is allowing the permittee to contribute to an exceedance of the applicable AGQS. This is in conflict with RSA 125-C:10-e V(a)(3).

Capture Efficiency Monitoring

Table 6, Item 6.c.) allows the facility to operate for a full year without confirmation that the capture system is working. The overall control efficiency is dependent on both capture

16 Revolutionary Road, Acton, MA 01720-3830 Phone: (978) 263-4895 • Fax: (978) 263-2191 • e-mail: [email protected]

efficiency (CE) and destruction removal efficiency (ORE). The confirmation of the CE should be at least as frequent as the ORE confirmation.

PFC Destruction Efficiency Monitoring

Table 6, Item 11.a.) requires that the permittee monitor the thermal oxidizer combustion chamber temperature at least once every 15 minutes and record the hourly average. With so few data points used as the minimum required for calculating the average, not only does the permittee run the risk of violating the average temperature requirement for a few minutes' worth of low readings, but the state also runs the risk of missing data that might indicate a problem. This would be particularly problematic with an RTO, whose bed cycles are typically between three and five minutes. To properly implement BACT, the monitoring strategies should include more frequent data collection. At a minimum, the monitoring frequency should be commensurate with the need to properly diagnose potential control device compliance issues.

Potential HF Emissions

The Barr report indicated that there were 190 PFAS detected in the Permittee's emissions. Eighty-nine of those compounds were quantified, while 101 of the compounds were not quantified. In a letter to the Permittee, dated June 20, 2019, NHDES indicated that it assumed that all of the fluorine from the 89 PFAS that were quantified were completely converted to hydrogen fluoride (HF). This effectively assigned an emission factor of zero to the 101 compounds that were detected, but not quantified. The Town attempted to quantify the HF emissions for the remaining 101 compounds. This estimation calculation was difficult to perform due to a lab report that only provided response area counts and no documented response factors. Given these constraints, the Town's attempt at quantifying HF emission is a reasonable effort, which results in a non-zero emission for those 101 compounds. Another reasonable estimation method would be to assume the detection limits for each compound, using an average molecular weight and fluorine molar ratio. By neglecting to include any reasonable assumptions for the HF contribution from destruction of these 101 PFAS compounds, the Permittee and the NHDES did not properly define the Permittee's potential to emit with respect to Env-A 1400.

The calculation of PTE requires the determination of the maximum emission rate of each pollutant- not an underestimation. The permit should be modified to correct this omission either by including these emissions in the PTE calculation, or by making an explicit restriction in the permit that prohibits the emission of the 101 compounds, or, alternatively, by imposing an equivalent restriction on production.

The permit process should have reflected the true PTE of PFAS - explicitly detailing any production or other restrictions that result in a calculation that is less than the true PTE. Once the restricted PTE was established, then the current BACT performance should have been applied to the restricted PTE of PFAS. Once BACT for PFAS was addressed, then the permit process should have followed the requirements of Env-A 1400 either by imposing further production restrictions or requiring add-on controls for HF to meet the AALs.

RTO Test Program

The draft permit originally required pre- and post-RTO emission testing of PFC (Table 6, Item 14) in order to determine compliance with the 90% minimum control efficiency requirement of Table 5, Item 5.f. This requirement was modified from the draft permit by removing the requirement to test the inlet. It is important to note that the destruction efficiencies may be different for different PFAS, depending on the functional groups embodied in the structure of the compound. These differences, if any, should be better understood to ensure that the


•

compliance efficiency is appropriate for all cases so that actual emissions of both PFAS and HF can be more accurately reported. The permittee should conduct a more comprehensive test program to support this understanding. Such a program may even support the achievement of higher PFAS destruction efficiencies at a lower compliance temperature.

Outlet Sample Run Times

To assist in obtaining better data at the outlet, and to provide more meaningful assessment of efficiencies, the permittee should increase the run times for those methods that concentrate the sample.

Other Items

• Ordinarily, when working under Env-A 1400, the approvable level of control need only comply with the AAL and not reflect BACT. Any level of control that meets the AALs is sufficient for compliance. In this particular project, however, the first paragraph of the review summary states that the project is "subject to the application of best available control technology (BACT) as defined in RSA 125-C:10-b, 1(a)." This "BACT Law'' specifically addresses the emission of PFC's. As such, the priority of compliance should be on BACT for PFC's. NHDES should ensure that the BACT requirement is satisfied with the appropriate PTE for PFC and/or PFAS, and then focus on compliance with the resulting AAL's. It appears that the permittee and NHDES have reduced the BACT stringency just so that the HF AALs can be met. In so doing, the permittee and NHDES compromised BACT for PFC's

• In the Findings of Fact and Director's Decision, there is a discussion of BACT (Issue No. 14, pages 9- 13) in which EPA guidance is cited. The citations (EPA/625/6-91/014, and EPA/453/R-93-017) date from the early to mid-1990's. While it is important to keep in mind certain historical references to the definition of BACT and process for establishing it, the case-by-case determination is an assessment of current technologies and current performance capabilities (i.e. what the control technologies are capable of achieving at the time the application was submitted). The Findings of Fact referred to a comment citing an EPA Technical Brief from 2019 indicating that an RTO can achieve 99.99% destruction of fluorinated/halogenated organic compounds. A cursory review finds that Daikin America, Inc. located in Morgan County Decatur, Alabama operates under permit number 712-0061, which states that emissions from the distillation columns (M1-3 through M1-8) are required to be routed to the T-Thermal incinerator in order to achieve a 99.99% ORE of CFC. This permit was renewed in 2018. This being the case, the claim that 90% ORE of the PFC's represents BACT is not based on current technology or current performance.

Please feel free to call or email if you have any questions,

Sincerely,

/j 1..

Paul Murphy Project Manager


Paula.M.Scott

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State of New Hampshire Department of Environmental Services Air Resources Division

Temporary Permit

Permit No: TP-0256 Date Issued: February 11, 2020

This certifies that:

Saint-Gobain Performance Plastics Corporation 701 Daniel Webster Highway Merrimack, NH 03054

has been granted a Temporary Permit for a:

Coated Fabrics and Films Manufacturing Operations and Two Emergency Engines

at the following facility and location:

Saint-Gobain Performance Plastics Corporation 701 Daniel Webster Highway Merrimack, NH 03054

Facility ID No: 3301100165 Application No: 18-0227, received March 26,2019

which includes devices that emit air pollutants into the ambient air as set forth in the permit application referenced above, which was filed with the New Hampshire Department of Environmental Services, Air Resources Division (department) in accordance with RSA 125-C of the New Hampshire Laws. Request for permit renewal must be received by the department at least 90 days prior to expiration of this permit and must be accompanied by the appropriate permit application forms.

This permit is valid upon issuance and expires on August 31, 2021.

Director Air Resources Division

TP-0256 Saint-Gobain Performance Plastics Corporation

. Abbreviations and Acronyms AAL Ambient Air Limit AGQS Ambient Groundwater Quality Standard ASTM American Society of Testing and Materials BACT Best Available Control Technology Btu British thermal units CAS Chemical Abstracts Service CFR Code ofF ederal Regulations CO Carbon Monoxide Env-A New Hampshire Code of Administrative Rules- Air Related Programs ft foot or feet ft3 cubic feet gal gallon HAP Hazardous Air Pollutants (as defined in Section 112 of the 1990 Clean Air Act

HF hp hr kW lb MM MSDS NAAQS NG NHDES NOx NSPS PFAS PFCs PM10 ppt ppm PTFE RACT RSA RTAP RTO scf SDS SOz SWQS TSP TPE tpy USEPA VOCs

Amendments) Hydrogen Fluoride (as F) horsepower hour kilowatt pound million Material Safety Data Sheet National Ambient Air Quality Standard Natural Gas New Hampshire Department of Environmental Services (department) Oxides of Nitrogen New Source Performance Standard Per- and Polyfluorinated Substances Perfluorinated Compounds Particulate Matter< I 0 microns parts per trillion parts per million Polytetrafluoroethylene Reasonably Available Control Technology Revised Statutes Annotated Regulated Toxic Air Pollutant Regenerative Thermal Oxidizer standard cubic foot Safety Data Sheet Sulfur Dioxide Surface Water Quality Standard Total Suspended Particulate Theoretical Potential Emissions tons per consecutive 12-month period United States Environmental Protection Agency Volatile Organic Compounds

Page 2 of34

TP-0256 Page 3 of34 Saint-Gobain Performance Plastics Corporation

I. Facility Description

Saint-Gobain Performance Plastics Corporation (SGPP), 701 Daniel Webster Highway in Merrimack, NH primarily manufactures PTFE coated fabrics and PTFE films. The fabrics are manufactured for a variety of chemical and weather resistant applications. This permit covers I 0 coating towers, 2 film lines, an R&D coater and 4 additional ancillary devices that will be tied into the proposed regenerative thermal oxidizer. Pursuant to RSA 125-C:IO-e, NHDES determined that devices operated at SGPP have emitted and continue to emit to the air PFCs and precursors. The emission of these PFCs have caused and continue to contribute to an exceedance of AGQS as a result of deposition of the PFCs and precursors from the air. Therefore, the devices located at SGPP are subject to the application of BACT as defined in RSA 125-C:IO-b, !(a).

The permit also covers an antenna cover fabrication area, a fire pump, and an emergency generator. The antenna cover fabrication area is part of the finishing operations which includes manual application of adhesives to the fabric for bonding to other pieces of fabric, ancillary items or to metal frames. The Facility is a synthetic minor source of air pollution for VOCs and HAPs. The Facility does not have the potential to emit the criteria pollutants S02, NOx, CO, and PM10 at levels greater than the major source thresholds for these pollutants. Therefore, the Facility is a true minor source for S02, NOx, CO, and PM10.

This Temporary Permit, TP-0256, includes new conditions associated with the project as well as existing conditions from the State Permit to Operate SP-0072. Upon issuance of this Temporary Permit, SP-0072 is terminated.

II. Emission Unit Identification

This permit covers the devices identified in Tables I and 2:

Emission Unit ID

EUOI

EU02

EU03

EU04

EU05

EU06

EU07

EU08

EUI2

EUI3

EUI5

EUI6

EU17

EU22

Device Name

MA Tower

MB Tower

MC Tower

MR Tower

MD Tower

QX Tower

20" SBC

20" Coater

MGTower

MPTower

MQTower

MS Tower

Antenna Cover Fabrication Area

R & D Coater

lnstaUation Date

1994

1998

1998

2002

1999

1989

1986

1986

2002

2002

2002

2002

!993

N/A

Process Parameters

Maximum Product Width # QfStages

(in)

60 I

175 I

92 I

92 I

92 2

60 5

20 6

20 I

175 I

175 I

44 I

92 I

N/A N/A

26 I

Maximum PrQduction (sq. ftlbr)

6,000

17,500

9,200

9,200

9,200

6,000

500

500

4,375

4,375

I, 100

2,300

N/A

2,600

Emission Unit lD

EU23

EU24

EU25

EU26

Emission UnitlD

EU20

EU21

TP-0256

Device Name Installation Date

Chemsil Coater NIA

MTM N/A

Step Press/ Laminator N/A

Heat Clean NIA

Emission Unit Description

Clarke fire pump- Model JU4H-UFAD58 John Deere engine- Model 4045 Serial #PE4045L273937

Kohler emergency generator set- Modei40REOZJC John Deere engine- Model 4024HF285B Serial #SGM32DG5J

Ill, Pollution Control Equipment Identification

Page 4 of 34

Process Parameters

Maximum Product Width

(in)

38

50

48

N/A

Installation Date

2015

2015

#of Stages Maximum Production (sq. fl.lbr)

3,800

5,000

4,800

N/A

'·.· .... · •... .. ·.

Maximum Design Capacity & Permitted Fuel Types'

1.20 MMBtulhr (II 0 bhp; 82 kW) ULSD -equivalent to 8. 7 gallhr

0.47 MMBtulhr (80 bhp; 60 kW) ULSD- equivalent to 3.4 gal/hr

Pursuant to RSA 125-C: I 0-e, Requirements for Air Emissions of Perfluorinated Compounds Impacting Soil and Water, within 12 months of permit issuance, the applicant shall complete construction and installation of controls listed in Table 3. Operation of the source may continue through the construction and installation time period. After the final construction and installation date, the air pollution control equipment listed in Table 3 shall be operated at all times that the associated devices are operating in order to meet permit conditions.

Pollution Control Equipment ID

PCEOI

Description

Regenerative Thermal Oxidizer as described in Table 5, Item 5.

Purpose

Control of PFCs and precursors Control ofVOCs

Emission. Units Controlled

EUOI-EU08, EU12, EUI3, EU15, EU16 and

EU22-EU26

The hourly fuel rates presented in Table 2 are set assuming a heating value of 137,000 Btu/gal for ultra-low sulfur diesel (ULSD). The fuel consumption and maximum power ratings for each engine come from their respective engine specification sheets which also state that both engines are US EPA Tier 3 certified.

TP-0256 Page 5 of 34 Saint-Gobain Performance Plastics Corporation

IV. Stack Criteria

The following devices at the Facility shall have exhaust stacks that meet the criteria in Table 4:

Stack Number

2

Emission Unit or Pollution Control

Equipment ID

PCEOI

EUI7

Stack Configuration

Vertical

Horizontal - 3 identical exhaust points

V. Operating and Emission Limitations

Minimum Height (feet above

ground surface)

60

2

Maximum Edt Diameter (feet)

6

6.25 ft2 (30"x30")

The owner or operator shall be subject to the operating and emission limitations identified in Table 5:

Item#

I.

2.

3.

Requirement

Facilitv-Wide Emission Limitations2

a.) Facility-wide emissions ofVOCs shall be limited to less than 50 tpy; and

b.) Facility-wide emissions of HAPs shall be limited to less than 10 tpy for any individual HAP and 25 tpy for all HAPs combined.

24-hour and Annual Ambient Air Limit

The emissions of any R TAP shall not cause an exceedance of its associated 24-hour or annual AAL as set forth in Env-A 1450.01, Table of All Regulated Toxic Air Pollutants.

Revisions oft he List o(RTAPs

In accordance with RSA 125-1:5 IV, if the department revises the list of RTAPs or their respective AALs or classifications under RSA 125-1:4, II and Ill, and as a result of such revision the owner or operator is required to obtain or modify the penn it under the provisions of RSA 125-1 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.

Applicable Emission Unit

Facility Wide

Facility Wide

Facility Wide

Regulatory Basis

Env-A 604.02(aXI)

Env-A 1400 (State-only

Enforceable Limit)

Env-A 1404.02 (State-only

Enforceable Limit)

The Facility has the potential to emit VOCs at levels greater than the major source threshold for these pollutants of 50 tpy and HAPs at levels greater than the major source threshold of 10 tpy for any individual HAP and 25 tpy for all HAPs combined. The annual emission limits in Table 5, Item I are less than these thresholds and establish the Facility as a synthetic minor source of air pollution for VOCs and HAPs. The Facility does not have the potential to emit the criteria pollutants NOx, S02, CO and PMw at levels greater than the major source thresholds for these pollutants. Therefore, the Facility is a true minor source for NOx, S02, CO, and PM10.

Item#

4.

TP-0256

Requirement

NSPS General Provisions

a.) At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Detennination of whether acceptable operating and maintenance procedures are being used will be based on available information which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source;

b.) For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

AppiiCllble Emission Unit

EUOI-EU08, EUI2, EUI3,

EU15 & EU16

Page 6 of34

Regulatory Basis

40 CFR 60.1 l(d) &

40 CFR 60. I I (g)


. ' ···•·•,•••,·•·•••·•i·······,·············,··•·•••••··•·••i~···•·'•··••••··•'f~6~~s•2op~~~iitig•a~ali:~is~io~~-njit;o~~$\; .. ,•• : ,? ..• ,,,... i/i'·.· <

..... .. · .. · • • . •• • • ••• • ••.. '·> • .... . •••• •. • •• • •••...• ·'· .... •·• ... Item# Requirement Applicable Emission Regulatory Basis

Unit

5. Al2.f2lication o[.RSA 12 5-C: I 0-e Re(luirem(nls (pr Air Emissions o( PCEOI RSA 125-C:IO-e Perfluorinated Comf2ounds Imeacting Soil and Water and Installation o[_Regenerative Thermal Oxidizer

a.) Within 12 months of permit issuance, the owner or operator of the Facility shall complete construction and installation of a three-chamber RTO (PCEOI) or equivalent to minimize untreated process gases during RTO operation for the control ofPFCs and precursors' from EUOJ-EU08, EUI2, EU13, EUI5, EU16 and EU22-EU26.

b.) Once the RTO is operational, PCEO I shall operate at all times the coating towers or auxiliary equipment are operating to meet the requirements of Table 5, Item 5. and in accordance with the start-up and shutdown conditions outlined in the Air Pollution Control Equipment Monitoring Plan submitted with the application and outlined in Table 6, Item 13.

c.) The active combustion chamber of the RTO shall be maintained at a minimum temperature of 1832°F (I 000°C), based on an hourly block average as required in Table 6, Item II;

d.) The combustion chambers of the RTO shall be designed with a minimum gas residence time of l second each.

e.) The inlet flow rate to the RTO shall not exceed 70,000 scfm.

f.) For the purpose of ensuring that the application of BACT will not cause or contribute to an exceedance of an AGQS or SWQS, the maximum annual controlled PFC emission limits shall be less than or equal to 0.45 lbs/yr PFOA and 0.57 lbs/yr PFOS.

g.) The R TO operation and maintenance shall be in accordance with the Air Pollution Control Equipment Monitoring Plan submitted with Application #18-0227, as updated in accordance with Table 8, Items 10 and II.

6. Work Practice Standards (pr Cleaning Materials Used in Coating o[ EUOI- EU08, Env-A 1207.02 Paeer, Fabric, Film and Foil Substrates EUI2, EUI3

A paper, fabric, film, or foil coating operation that uses VOC- &

containing cleaning material shall control VOC emissions from the EUI5- EUI7

cleaning materials using the following work practices:

a.) Storing VOC-containing cleaning materials in closed containers;

b.) Keeping mixing and storage containers closed at all times except when depositing or removing VOC-containing materials;

c.) Minimizing spills ofVOC-containing cleaning materials;

d.) Conveying VOC-containing cleaning materials from one location to another in closed containers or pipes; and

e.) Minimizing VOC emissions from the cleaning of storage, mixing, and conveying equipment.

RSA 125-C: I 0-e l(d) defines PFCs as a list of compounds identified in paragraph 1.1 of Environmental Protection Agency Document #: EPN600/R-08/092 Method 537. "Determination of Selected Perfluorinated Alkyl Acids in Drinking Water by Solid Phase Extraction and Liquid Chromatographyffandem Mass Spectrometry (LC/MS/MS)", Version !.I (September 2009). RSA 125-C:IO-e l(e) defines precursor as any substance that has been shown by sound science to be transformed into a PFC under ambient conditions reasonably expected to occur in New Hampshire.

TP-0256 Page 8 of 34 ant- 0 am er ormance S I G b . P ~ PI ashes c oroorahon

I , ................... ··•••·•. ······•••I \.•·······•.••··•·· ..•...•••••. ; ....... ·.· .. ·. rt~bles +·O~~fttitig ~ij~i};~i~;i~~ti~lt~ti~~~·:~;.·•> ·· . ..... .. .·.... . ... . ...•.•.... ·· ... ······ ........ ,................. ... . )";, ................ ., · ... :J• /;?i/;······· '{;; .. .. ... .· Item# Requirement

Applicable Emission I Regulatory Basis

Unit

7. Emission Rate Limits (pr CQating o[_Pa{2er, Fabric, Film and Foil EUOI- EU08, Env-A 1207.03(c) Substrates EU12, EUI3

A paper, fabric, film, or foil coating operation that has TPE of &

VOCs equal to or greater than 25 tons per consecutive 12-month EUI5- EUI7

period, as applied, shall be limited at all times to either the control efficiency or emission rates as applied, as follows:

Paper, Film and Foil Surface Coating (not including pressure sensitive tape and .label coating)

a. Overall Control Efficiency (OC] 90%

b. kg VOC/kg solids (ERJ 0.40

(lb VOC/Ib solids) (0.40)

kg VOC/kg coating (ER( 0.08 c.

(lb VOC/Ib coating) (0.08)

8. Determination o[.Emissions EUOI-EU08, Env-A 1205

a.) For a coating source that uses add-on control equipment to EU12, EU13

achieve compliance, the overall control efficiency (OC) shall be &

determined on a daily basis using the procedures specified in EUI5- EUI7

Table 6, Items 9 and I 0.

b.) For a coating source that uses a bubble to achieve compliance, the emission rate (ER) shall be determined on a daily basis using the procedures specified in Table 6, Items 5 through 8.

9. Visible Emission Standards Prior to installation of Env-A 2103.02

The average opacity shall not exceed 20 percent for any continuous PCEOI:

6-minute period.' EUO l-EU08, EU 12, EUIJ, EU15- EU17 After installation of

PCEOJ: EU17 & PCEOl

·--

EU20 & EU21 Env-A 2002.02

10. Particulate Emission Standards (pr Fuel Burning Devices Installed EU20, EU21 & Env-A 2003.03 on or Afler Janua[Jl_ I, 1985 PCEOI

The particulate matter emissions from fuel burning devices installed on or after January 1, 1985 shall not exceed 0.30 lb/MMBtu.

II. Maximum Sul(_ur Content Allowable in Liguid Fuels EU20&EU21 40 CFR 60.4207

The sulfur content of diesel fuel burned in the emergency engines (Subpart Ill!)

(EU20 & EU21) shall not exceed 15 ppm (0.0015 percent sulfur by weight).

Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, or department approved method, upon request by the department.

TP-0256 Page 9 of34 Saint~Gobain Performance Plastics Corporation

~; ;>·>·>··\' •.. > \3 >··>·.····· ...... . ... •···· .·· ·· .tta~~~~.:Q(l'@~twgii~~F.~.lssio#•'Li~lt!ltif>~~.>·

- ~- ------ '"" ---" - '"---- ,._,-- --- -- _-,--; -- ---/-"", ••. ::i i•·••• ;ar;;>• ):···••···•.·••·· ;· \: .••••... Item# Requirement

Applicable Emission Regulatory Basis Unit

12. Emer"-enQ!_ Engine Oeeratin~ Reguirements EU20 & EU21 40 CFR 60.4206

The owner or operator of the emergency engine shall: 40 CFR 60.4211 (a)

a.) Purchase a certified emergency engine in accordance with the &

requirements listed in 40 CFR Part 60, Subpart III!; 40 CFR 60.42ll(c)

b.) Install, configure, operate and maintain the engine according to (Subpart Ill!)

the manufacturer's emission-related written instructions or change only the emission-related settings in a way that is permitted by the manufacturer; and

c.) Operate and maintain the engine to meet the emission standards over the entire life of the engine.

13. Emer'5.enQ!_ Generator 012.erating_ Hours Limitation EU20 & EU21 Env-A 606.02(c)(l)

Each emergency engine' shall be limited to 500 hours of total operation per any consecutive 12-month period and only under the operating scenarios listed in Table 5, Item 14.

14. Emerg_en0!. Engines EU20 & EU21 Env-A I 01.671,

Each emergency engine shall only operate: Env-A 1302.17

a.) As a mechanical or electrical power source during an &

40 CFR 60.4211 (t) emergency which is defined in Env-A 1302.17 as an

(Subpart !Ill) unforeseeable condition that is beyond the control of the owner or operator that;

I. Results in an interruption of electrical power from the electricity supplier to the premises;

2. Requires an interruption of electrical power from the electricity supplier to the premises in order to enable the owner or operator to repair damage from fire, flood, or any other catastrophic event, natural or man-made;

3. Requires operation of an emergency engine to minimize damage from fire, flood, or any other catastrophic event, natural or man-made; or

b.) During scheduled maintenance checks and readiness testing, as recommended by federal, state or local government, the manufacturer, the vendor or the insurance company associated with the engine, for a maximum of I 00 hours per calendar year. 6

If the emergency engines are not operated in accordance with the requirements in 40 CFR 60.4211 (f) or Table 5, Item 14, the engines will not be considered emergency engines and must meet all requirements for non-emergency engines including air pollution controls. The owner or operator shall notifY the department of any proposed change to the mode of operation of the emergency generators, which would result in a change in applicability pursuant to 40 CFR 60, Subpart 1111 in accordance with Condition X.

The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency engine beyond 100 hours per calendar year.


VI. Monitoring and Testing Requirements

The owner or operator is subject to the monitoring and testing requirements as contained in Table 6:

...... · ........... · ..• •·••···••···.·.·.·•···•····•· .·

••·•'fl>1~·6·:~1\£ Ii'fi 'allll'f ·t• nt···i·•···•t··.g .• · .... J• ..•.•. Jl~ .. !) .• !lg ....... l)sJug .. ·•·· .IJJI reJ»Il!l .. ~ ••.. A•• ,,,,

. :. . Item

Par!lmeter Method of Compliance Frequency Applicable Regulatory # Unit Basis

I. To Be When conditions warrant, the department may Upon request Facility Wide RSA 125-C:6, XI Determined require the owner or operator to conduct stack by the

testing in accordance with US EPA or other department department approved methods.

2. Sulfur Conduct testing in accordance with For each Facility Wide Env-A 806.02 Content of appropriate ASTM test methods or retain delivery of &

Liquid Fuels documentation in accordance with Table 7, fuel oil/diesel Env-A 806.05 Item 4 in order to demonstrate compliance to the facility with the sulfur content limitation provisions specified in this permit for liquid fuels.

3. Opacity Until PCEO I is installed and operational, the Daily when EUOI-EU08, Env-A 604.02 owner or operator shall perform daily the associated EUI2, EUI3, & observations ofEUOI-EU08, EUI2, EUI3, processes are EUI5- EUI7 Env-A 810.02 EU 15-EU 17 in accordance with the operating Corrective Action Plan for Achieving Compliance with Opacity Limits submitted August 18,2016 and updated November 8, 2016 to evaluate the presence of visible emissions, and take appropriate action to mitigate opacity in excess of the standard listed in Table 5, Item 9.

4. VOC Content VOC Content o[a Coatinr;. Maintain on a EUOI- EU08, Env-A 804.03 of Coatings a.) VOC coating information based upon continuous EUI2, EU13 &

supplier or stationary source formulation basis & Env-A 804.04

data shall be prima facie evidence of the EUI5- EU17

actual VOC content of the coating. Record all information in accordance with Table 7, Item 6.

b.) One of the following methods, as applicable, may be used to determine VOC content for coatings:

I. Use Method 24 as described in 40 CFR 60, Appendix A, using the 60-minute bake time procedure for test ASTM D 2360-01; or

2. Use Method 24A as described in 40 CFR 60, Appendix A.

5. VOC Content Calculation o[VOC Content o[a Coating Maintain up- EUOl- EU08, Env-A 804.05 of Coatings Formulation to-date data EU12, EU13

For a coating that contains more than one &

VOC component, calculate the VOC content EU15- EU17

of the coating using the following formula, provided no chemical reaction occurs during the formulation process:

TP-0256 Page II of34

r:JJJJ~±iJJ~~~~~JJ~~Sa~in~c~~o.n~oh~,.~;·~P~e~r~fo~r~m~a~n~c~e~~~·~r,~~~~~~~ ~·· .. ···········•··•••········ •... 2i'··· .•..•.. ,\ ··,···· :. ;.:··;:;:, ...• ;•, ·:::... :s ~.,;;, ,, .•.•.•• ; :.·······~·.'! % •.• ~~c .• : .• . •. ·· Item Parameter Method of Compliance Frequency Applicable Regulatory

# Unit Basis

5. VOC Content "'" (v c) (cont.) of Coatings P= .L.Ji-1 I X I

6.

v; Where:

P = The VOC content of the coating fonnulation, as applied, used on a coating line or operation in units of Jb VOC/gal coating, minus water and exempt VOC compounds;

n = The number of different coatings or diluents, as applied, used in the coating formulation;

i = The subscript denoting an individual coating or diluent;

v, =The volume of the coating or diluent, i, as applied, used in the coating formulation in units of gallons, minus water and exempt VOC compounds;

c, =The VOC content of the coating or diluent, i, as applied, used in the coating formulation in units of lb VOC/gal coating Jess water and exempt VOC compounds, as determined from the Method 24 or 24A analysis and the calculation procedures in Section 2.2 of EPA-30411-86-016, A Guideline for Surface Coating Calculations, July, 1986;and

V, = The total volume of the coating formulation, as applied, in units of gallons minus water and exempt VOC compounds.

VOC Content Calculation a( Daily-weighted Average for a of Coatings Coating Line Using Multiple Coatings

Calculate the daily-weighted average VOC content of each coating line or operation using the following formula:

"'" (v c) p =L..-1~1 ,X' • I'

' Where: P, = The daily-weighted average VOC

content of the coatings, as applied, used on a coating line or operation in units of lb VOC/gal coating, minus water and exempt VOC compounds;

n = The number of different coatings or diluents, as applied, used each day on the coating line or operation;


Maintain upto-date data


EUOI- EU08, EUI2, EU13

& EU15- EUI7

EUOJ-EU08, EUI2,EU!3

& EUI5-EUI7

Env-A 804.05

Env-A 804.06

r .. ··•·············•·• ··••·•··· : .· .. Item

#

6. (cont.)

7.

Parameter

VOC Content of Coatings

Dailyweighted Average Coating

Density (Pw)

TP-0256 Saint-Gobain Performance Plastics CorporatiOn

Method of Compliance . . .· .

v, ~ The volume of the coating or diluent, i, as applied, used each day on a coating line or operation in units of gallons, minus water and exempt VOC compounds;

Ct ~ The VOC content of the coating or diluent, i, as applied, used each day on a coating line or operation in units of lb VOC/gal coating less water and exempt VOC compounds, as determined from the Method 24 or 24A analysis and the calculation procedures in Section 2.2 ofEPA-304/1-86-016, A Guideline for Surface Coating Calculations, July, 1986. For multiple component coatings, Ct = P as calculated in Table 6, Item 5; and

V, ~ The total volume of all coatings, as applied, used each day on a coating line or operation in units of gallons minus water and exempt VOC compounds.

Calculation ofDaily-weightedAverage Coating Densitv Cowl for a Coating Line Using Multiple Coatings

Calculate the daily-weighted average coating density of each coating line or operation using the following formula:

Li(V, X Pt) Pw = v,

Where:

p" ~ The daily-weighted average density of the coatings, as applied, used on a coating line or operation in units of lb/gal coating;

n ~ The number of different coatings or diluents, as applied, used each day on the coating line or operation;


v, ~ The volume of the coating or diluent, i, as applied, used each day on a coating line or operation in units of gallons;

p1 ~ The density of the coating or diluent, i, as applied, used each day on a coating line or operation in units oflb/gal coating; and

Vt ~ The total volume of all coatings, as applied, used each day on a coating line or operation in units of gallons minus water and exempt VOC compounds.

Frequency



Applicable Unit

EUOI- EU08, EUI2, EU13

& EUI5- EUI7

EUOI-EU08, EUI2, EUI3

& EUI5- EU17

Page 12 of34

Regulatory Basis

Env-A 804.06

Env-A 804.06

Item #

8.

9.

10.

Parameter

Dailyweighted average

emission rate (ER)

Coating Towers VOC

Controlled Emission

Rate

Overall Control

Efficiency for VOCRACT

TP-0256 Samt-Gobam Performance Plashes Corooration

Method of Compliance

Calculation ofDaily-weightedAverage Emission Rate{£~<) for a Coating Line Using Multiple Coatings without Add-on Control

The owner or operator may choose to demonstrate compliance with the emission limitations specified in Table 5, Item 7.c. by calculating the daily weighted average ER as follows:

Where:

ER ~ The daily-weighted average VOC emission rate, as applied, used on a coating line or operation in units of lb VOC/lb coating;

P,. ~ The daily-weighted average VOC content of the coatings, as applied, used on a coating line or operation in units of lb VOC/gal coating, minus water and exempt VOC compounds as calculated in Table 6, Item 6; and

p,. ~ The daily-weighted average density of the coatings, as applied, used on a coating line or operation in units of lb/gal coating as calculated in Table 6, Item 7.

Calculation of Controlled VOC Emission Rate for Coating Towers (E,cl The owner or operator shall calculate the controlled VOC emission rate from the coating towers using the following calculation:

E,, = E,u(l- CE x RE)

Where:

E,, ~The controlled VOC emission rate tram the towers;

E,. ~The uncontrolled VOC emission rate fi"om the towers that are exhausted through the RTO;

CE ~ Capture efficiency as determined during testing pursuant to Table 6, Item 16.c.; and

RE ~ Removal efficiency as determined during testing pursuant to Table 6, Item 14.d.

Calculation of Overall Control E@ciency (OC)

The owner or operator may choose to demonstrate compliance with the overall control efficiency specified in Table 5, Item 7.a. by using the following calculation:

Frequency




AppliCllble Unit

EUOl- EU08, EU12, EU13

& EU15- EU17

EUOl- EU08, EU12, EU13

& EU15- EU16

EUOl- EU08, EU12,EU13

& EU15- EU17

Page 13 of 34

····.··.·.··• .. ·· .. ·.:·>.( ·.:yc ••••• .•....•• ;.:<·· : •.•. /; ••.. Regulatory

Basis

Env-A 804.06

Env-A 804

Env-A 804 &

Env-A 1203.64

Item #

10. (cont.)

I I.

12.

Parameter

Overall Control

Efficiency for VOC RACT

Thermal Oxidizer

Operating Parameters

Annual Thermal Oxidizer

Inspection

TP-0256 Saint-Gobaln Performance Plastics Corporation

Metboo of Compliance

(E,u + Ea) - (Etc + Ea) oc = (Etu + Ea)

X 100

Where:

OC = The overall control efficiency in %;

E,u = The uncontrolled VOC emission rate rrom the towers that are exhausted through the RTO;

E, =The VOC emission rate from the antenna cover fabrication area (EU 17); and

E" =The controlled VOC emission rate rrom the towers calculated pursuant to Table 6, Item 9.

a.) Monitor the thermal oxidizer combustion chamber temperature at least once every 15 minutes and record the hourly average temperature.

Frequency


Monitor every 15

minutes when the associated

process is

1--------------1-· operating

b.) If the average hourly temperature reading is less than the minimum specified in Table 5, Item 5.c, then the owner or operator shall investigate and take corrective action immediately upon discovery of the permit deviation to restore the air pollution control equipment (PCEO I) to within allowable permit conditions.

c.) If the average hourly temperature cannot be brought back up within 48 hours of the excursion7

, then maintain records of the excursion pursuant to Table 7, Item 15.

d.) Monitor the gas flow to the thermal oxidizer at least once every 15 minutes and record the hourly average tlowrate.

a.) Conduct an annual (or more rrequently if conditions indicate an inspection is warranted) visual external integrity inspection of the thermal oxidizer and the ductwork from each source leading to the

As noted

Monitor every 15

minutes when the associated

process is operating

As noted

Applicable Unit

EU01-EU08, EU12, EU13

& EUI5- EU17

PCEO!

PCEOJ

Page 14 of34

Regulatory Basis

Env-A 804 &

Env-A 1203.64

RSA 125-C:6, XI Env-A 906

& Env-A 9!1.03(b)

RSA 125-C:6, XI

An excursion occurs when a monitored parameter specified by the permit to document the performance of the air pollution control equipment is above the maximum or below the minimum set point or is outside of the required operating range for that parameter.

13.

14.

TP-0256 .r.

. . / ··.·• .··•···•···· ······ ··•·······•· \.. '--~~·" ); -~ ~·~. ':~ ~;--:_ ,,

Air Pollution Control

Equipment Monitoring

Plan

Initial RTO Stack Testing Requirements


RTO. The inspection shall include an evaluation of whether all emissions are being vented through the dedicated stack exit.

Monitor parameters to ensure total enclosure of applicable emission units in a manner and a frequency as outlined in the Air Pollution Control Equipment Monitoring Plan required in Table 8, Item 10;

c.) Confirm that collection headers that are routed to the RTO are operating under negative pressure on an annual basis and in accordance with the Air Pollution Control Equipment Monitoring Plan in Table 8, Item I 0.;

d.) The inspections and monitoring shall be conducted by plant personnel familiar with the operation of the oxidizer and associated equipment.

Start-up and Shutdown Requirements

a.) The owner or operator shall not initiate process operations with pertluorinated compounds prior to the RTO (PCEOI) reaching the established operational temperature required in Table 5, Item 5c.

b.) During any shutdown condition, process operations will proceed to a safe stopping point to minimize potential emissions.

Initial Regenerative Thermal Oxidizer Stack Testing Requirements

The owner or operator shall conduct initial emissions testing in accordance with Table 6, Items 15 and 16 to evaluate the following parameters:

a.) Post-RTO emissions ofPFAS compounds in order to determine compliance with the maximum allowable annual controlled PFC emission limitations listed in Table 5, Item 5.g.;

b.) Post-RTO emissions of hydrogen fluoride (CAS #7664-39-3), perfluoroisobutene (CAS #382-21-8), tetrafluoroethylene (CAS# 116-14-3), hexafluoropropylene (CAS# 116-15-4), carbcnyl fluoride (CAS #353-50-4), and ammonium perfluorooctanoate (CAS #3825-26-1) to determine compliance with Env-A 1400 as outlined in Table 5, Item 2; Table 7, Item 10 and Table 8, Item 5.;

c.) Pre- and post-RTO emissions ofVOC to

Frequency

As noted

Continuous

Within 60 days of

startup of the control device

Applicable Unit

PCEOI

PCEOI

PCEOI

Page 15 of34

Regulatory Basis

RSA 125-C:6, XI

RSA 125-C:IO-e Env-A 810.01

& Env-A 910.0 I

RSA 125-C:IO-e Env-A 802 Env-A 804

& Env-A 704.02

·· ..•....••........ • ·.

Item #

15.

16.

Parameter

Performance Test

Notifications

Perfonnance Test

TP-0256 Salnt-Gobain Performance Plast cs Corooratmn

determine removal efficiency (RE);

d.) Capture efficiency for VOC and PFC emissions from the controlled devices into the main header to the RTO; and

e.) The owner or operator shall be subject to fees for any testing and monitoring which department personnel undertake or audit in accordance with this permit.

Compliance testing shall be planned and carried out in accordance with the following: a.) The facility must notify the department at

least 30 days prior to conducting a performance test;

b.) A pre-test protocol meeting the requirements ofEnv-A 802.04 shall be submitted to the department at least 30 days prior to the commencement of testing;

c.) The owner or operator and any contractor retained by the owner or operator to conduct the test shall meet with a department representative at least I 5 days prior to the test date to finalize the details of the testing as outlined in Env-A 802.05;

d.) A pre-test meeting may be held less than I 5 days prior to the test so long as the department staff are available and implementation of any testing or operation changes resulting from the meeting can be carried out prior to scheduled test date and scheduled test integrity is not jeopardized;

e.) Notify the department as soon as possible, but no later than 7 days, and obtain approval from the department prior to any proposed changes in the testing schedule for a compliance stack test;

f.) The owner or operator shall obtain prior approval from the department, which shall be based on staff availability, of any new date for a compliance stack test;

g.) A test report shall be submitted to the department within 60 days after the completion of testing.

a.) Each performance test shall conform to the following:

I. The general requirements of 40 CFR §60.8; and

Frequency

30 days prior to

performance testing or as

specified

For each performance

test

Applicable Unit

PCEOI

PCEOI

Page 16of34

RegulatQry B3$is

RSA I 25-C: I 0-e Env-A 802

Env-A 804.12 &

Env-A 804. I 3

RSA I 25-C: I 0-e Env-A 802

& Env-A 804.14

Item #

16. (cont.)

Parameter

Performance Test



2. The test methods contained in 40 CFR 60, Appendix A, 40 CFR 51, Appendix M, or any other stack test method promulgated by the USEPA, or any alternative, conditional or other test method approved by the USEPA, or any alternative method approved by the department in accordance with Env-A 809.

b.) The department shall approve deviations from the agreed-upon test method or pretest protocol only if the following criteria are met:

I. The owner or operator informs department personnel assigned to the stack test of the following:

i. The deviation from the testing method or planned operational mode of the source;

ii. The reason(s) for the deviation; and

iii. The implications of such a deviation;

2. The Owner or Operator provides technical justification showing that allowance of such deviation will not affect the accuracy of the compliance stack emissions test;

c.) The following test methods, or department approved alternatives, shall be used, as applicable:

I. For PF AS testing required in Condition VI. Table 6, Item 14, the testing shall consist of six separate sampling runs of sufficient duration to ensure reporting levels sufficient to demonstrate compliance with the limitations in Table 5, Item 5.g. Samples of three of the sampling runs, consistent with the stack testing conducted in 2018, will be provided to NHDES so that NHDES can have the samples analyzed by a separate laboratory. For PFAS testing required in Condition VI Table 6, Item 17, the testing shall consist of three separate sampling runs of sufficient duration to ensure reporting levels sufficient to demonstrate compliance with the limitations in Table 5, Item 5.g.

Frequency

For each performance

test

Applicable Unit

PCEOI

Regulatory Basis

RSA 125-C: I 0-e Env-A 802

& Env-A 804.14

TP-0256 Page 18 of34

Item Parameter Method of Compliance Frequency ·Applicable Regulatory

# Unit Basis

16. Performance 2. For HF, the testing shall consist of For each PCEOI RSA 125-C: I 0-e

(cont.) Test three separate one-hour sampling performance Env-A 802 runs post-RTO. test &

3. For VOCs, the testing shall consist of Env-A 804.14

three separate one-hour sampling runs with concurrent sampling pre-and post-RTO.

4. Collect combustion zone temperature readings as agreed upon in the pre-test protocol required in Table 6, Item 15;

5. Collect process information as agreed upon in the pre-test protocol required in Table 6, Item 15;

6. USEPA Methods 1-4 for exit flow rate, percentage of carbon dioxide, oxygen and moisture;

7. Modified Method 5 as per MOOIO in SW-846 for PFAS emissions or an EPA-approved method';

8. USEPA Method 25 or 25A for total gaseous organic emissions;

9. USEPA Method 26A for hydrogen fluoride emissions;

10. USEPA Method 204 to determine capture efficiency of the towers into the main header to the R TO; and

II. USEPA Method 18 for methane.

d.) Dip pan samples of formulated dispersions shall be taken during each stack test run and analyzed.

17. Periodic RTO Periodic Regenerative Thermal Oxidizer Annually no PCEOI RSA 125-C:IO-e

Stack Testing Stack Testing Reguirements more than 13 Env-A 802

Requirements The owner or operator shall conduct periodic months after &

emissions testing in accordance with Table 6, previous test Env-A 804.13

Items 15 and 16 to evaluate the following or

parameters: to establish

a.) Post-RTO emissions ofPFAS compounds new

operating in order to determine compliance with the limits maximum allowable annual controlled PFC emission limitations listed in Table 5, Item 5.g.; and

b.) Capture efficiency for PFC emissions from the controlled devices into the main header to the RTO.

If no EPA-approved method for PFAS testing exists at the time of the perfonnance test required in Condition VI. Table 6, [tern 14, PFAS samples shall be analyzed for at least the list ofPFAS identified by USEPA Method 537. I fan EPA-approved method for PFAS testing (OTM~45) does exist at the time of the perfonnance test required in Condition VI. Table 6, Item 14, PFAS samples shall be analyzed for the complete list ofanal)1es identified in the EPA-approved method.

TP-0256 Page 19 of34 amt- 0 am er ormance S"Gb"P~ PI ast1cs c r orpora 100

.. ' .·c ·.·

·,_ ) •••·-/ )·,··•••-.,••'-·.--:r~~~~6 .1\i~~~j~j'fil~~li~'~~~tiriilR¢9'4ir~meuts' · ', : /< >'....... , ... ; . . .... · ..... _ ...

Item P~trameter Metbod of Compli~tnce Frequency AppliCilble Regul~ttory

# Unit Basis

17. Periodic RTO c.) Pre- and post-RTO emissions ofVOC to Every 5 years PCEOI RSA 125-C: I 0-e (cont.) Stack Testing determine compliance with the VOC within the Env-A 802

Requirements control efficiency requirement in Table 5, same & Item 7a.; and calendar Env-A 804.13

d.) Capture efficiency for VOC emissions quarter of the

from the controlled devices into the main date of the

header to the RTO. anniversary of the most recent stack

test --

e.) Pursuant to RSA 125-C: I 0-e, should the As specified EUOI-EU08, RSA 125-C: I 0-e owner or operator wish to demonstrate to EUI2, EUI3, the department that the devices subject to EU15, EU16 RSA 125-C: 10-e no longer contribute to and EU22-an exceedance of an AGQS or SWQS, the EU26 owner or operator shall submit a written demonstration and conduct emission testing to establish an appropriate minimum combustion chamber temperature for the RTO (PCEOI) as required in Condition V. Table 5, Item 5(c).

18. Hours of Each emergency engine shall be equipped Continuous EU20 40 CFR 60.4209 Operation with a non-resettable hour meter. & (Subpart Jill)

EU21

VII. Recordkeeping Requirements

The owner or operator shall be subject to the recordkeeping requirements identified in Table 7:

i•••••··-····.:····-··········-•• ·•• -- /•-'~'· : i'I'ai>I~'7c~l{'~f•··-··;it~~~ii$.!.·:.••<···•····· ;•;Dt:'.(;n {·i•.•··· .. . . . .·. -.. :. . .••.•..... _ •. ,. Item Requirement_ Duratioo! Applicable Regulatory

# ~- Unit BllSis . .. I. Record Retention and Availability Retain for a Facility Wide Env-A 902.0 I

Keep the required records on file. These records shall be minimum of

available for review by the department upon request. 5 years

2. General RecordkeeeJng Requirements {gr Process Oe.erations Monthly EUOI-EU08, Env-A 903.02

Maintain the following records for process operations: EUI2, EU13,

EU15 -EUI7, a.) Total quantity of all materials used or produced in each EU22- EU26

process that are necessary to calculate emissions;

b.) Hours of operation of each process;

c.) Safety Data Sheets (SDSs) or other documentation As specified

containing the concentration of total VOCs, each HAP and RTAP in each raw material used; and

d.) Results of dip pan samples of formulated dispersions taken in accordance with Table 6, Item 16(d) containing the concentration of PF AS.

TP-0256 Saint-Gobain Performance Plastics Cor oratiOn

Item #

3.

Requirement

General Recordkeeping Requirements for Combust;on Devices

Maintain the following records of fuel characteristics and utilization for the fuel used in the combustion devices:

a.) Type (e.g. diesel fuel, natural gas) and amount of fuel burned in each device; or

b.) Type and amount of fuel burned in multiple devices and hours of operation of each device to be used to apportion fuel use between the multiple devices.

c.) Hours of operation for the emergency engines.

4. Liquid Fuel Oil Recordkeeping Requirements

In lieu of sulfur testing pursuant to Table 6, Item 2, the owner or operator may maintain fuel delivery tickets that contain the following information:

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.

5. VOC Emission Statements Recordkeeping Requirements

6.

If the actual annual VOC emissions from all permitted devices located at the Facility are greater than or equal to I 0 tpy, then record the following information: a.) Identification of each VOC-emitting process or device; b.) The operating schedule during the high ozone season (June I

through August 31) for each VOC-emitting process or device identified in Table 7, Item 5.a. above, including: I. Typical hours of operation per day; and 2. Typical days of operation per calendar month.

c.) The following VOC emission data from each VOC-emitting processes or devices identified in Table 7, Item 5.a. above, including: I. Actual monthly VOC emissions, in tons; 2. Typical high ozone season day VOC emissions, in

pounds per day; and 3. The emission factors and the origin of the emission

factors used to calculate the VOC emissions.

VOC Recordkeeping for Surface Coating and Printing Operations

Record the following information for each coating operation subject to Env-A 1200:

a.) Coating fonnulation and analytical data, as follows:

I. Supplier;

2. Name and color;

3. Type;

4. Identification number;

5. Density described as lb/gal;

6. Total volatile content described as weight percent;

7. Water content described as weight percent;

8. Exempt solvent content described as weight percent;

9. VOC content described as volume percent;

Duration! Frequency

Monthly

Whenever there is a change in

fuel supplier but at least annually

Maintain Data for Annual Report

Maintain Current Data

Applicable Unit

EUOI- EU06, EUI2, EU13, EUI5, EU16, EU20- EU22, EU24& EU26

EU20 & EU21

EU01-EU08, EU12, EUI3, EU15- EU17

& EU20- EU22

EUOI- EU08, EU12, EU13

& EUI5-EU17

Page 20 of34

Regulatory Basis

Env-A 903.03

Env-A 806.05

Env-A 904

Env-A 904.03

Item #

6. (cont.)

7.

8.

TP-0256

Requirement

I 0. Solids content described as volume percent;

ll. Diluent name and identification number;

12. Diluent solvent density described in lb/gal;

13. Diluent VOC content described as weight percent;

14. Diluent exempt solvent content described as weight percent;

15. Volume of diluent VOC described as gal; and

16. Diluent/solvent ratio described as gal diluent solvent per gal coating.

b.) The number of gallons of each coating, including solvents and diluents, utilized during a typical high ozone season day; and

c.) Process information for a typical high ozone season day, including:

I. Method of application;

2. Number of coats;

3. Drying method; and

4. Substrate type and form.

Recordkeeping fOr VOC RACT Compliance

Maintain the following records in order to show compliance with the VOC RACT limits stated in Table 5, Item 7: a.) If all compliant coatings are used on a given day, then records

ofVOC coating content shall be maintained pursuant to Table 6, Items 4 and 5, and Table 7, Item 6. These records shall be used to show compliance with the coating limits in Table 5, Item 7 .b. or c.

b.) If a bubble is used to average coating VOC contents, then maintain records of the calculations conducted pursuant to Table 6, Items 6, 7, and 8. The result of the bubble calculation shall be less than the limit contained in Table 5, Item 7.c.

c.) If the owner or operator is showing compliance with the overall control efficiency limit contained in Table 5, Item 7.a. then maintain records of the calculations conducted pursuant to Table 6, Items 9 and I 0.

Recordkeeping (Or Sources or Devices with Add-on VOC Air Pollution Control Equipment

Record the following information for the RTO:

a.) The air pollution control device identification number, type, model number, and manufacturer;

b.) Installation date;

c.) Process or devices controlled;

d.) The type and location of the capture system, capture efficiency percentage, and method of determining capture efficiency;

e.) Records of startup and shutdown of the PCEOI in conjunction with appropriate operational information of the

Duration/ P. ...


Daily


Applicable Unit

EUOI -EU08, EU12, EU!3

& EU!5 -EU17

EUOI -EU08, EU12, EU13

& EU15- EU17

PCEOI

Page 21 of34

Regulatory Basis

Env-A 904.03

Env-A 906

Env-A 904.08 &

RSA 125-C: 10-e

TP-0256 Page 22 of 34 Saint-Gobain Performance Plastics Corporatwn

·.·.·· .;, ./ ,,, . ... .·· ·.··.·••··· ........... · .. ·•···.·· ; ;": ... ··•······ •.••.:l••~l!~~jl7,;:i~~ijr:d.~~tiii~i.R.~~~Kfm~~ .· .. !•4%•,r.•·· ..... ,~ ,, •...•..••...•.. , ... :: :..···•·•·· Item

# Requirement

8. process operations to demonstrate compliance with Table 6, (cont.) Item 13; and

9.

f.) The destruction or removal efficiency of the RTO, including:

1. Destruction or removal efficiency, in percent;

2. Date tested; and

3. The emission test results, including;

i. The inlet concentration ofVOC;

ii. The outlet concentration ofVOC and each PFC for which an AGQS or SWQS has been established; and

iii. The method of determination of the above concentrations.

g.) The hourly average combustion chamber temperature in degrees F and hourly average inlet gas flowrate in scfin.

General NOx Recordkeeping Requirements

If the actual annual NOx emissions from ali permitted devices located at the Facility are greater than or equal to 10 tpy, then record the following information:

a.) identification of each fuel burning device;

b.) Operating schedule during the high ozone season (June I through August 31) for each fuel burning device identified in Table 7, item 9.a, above, including:

I. Typical hours of operation per day;

2. Typical days of operation per calendar month;

3. Type and amount of each fuel burned;

4. Design heat input rate in MMBtulhr; and

5. The following NOx emission data:

i. Actual NOx emissions per month;

ii. Typical high ozone season day NOx emissions, in pounds per day; and

iii. Emission factors and the origin of the emission factors used to calculate the NOx emissions.

Duration! Applicable Regulatory Frequency Unit Basis


Maintain Data for Annual Report

PCEOI

EUOI ~EU06, EU12, EUI3, EU15, EUI6, EU20 ~ EU22,

EU24 &

EU26

Env-A 904.08 &

RSA 125-C: I 0-e

Env-A 905.02


r \ , > ''.' .·· .. ; ; ; ··· jt~~·~/j.$;){~qol-~k~~~i~g?R.~fi~i~~m~l\ts••·-~-· .x· \•.:'·.·•••s:~· ;·• .·.·.••···; > •• , •. ' ·· .. ·• ' .. . · ... .. · .. .

Item Requirement Duration! Applicable Regulatory

# Frequency Unit Basis

10. Re~u/gted Toxic Air Pollutants Update prior Facility Wide Env-A 902.0 I

Maintain records documenting compliance with Env-A 1400. to process (State-only

Compliance was demonstrated at the time of permit issuance as changes and Requirement)

within 90 described in the department's Permit Application Review

days of each Summary for Application #18-0227. The source must update the revision of compliance demonstration using one of the methods provided in

Env-A 1400 Env-A 1405 if:

a.) There is a revision to the list ofRTAPs lowering the AAL or de minimis value for any RTAP emitted from 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 coating will increase);

c.) An RTAP that was not evaluated in the Application Review Summary will be emitted (e.g., a new coating will be used); or

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

II. Additional RecordkeeeJng Requirements: Facility_-wide emission Monthly EUOI -EU08, Env-A 906 limitations9 EU12, EUI3, &

Maintain a 12-month running total of facility-wide emissions, EUI5- EU17, Env-A

calculated pursuant to Env-A 705.03, ofVOC and HAPs, for the EU20-EU26 604.02(a)(3)

purpose of demonstrating that the total emissions of these &PCEOI

pollutants are below the major source thresholds as limited in Table 5, Item I.

12. 40 CFR 60 Subeart VVV- Pol~meric Coating o[Su1212orting Semiannual EUOI -EU08, 40 CFR 60.744(b) Substrates Recordkeee_ing Reguirements EU12, EUI3, &

Maintain records of estimates of the projected annual amount of EUI5&EUI6 40 CFR 60.747(c)

VOC to be used for the manufacture of polymeric coated (Subpart VVV)

substrates over the year and actual 12-month VOC use.

Facility~wide VOC emissions shall include not only the contribution from the process equipment, but also the contribution from fuel burned in the process equipment burners and the emergency engines. Prior to the final construction and installation date of the RTO (PCEO 1), actual VOC emissions will be exhausted through the existing coating tower stacks. After the final construction and installation date of the RTO (PC EOI ), VOC emissions will be exhausted through the proposed RTO stack.


r· . )i ....... • o I . . ·. ·•· . ·• . • ;",')' :~:::~; ;'''f~~~~ti'~i~~~~~k~~~}~~;Q.e~llir~pi~jtts .. '.f')•······ ····:····· ,/ • ; ............. <

Item Durlltillnl ....

Regullltllry Requirement AppllCllble

# Frequency Unit BliSiS

13. AdditiongJ Recordkee{2.ing Requirements: Pollution control As specified PCEOI Env-A 906 equipment in Table 6

Maintain records of all air pollution control equipment activities required in Tables 5 and 6, including:

a.) Stack test results required pursuant to Table 6, Items 14 and 17;

b.) The information recorded in Table 6, Item 3 for visible stack emission checks including any Method 9 observations 10;

c.) Hourly averaged combustion chamber temperature readings pursuant to Table 6, Item I I.a.;

d.) Date, time, duration and probable cause of pollution control equipment monitoring parameter excursions;

e.) Air pollution control equipment maintenance activities, including preventative maintenance and annual visual inspections. Records shall include the date and duration of any outages; and

f.) Corrective actions and preventative measures taken.

14. 40 CFR 60 S~beart /lll- Stationa[J!. Comeression Ir;n.itiQn Maintain EU20& EU21 40 CFR 60.4211 Internal Combustion Enginf;_s Recordkeff.f}.ing Reguirements Up-to-date (Subpart IIII)

The owner or operator shall maintain the following records: Data

a.) Documentation from the engine manufacturer certifYing that the engine complies with the applicable emission standards stated in 40 CFR Part 60, Subpart llll;

b.) A copy of the manufacturer's emission-related written instructions (O&M manual) for the engine and its associated control devices;

c.) The maintenance conducted on the engine in order to demonstrate that the device was operated and maintained according to the O&M manual;

d.) The operation of the engine in emergency (i.e. loss of power) and non-emergency situations (i.e. maintenance and testing)

14. that are recorded through the non-resettable hour meter. The Maintain EU20 & EU21 40 CFR 60.4211 (cont.) owner or operator must record the time of operation of the Up-to-date (Subpart III I)

engine and the reason the engine was in operation during that Data time; and

e.) Documentation of the federal, state or local standard(s) that require the owner or operator to conduct maintenance and testing for more than I 00 hours per calendar year if the owner or operator is exercising the option listed in Footnote 7.

15. Permit Deviation Recordkeeeing As specified EUOI-EUOS, Env-A 9!1.03(b)

Maintain records of each permit deviation which result in excess EUJ2, EUJ3,

emissions or monitoring parameter excursions lasting 48 hours or EUI5- EU17,

more. The content of the records is specified in Condition EU20-EU26

IX.B.2.(e through n). & PCEOJ

10 If a Method 9 test is conducted, the records shall include a copy of the certification for the person who conducted the test.

TP-0256 Page 25 of34 Salnt-Gobain Performance Plastics Corporation

VIII. Reporting Requirements

A. Pursuant to Env-C 203.02(b), Date of Issuance or Filing, written documents shall be deemed to have been filed with or received by the department on the actual date of receipt by the department, as evidenced by a date stamp placed on the document by the department in the normal course of business.

B. All emissions data submitted to the department shall be available to the public. Claims of confidentiality for any other information required to be submitted to the department pursuant to this permit shall be made at the time of submission in accordance with Env-A I 03, Claims of Confidentiality.

C. The owner or operator shall be subject to the reporting requirements identified in Table 8 below.

. ·.·.;; '/··· .. · ................... ,,. __ .>. . ···• .. 'J:'~ljl~ s•:R.~portin~·~~q'l)ire!Pents····.······ ( ;;··~············ •.•..•.••..•••• \. •••• •• •••••••••••••••••••••• • . .; . ··.;.: ... ·;· .

Item Requirement Frequency Applicable Regulatory

# Emission Unit Basis

I. Gfl_nera/ Re(2orting_ Reguirements For each report Facility Wide Env-A 907.0 I a.) Each report shall be separately and clearly labeled submitted to the

with: department I. The name, mailing address and physical

address of the source covered by the report; 2. The operating period covered by the report; 3. The penn it number and condition or item

number that requires the report submittal; 4. The type of report, using the name of the report

as specified in the reporting condition in the pennit, that is being submitted; and

5. The date the report was prepared; b.) An owner or operator who submits a report that is a

revision to a previously-submitted report shall clearly identiJY the revised report with the infonnation specified in Table 7, Item Ia. above, and indicate which portions of the report have been revised;

c.) The owner or operator may submit more than one report with a single cover, provided the owner or operator clearly identifies each report being submitted using the infonnation required in Table 7, Items I a. and I b. above, if applicable, for each report; and

d.) The owner or operator shall submit reports as paper documents or by electronic means.

"

TP-0256 Page 26 of 34 Saint-Gobain Performance Plastics ro,

,;••···•·· ·· ····••··•· .•.. '· > i ••• ;\' •• b .• , · •.. (J;'~n.~;i~:J.l::"' '·' .. ~:ci;,; ;::,:;.;•••··.·.··•·•• .'. ··•·····•••· \' :·x·•••··.····· .. · ...... Item

Requirement Frequency . Applicable Regulatory # Emission Unit Basis

2. Annual Emissions Report Annually EUOI-EUOS, Env-A 907.02

Submit an annual emissions report which shall include (received by the EUI2, EU13, &

the following information: department no EU15 ~ EU17 RSA 125-C:IO-e

a.) Actual calendar year emissions from each coating later than April &

15th of the EU20~ EU26 tower (EUOI-EUOS, EU12, EU13, EU15 ~ EU17,

following year) EU22 ~ EU26) of:

I. Total VOCs;

2. Each HAP and RTAP, reported by CAS number; and

3. Each PF AS as measured by the most recent stack test conducted in accordance with Table 6, Items 14or 17.

b.) Actual calendar year emissions from the process heaters associated with the coating towers (EUO I ~ EU06, EUI2, EU13, EUI5, EU16, EU22, EU24 and EU26) and the engines (EU20 and EU21 ) 11 of:

I. NOx,

2. Total VOCs;

3. Filterable PM;

4. CO; and

5. so,. c.) The methods used in calculating such emissions in

accordance with Env-A 705.03, Determination of Actual Emissions for Use in Calculating Emission-Based Fee;

d.) The emission factors and the origin of the emission factors; and

e.) All information recorded in accordance with Table 7, Items 2 and 3.

3. VOC Emission Statements Rqzorting_ Reguirements Annually EUOI-EUOS, Env-A 908

If the actual annual VOC emissions from all permitted (received by the EU12, EU13,

devices located at the Facility are greater than or equal to department no EU15~EU17

I 0 tpy, then include all the data recorded in accordance later than April &

with Table 7, Item 5 with the annual emission report. 15th of the EU20 ~ EU22 following year)

4. NOx Emission Statements Re{2orting Reguirements Annually EUOI ~ EU06, Env-A 909

If the actual annual NOx emissions from all permitted (received by the EUI2, EU13,

devices located at the Facility are greater than or equal to department no EU15, EUI6,

10 tpy, then include all data recorded in accordance with later than April EU20~ EU22,

Table 7, Item 9 with the annual emission report. 15th of the EU24 following year) &

EU26

The RTO (PCEOI), rated at less than 10 MMBtulhr burning natural gas, and a boiler, rated at 1.56 MMBtulhr burning #2 fuel oil, are also located at the facility but because they are below pennitting thresholds of Env~A 607.0 I and the facility is a true minor source for SOl, NOx, CO, and PM, the criteria pollutant emissions from these combustion devices are not required to be included in the annual emissions reporting requirements pursuant to Env-A 907.02.

TP-0256 Saint-Gobain Performance Plastics CorporatiOn

•;,·.······················•··.••····•··.\•/' ~\'ig; Tal?';:.?$/.'.·:·,······f·•····•·····.•. ~ . · ....

Requirement Frequency #

5. Compliance Demons/ration fOr Env-A 1400. Regulated Toxic Air Pollutant Regulation andRSA 125-C: 10-e. Requirements for Air Emissions ofPerfluorinated Compounds Impacting Soil and Water

a.) The owner or operator shall update and submit an Env-A 1400 compliance demonstration in accordance with Table 7, Item I 0 and an updated air deposition modeling analysis of post-controlled PFC emissions based on final as-built RTO emission parameters and the results of the stack testing conducted pursuant to Table 6, Item 14 for RTAPs and PFCs, respectively.

b.) The Env-A 1400 compliance demonstration required in Table 8, Item 5(a) above, shall include the submission of the air dispersion model for RTAP emissions, an evaluation of compliance with the limitations in Env-A 1400, a determination if the RTO requires a permit pursuant to Env-A 607.0l(t) and Env-A 1403, Permit Requirements and if so, a compliance plan and schedule as outlined in Table 8, Item 5(c), below.

c.) The compliance plan and schedule shall include the following:

I. A narrative description of how the source shall achieve compliance with Env-A 1400 in both the long-terrn (i.e. proposed permit conditions or addition of air pollution control equipment) and short-terrn (i.e. operating limitations to mitigate the emissions until a permit is issued);

2. A schedule of remedial measures, including an enforceable sequence of actions with milestones leading to compliance with any applicable requirements for which the source identified in Item 5(b) above; and

3. A schedule for submission of certified progress reports no less frequently than every month.

d.) The updated deposition model required in Table 8, Item 5(a) above, shall include the submission of an evaluation of compliance with the limitations in Condition V. Table 5, Item 5(g), a determination if the facility requires a permit limiting its potential to emit pursuant to Env-A 607.0l(n) and proposed operating limitations, if necessary, to ensure compliance with the annual PFC emission limits in Condition V. Table 5, Item 5(g).

Received by the department within 30 business days

of the submittal of the stack testing

report required in Table 6, Item 15


PC EOI

Page 27 of34

Regulatory Basb

RSA 125-C:10-e Env-A 1400

& Env-A 910.0 I

TP-0256 Page 28 of 34 Saint-Gobain Performance Plastics C

l_········ ........................ · .. ·/·· ..... •~ ;;;~ •,: u• · ....... ,; .. ~l>'Q.; "':··~ ..... ·.··· ·i;.. .j ,. • •.•.• Item

Requirement Frequency Applicable Regulatory

# Emission Unit Basis 6. U12date to Air Pollution Diseersion and De{2osition As specified EUOI-EU08, RSA 125-C:IO-e

Modeling Impact Analvsis EUI2, EU13, &

If an update to the facility's air pollution dispersion or EUI5- EUI7, Env-A 910.01

deposition modeling impact analysis is required pursuant EU22-EU26

to Env-A 606.02 (e.g. stack parameters including &

exhaust flow rate and temperature for PCEO I differ rrom PC EOI

stack parameters as modeled in Application# 18-0227), submit the information required pursuant to Env-A 606.04:

a.) With the permit application submitted for the change which triggered the analysis; or

b.) Within 15-days of completion of the change which triggered the analysis, if a permit application is not required.

7. Permit Deviation Reaortinf:_ Reg_uirgments As specified EUOI-EU08, Env-A 911.04(a)

Report pennit deviations that cause excess emissions, or EUI2, EU13, &

monitoring parameter excursions lasting 48 hours or EUI5- EUI7, Env-A 911.04(d)

more, in accordance with Condition IX. B. EU20- EU26 &

PC EOI

8. Annual Emission Fee Annually EUOI-EU08, Env-A 705

Pay annual emission fee in accordance with Condition (received by EUI2, EUI3,

XII. department no EUI5- EU17, later than May EU20-EU26

15th of the & following year) PCEOI

9. Startuv Notification Actual date of PCEOI Env-A 910.01

Submit a notification to the department stating the date initial startup of

of initial startup ofPCEOI. the device, received by the

department within I 0 business days after such date

TP-0256 Saint-Gobain Performance Plast cs CorporatiOn

1···: .. ···>'cti\~\n\ ·,'•8t;"~;,.) ~ ··•··••·•·.·:•...;;:.:~;; ... ~··~·•;;u Item

#

10.

Requirement

Air Pollution Control Equipment Monitoring Plan

An air pollution control equipment monitoring plan was submitted with Application# 18-0227. However, because the proposed control device is in the preliminary design phase, not all information was provided in the plan. Therefore, the owner or operator shall submit a monthly update report which shall include the following:

a.) Manufacturer of Control Device: Status update on selection of the manufacturer of the air pollution control device.

b.) Model and Serial Number of Control Device: Submit information once model and serial numbers are known.

c.) Description of Control Device and How It Operates in the Process: Submit documentation from the manufacturer of the air pollution control device including schematics, documentation of design and detailed description of the control device and how it will be designed to operate.

d.) The Capture Efficiency of the Device and Method of Determination: Status update on tower improvements for maximizing capture efficiency conducted to date and going forward until construction is complete. Submit a Total Enclosure Monitoring and Capture Efficiency Verification Plan (for each device, as applicable) so that fugitive emissions are minimized or eliminated.

e.) The Control Ejjiciency of the Device and Method of Determination: Submit documentation from the manufacturer of the air pollution control device regarding control efficiency guarantees and proposed methods of determination of the control efficiency of the device.

f.) Operational Parameters of the Device, and Normal Ranges, and Range During Start-up or Shutdown Conditions: Submit updated operational parameters of the device and normal ranges from the manufacturer of the air pollution control device.

g.) Description of Data Recording or Recordkeeping, Parameter Set points and Alarms, and Operator Responses to Malfunctions of the Control Device to Prevent Uncontrolled Emissions: Submit updated information pertaining to data recording or recordkeeping, parameter setpoints and alarms, and operator responses to malfunctions from the manufacturer of the air pollution control device.

Frequency

Monthly (Received by the

department within I 0 business days

of the end of each month) until the

Final Air Pollution Control

Equipment Monitoring Plan required in Table 8, Item I 0. k.) is approved by the

department


PCEOI

Page 29 of34

Regulatory Ba8is

RSA 125-C: I 0-e Env-A 810.0 I

& Env-A 910.01

Item # Requirement

TP-0256

10. h.) Manufacturer's Recommended Procedures for (cont.) Operation: Submit documentation from

manufacturer of the air pollution control device regarding recommended procedures for operation.

II.

i.) Manufacturer's Recommended Schedule for Service, Maintenance and Calibration of the Device:

I. Submit documentation from the manufacturer of the air pollution control device regarding recommended schedule for service, maintenance and calibration of the device; and

2. Submit additional information pertaining to the maintenance of the process vent emission streams that will be collected and tied into a header system. This information shall include methods for keeping the vents clear of char material, including but not limited to insulation, cleaning ports, cleaning frequency and methodology and any proposed operation and maintenance of auxiliary equipment necessary to ensure the process vent emission streams remain clear of char material.

j.) Other Operational Parameters Affecting the Ability of the Device to Control Emissions: Submit documentation from manufacturer of the air pollution control device regarding any other operational parameters affecting the ability of the device to control emissions, as necessary.

k.) Final Air Pollution Control Equipment Monitoring Plan: The owner or operator shall submit a final approvable Air Pollution Control Equipment Monitoring Plan to the department.


If the owner or operator determines that the information and procedures documented in the air pollution control equipment monitoring plan submitted with Application #18-0227 and revised in accordance with Table 8, Item 10 need to be changed at any time to accurately represent the activities performed to maintain the control equipment, the owner or operator shall submit a revised monitoring or management plan, as applicable, to the department in writing.

~ >~:::

Frequency

Monthly (Received by the

department within I 0 business days

of the end of each month) until the

Final Air Pollution Control

Equipment Monitoring Plan required in Table 8, Item I 0. k.) is approved by the

department

Received by the department no

later than 60 days after completion of construction

and installation of PCEOI

Submit to the department within

30 days of any change to the plan


PCEOI

PCEOI

Page 30 of34

Regulatory Basis

RSA 125-C:IO-e Env-A 8!0.01

&

Env-A 910.0 I

Env-A 810.0l(e)


! ................................... /< ••.••• • /

-,,,:o;;,'

·.;.·.•· •ra1>}~~·~1~~~~if-~~ij~ij\l,irl.l~e~l:~·.••·• .. ·•·•>:.;•>C•·······•·•····· ;•~ .••. ; ; (' .;(· .... · .. ·.······ ::::z,,;:<'

Item Requirement Frequency

Applicable Regulatory # Emission Unit Basis

12. NSPS R~.fl.Drling Rffi..uiremg_nts As required EUOI ~ EU08 40 CFR 60.747(c)

Submit to the department and U.S. EPA Region I, a & (Subpart VVV)

report on the first semiannual estimate in which EUi 1 ~ EU16

projected annual VOC use exceeds 95 Mg and report the first 12-month period in which the actual VOC use exceeds the applicable cutoff.

The address for US EPA Region I is:

Director, Enforcement and Compliance Assurance Division

U.S. EPA Region I 5 Post Office Square

Suite l 00 (04~2) Boston, MA 02109~3912

Attn: Air Compliance Clerk

The address for the department is:

NH DES~ Air Resources Division Attn: Compliance Measurement & Data Programs

Manager PO Box 95

29 Hazen Drive

Concord, NH 0330 l-0095

IX. Permit Deviation Reporting Requirements

A. Env-A 10 I, Definitions:

1. A permit deviation is any occurrence that results in an excursion from any emission limitation, operating condition, or work practice standard as specified in either a Title V permit, state permit to operate, temporary permit or general state permit issued by the department.

2. An excess emission is an air emission rate that exceeds any applicable emission limitation.

3. An emission limitation means "emission limitation" as defined in section 302(k) of the Act, namely "a requirement established by the State or the Administrator which limits the quantity, rate, or concentration of emissions of air pollutants on a continuous basis, including any requirement relating to the operation or maintenance of a source to assure continuous emission reduction and any design, equipment work practice or operational standard promulgated under this Act." This term includes "emission standard".

B. Env-A 911.04, Reporting Requirements: In the event of a permit deviation that causes excess emissions, or for pollution control equipment monitoring parameter excursions lasting more than 48 hours in duration:

1. Notify the department of the permit deviation and excess emissions by telephone (603-271-1370), fax (603-271-7053) or e-mail ([email protected]), within 24 hours of discovery of the permit deviation, unless it is a Saturday, Sunday, or state legal holiday, in which event, the department shall be notified on the next day which is not a Saturday, Sunday, or state legal holiday.


2. Submit a written report of the deviation on paper or by electronic means to the department within I 0 days of discovery of the permit deviation reported above. The report shall include all of the following information:

a. Facility name; b. Facility address; c. Name of the responsible official; d. Facility telephone number; e. A description of the permit deviation, including the applicable permit number and

permit condition(s); f. The probable cause of the permit deviation; g. The date and time of the discovery of the permit deviation; h. The actual date( s) and time( s) of the permit deviation; 1. The duration of the permit deviation, including the date and time that the device,

process or air pollution control equipment returned to operation in compliance with an enforceable emission limitation or operating condition;

J. The specific device, process or air pollution control equipment that contributed to the permit deviation;

k. Any corrective measures taken to address the permit deviation; I. Preventative measures taken to prevent future permit deviations; m. The type and amount of excess emissions that occurred as a result of the permit

deviation; and n. The calculation or estimation used to quantify the excess emissions.

X. Permit Amendments

A. Env-A 612.01, Administrative Permit Amendments:

I. An administrative permit amendment includes the following:

a. Corrects typographical errors; b. Identifies a change in the name, address, or phone number of any person identified

in the permit, or provides a similar minor administrative change at the source; c. Requires more frequent monitoring or reporting; or d. Allows for a change in ownership or operational control of a source provided that a

written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and new permittee has been submitted to the department.

2. The owner or operator may implement the changes addressed in the request for an administrative amendment immediately upon submittal of the request.

B. Env-A 612.03, Minor Permit Amendments: Temporary Permits and State Permits to Operate:

I. The owner or operator shall submit to the department a request for a minor permit amendment for any proposed change to any of the conditions contained in this permit which does not qualify as either an administrative or significant amendment.

2. The request for a minor permit amendment shall be in the form of a letter to the department and shall include the following:

a. A description of the proposed change; and


b. A description of any new applicable requirements that will apply if the change occurs.

3. The owner or operator may implement the proposed change immediately upon filing a request for the minor permit amendment, but shall be subject to enforcement if the department later determines that the change violated any applicable state or federal requirement.

C. Env-A 612.04, Significant Permit Amendments: Temporary Permits and State Permits to Operate:

I. The owner or operator shall submit a written request for a permit amendment to the department prior to the implementation of any proposed change which meets one of the following:

a. Any proposed change to an existing process or device that results in the following: i. Any increase in allowable hourly or annual emissions ofNOx, SOz, VOCs, HAPs

or PM10; or ii. Any increase in potential emissions equal to or greater than 5 lb/hr of CO;

b. Any proposed change to operating or emission limitations; c. Any proposed change in the type of pollution control equipment; or d. Any proposed change that results in an increase in previously-allowed loading of

existing pollution control equipment by greater than 50%.

2. A request for a significant permit amendment shall include the following:

a. A complete application form, as described in Env-A 1703 through Env-A 1708, as applicable;

b. A description of: i. The proposed change; ii. The emissions resulting from the change; and iii. Any new applicable requirements that will apply if the change occurs; and

c. Where air pollution dispersion modeling is required for a device pursuant to Env-A 606.02, the information required pursuant to Env-A 606.04.

d. An air pollution control equipment monitoring plan.

3. The owner or operator shall not implement the proposed change until the department issues the amended permit.

XI. Inspection and Entry

Department personnel shall be granted access to the facility covered by this permit, in accordance with RSA 125-C:6, VII for the purposes of inspecting the proposed or permitted site, investigating a complaint, and assuring compliance with any applicable requirement found in the New Hampshire Rules Governing the Control of Air Pollution and/or conditions of any permit issued pursuant to Chapter Env-A 600.

XII. Annual Emission Fee Requirements

A. Env-A 705.02, Annual Emission Fee: The owner or operator shall pay to the department each year an annual emission fee consisting of an emission-based fee calculated pursuant to Condition Xll.C and a baseline emission fee stated in Condition XII.D. The owner or operator shall submit, to the department, payment of the annual emission fee so that the department receives it on or before May 15th for emissions during the previous calendar year. For example, the fees for calendar year 2019 shall be received on or before May 15, 2020.

12

I)


B. Env-A 705.03, Determination of Actual Emissions for use in Calculating of Emissionbased Fee: The owner or operator shall determine the total actual annual emissions from the emission units listed in Table I for each calendar year in accordance with the methods specified in Env-A 705.03.

C. Env-A 705.04, Calculation of Emission-based Fee: The owner or operator shall calculate the annual emission-based fee for each calendar year in accordance with the procedures specified in Env-A 705.04 and the following equation:

FEE=E*DPT where:

FEE =The annual emission-based fee for each calendar year as specified in Env-A 705; E =Total actual emissions as determined pursuant to Condition XII.B; and OPT =The annual fee, in dollars per ton of emissions, which the department has

calculated in accordance with Env-A 705.04 12.

D. Env-A 705.06, Payment of Annual Baseline Emission Fee: In addition to the annual emission-based fee, the owner or operator shall pay to the department each year an annual baseline emission fee of$5,250 pursuant to Env-A 705.07(a). 13

For additional information on emission-based fees, visit the department website at h Ups:/ /www. des. n h. go vI organization/ d i visions/air /pehb/ apps/ fees. htm. Pursuant to Env-A 705.06(c), if the owner or operator is not required to pay an emission-based fee for any calendar year because the Facility had zero reportable emissions, the annual baseline fee shall be $500 in lieu of the fee stated in Condition XILD.

3

Facili : Location: AFS#:

PERMIT APPLICATION REVIEW SUMMARY

PROJECT DESCRIPTION

New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH 03302-0095 Phone: 603-271-1370 Fax: 603-271-7053

En ineer: Catherine Beahm

Date: 02/ll/2020 Pa e I of28

Pursuant to RSA 125-C: I 0-e, the New Hampshire Department of Environmental Services (NHDES) determined that devices operated at Saint-Gobain Performance Plastics Corporation (SGPP), 70 I Daniel Webster Highway in Merrimack, New Hampshire have emitted and continue to emit to the air perfluorinated compounds (PFCs) 1 and precursors. The emission of these PFCs have caused and continue to contribute to an exceedance of ambient groundwater quality standards (AGQS) as a result of deposition of the PFCs and precursors from the air. Therefore, the devices located at SGPP are subject to the application of best available control technology (BACT) as defined in RSA 125-C: I 0-b, I( a).

• SGPP was required to submit an air permit application and BACT analysis to NHDES by March 26, 2019. The details ofNHDES' determination and the requirements of the application were outlined in the NHDES letter issued to SGPP on September 26, 2018.

• SGPP submitted both a confidential and a redacted air permit application on March 26,2019 with supplemental information on April 19,2019.

• NHDES requested additional information in a letter dated May I, 2019.

• SGPP submitted supplemental information in a letter with attachments on May 30, 2019.

• NHDES sent a letter to SGPP on June 20,2019 regarding EPA Office of Research and Development (EPA ORO) Report #6 which identified additional per- and polyfluorinated alkyl substances (PFAS) emitted from the facility. In the letter, NHDES quantified 89 PFAS compounds and identified the need for air dispersion modeling for hydrogen fluoride (HF) emissions from the proposed control device.

• SGPP submitted additional information in a letter dated August 1, 2019. In the letter, SGPP responded to the NHDES letter dated June 20, 2019 regarding the calculation methodology for PFAS and HF emissions and submitted an air dispersion model conducted by Barr Engineering Co. (Barr) for HF (as fluoride) emissions from the proposed control device.

• On July 31,2019, NHDES requested additional information regarding small devices not previously included in historical air permits due to the nature of their operation. SGPP submitted the requested information along with changes to the maximum production rates of the coating towers and heat inputs of the combustion devices associated with the coating towers on August 20, 2019 and revised calculations as a result on August 29, 2019.

• The facility has determined that a Regenerative Thennal Oxidizer (RTO) would satisfy the requirements of the BACT analysis and is requesting via this application that NHDES issue a Temporary Permit pursuant to Env-A 607, Temporary Permits for the installation of a RTO for the control of PFC and precursor emissions associated with the facility's coating operations.

• This permit application review summary outlines NHDES' review of the temporary permit application, BACT analysis and regulatory requirements associated with the SGPP facility.

• The current State Permit to Operate (SP-0072) is scheduled to expire on April30, 2020. Therefore, a renewal application package including all the information contained in this permit application and additional information related to the antenna cover fabrication area, emergency generator, and fire pump engine is due January 31, 2020. These devices (EU 17, EU20 and EU21) were already a significant part of the regulatory review as a component

RSA 125-C: 1 0-e uses the term "Perfluorinated compounds" or PFCs. RSA 125-C: I 0-e I(d) defines PFCs as a list of compounds identified in paragraph 1.1 of Environmental Protection Agency Document#: EPA/600/R-08/092 Method 537. "Determination of Selected Perfluorinated Alkyl Acids in Drinking Water by Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS)", Version I. I (September 2009). The term PFAS (per- and polyfluorinated substances) and PFCs arc used interchangeably in this document; most notably using PFCs when referring to the statute requirements and PF AS when referring to overall compounds of interest.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Engineer: Catherine Beahm Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 0211112020 I Page 2 of28

of the temporary permit application. Therefore, on September 30, 2019, SGPP submitted additional information related to these devices and requested that the supplemental information be incorporated into this application package to satisfY the renewal application requirements for SP-0072. Therefore, this permit includes existing conditions from SP-0072 that did not change as a result of this project and upon issuance of this temporary permit, SP-0072 is terminated.

FACILITY DESCRIPTION

SGPP primarily manufactures polytetrafluoroethylene (PTFE) coated fabrics and PTFE films. The fabrics are manufactured for a variety of chemical and weather resistant applications. SGPP is currently permitted to operate 14 coating towers2

, an antenna cover fabrication area, a fire pump, and an emergency generator, all covered under an existing State Permit to Operate, SP-0072 which expires April 30, 2020. There are additional ancillary devices at the facility that do not emit air pollutants above permitting thresholds and are therefore not covered by the current air permit3•

In the PTFE coating towers, the fabric is passed through a coater dip pan filled with a PTFE aqueous dispersion, which can include surfactants, viscosity modifiers and colorants. The fabric then passes through a heating tower, which is divided into three temperature zones that remove water, volatilize the surfactant and sinter the resin onto the fabric. Similarly, the production of film products includes the same sequence of steps, however, rather than coating a cloth, the PTFE coating is temporarily applied to a reusable carrier belt. The film coating is then removed and the carrier belts are reused. The fabric and/or film can go through a single or multiple pass process to produce the desired intennediate or final product. SGPP manufactures finished products in which the intermediate coated fabrics and films are laminated and/or cut and assembled into final products.

In addition to the primary coating towers, there are other smaller production activities. The Chemsil process applies and dries coating onto fabric by thermally treating a solid paste without the use of a carrier solvent. There are also several pieces of post-processing equipment utilized at the facility after materials have been run on the coating towers. The MTM and Step Press/Laminator are pieces of equipment that utilize heat to perform operations which laminate or otherwise affix coated fabric and films. Neither piece of equipment utilizes the addition of solvents or other chemicals to join the different types of materials. The Heat Clean source is an oven used for cleaning by heating, and similarly does not involve the addition of solvents or other chemicals. These pieces of equipment have not previously appeared in the facility's air permit because they are not expected to result in releases of volatile organic solvents (VOCs), regulated toxic air pollutants (RTAPs) or hazardous air pollutants (HAPs). However, each of these sources are proposed to be exhausted to the new RTO control device in order to maximize the potential collection and control ofPFC by minimizing the potential for fugitive releases from facility operations. Therefore, they are being added as emission units in the proposed draft permit.

SGPP is currently permitted for an antenna cover fabrication area as part of the finishing operations. This operation includes manual application of adhesives to the fabric for bonding to other pieces of fabric, ancillary items or to metal frames. This process emits VOCs, RTAPs and HAPs but not PFCs.

SGPP is permitted for operation of an emergency generator and a fire pump engine. A #2 fuel oil-fired boiler system (for building heat) rated at 1.56 MMBtu/hr is also located at the facility but is below permitting thresholds. Because the proposed RTO will combust natural gas and therefore produces criteria pollutants\ facility-wide emission calculations of criteria pollutants from all fuel burning equipment were included in the application and evaluated in this permit application review summary. SGPP has the potential to emit VOCs at levels greater than the major source threshold of 50 tpy and the potential to emit HAPs at levels greater than the major source threshold of I 0 tpy for any individual HAP and 25 tpy for all HAPs combined. Therefore, the facility has penn it conditions limiting these pollutants to less than these thresholds thereby establishing the facility as a synthetic

Use of the ME Tower (EU II) was discontinued in November 2016 and the unit was removed in October 2017. Use of the MI Tower (EU 14) was discontinued in March 2017 and the unit was removed in October 2017. Sec REVIEW OF REGULATIONS: State Regulations later in the permit application review summary for permit applicability requirements. Criteria pollutants include particulate matter (PM w), sulfur dioxide (S02), oxides of nitrogen (NOx), and carbon monoxide (CO). In addition, volatile organic compounds (VOCs) are included because in combination with NOx, these compounds react in the atmosphere to from ozone which is another criteria pollutant for which EPA has set National Ambient Air Quality Standards (NAAQS).

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Eneineer: Catherine Beahm Location: 70 I Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02111/2020 I Page 3 of28

minor source of air pollution for VOCs and HAPs. The Facility does not have the potential to emit the criteria pollutants SO,, NOx, CO, and PM10 at levels greater than the major source thresholds for these pollutants. Therefore, the facility is a true minor source for SO,, NOx, CO, and PM 10•

PERMIT HISTORY

. . . : .. . .,

• . : ·Table 1 • Permit History . . •· · ..

•••• . . ·· . . . . .· ..• .. . . .· .

•.• : ) ···· ....... '.. .· ._ ' , __

I· Permit# A,ppUcatlon # EJ(pitati!ln . . ·· .. ·.•· · .

••• Des~ripti<!n ...•• · .. ·· ' - -<:

I~s~I\J)ate I·'·· Date.· ·

TP-BP-358 FY90-0084 Initial Temporary Permit- Pressure Sensitive Adhesive Coater5 01/0411991 06/30/1992

PO-BP-2607 FY90-0084 Initial State Permit to Operate- PSA Coater 0611111992 06/30/1995

TP-BP-0461 FY93-0148 Initial Temporary Permit- Antenna Cover Fabrication Area6 I 0/I 511993 04/30/1995

PO-BP-2607 FY94-0158 Permit Amendment regarding emission estimates for VOCs and

03/25/1994 06/30/1995 silica (R TAP)- PSA Coater

PO-BP-2607 No application # Permit Renewal - PSA Coater & Initial State Permit to Operate -

PO-BP-2697 assigned (received

Antenna Cover Fabrication Area 02/0611996 02/28/2001

09/0711995)

PO-BP-2607 Administrative Amendment- Change in ownership rrom N/A Chemfab Corporation to Compagnie de Saint-Gobain. Name N/A 02/28/200 I

PO-BP-2697 change to Chemfab/Saint-Gobain Performance Plastics.

SGPP requested permit PO-BP-2607 be re-issued until FP-S-0151 FYOJ-0074 08/31/2001. Requested renewal of State Permit to Operate for 05/29/2001 05/31/2006

Antenna Cover Fabrication Area.

Initial Temporary Permit- Tower Coaters

FP-T-0075 FY02-0035 SGPP submitted an application for installation of9 towers being 12/04/200 I 06130/2003 moved rrom VT to NH in addition to the existing 9 towers and

R&D tower in NH.

Permit FP-S-0151 Renewal for the Antenna Cover Fabrication FP-S-0151 FY03-0189 Area & incorporation of FP-T-0075 requirements for the Tower 11114/2003 11/30/2008

Coaters into one facility-wide permit

SP-0072 08-0335 Permit Renewal- Facility-wide permit 12/17/2009 12/31/2014

SP-0072 10-0161 Minor Amendment to replace 27 natural gas burners on tower N/A I2/31/2014 coaters with new high-efficiency burners.

SP-0072 14-0379 Permit Renewal- Facility-wide permit 04/2I/2015 04/30/2020

SP-0072 15-0492 Minor Amendment to replace 2 old fire pumps. 10116/2015 04/30/2020

The Pressure Sensitive Adhesive (PSA) Coater was installed in 1990 and removed from service August 31, 2001. The device applied VOC containing adhesive materials to the PTFE coated fiberglass fabrics for final assembly. Based on the information reviewed, it does not appear that PF AS compounds were utilized on this device. Based on the information reviewed, it does not appear that PFAS compounds were utilized on this device.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Engineer: Catherine Beahm Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 4 of28

PROCESS/DEVICE DESCRIPTION

Table 2- Emission Unit Identification

Process Identification Process Parameters Combustion Parameters (if applicable)

Installation Tower Max Maximum Number of Temperature Maximum Emission

Device Name Width Product #of Production Heating Range per Fuel Type Heat Input Unit ID7 Date Stages

(in) Width (in) (sq. ft/hr)8 Zones Zone("F) (MMBtu/hr)

EUOI MA Tower 1994 76 60 I 6,000 3 150-750 Natural Gas 3.9

EU02 MBTower 1998 188 175 1 17,500 3 150- 750 NG/Electric 7.5

EU03 MC Tower 1998 96 92 I 9,200 3 !50 -750 NG/Eiectric 4.5

EU04 MR Tower 2002 96 92 I 9,200 3 !50 -750 NG/Electric 4.5

EU05 MD Tower 1999 96 92 2 9,200 3 150- 750 NG/Electric 9.0

EU06 QXTower 1989 72 60 5 6,000 15 150-750 NG/Eiectric 7.5

EU07 20" SBC 1986 20 20 6 500 18 200 -750 Electric N/A

EU08 20" Coater 1986 20 20 I 500 2 150-450 Electric N/A

EU12 MGTower 2002 198 175 I 4,375 3 150-750 Natural Gas 6.0

EU13 MP Tower 2002 188 175 I 4,375 3 150- 750 Natural Gas 7.5

EU15 MQTower 2002 48 44 I 1,100 3 !50- 750 Natural Gas 4.5

EUI6 MS Tower 2002 96 92 I 2,300 3 !50- 750 NG/Eiectric 4.5

EUI7 Antenna Cover Fabrication Area 1993 N/A N/A N/A N/A None N/A None N/A

EU22 R & D Coater N/A 34 26 I 2,600 3 150-750 Natural Gas 2.0

EU23 Chemsil Coater N/A 42 38 I 3,800 6 !50- 600 Electric N/A

EU24 MTM N/A 52 50 I 5,000 2 !50 -750 Natural Gas 3.0

EU25 Step Press/Laminator N/A 60 48 I 4,800 I 650 Electric N/A

EU26 Heat Clean N/A 5'x6'x

N/A I N/A I !50- 750 Natural Gas 1.5 19'

7 Use of MH Tower (EU09) was discontinued prior to 2010 and the unit was removed in April 2013. Use of MX Tower (EU I 0) was discontinued in 2010 and the unit was removed in May 2012. s SGPP submitted revised maximum production rates for the towers in an email dated August 20,2019. Since maximum production rates was factored into the emission estimates both for

calculating RTAPs (Attachment 8.7 of the application) and scaling factors (Attachment 8.8 of the application), C.T. Male recalculated the emissions affected by these changes and submitted revised numbers on August 29, 2019. NHDES reviewed the revisions submitted and concurred with C.T. Male that the changes did not result in additional regulatory requirements or changed the facility's status with respect to regulatory compliance with existing permit limits.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Eneineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/1112020 I Page 5 of28

In addition to the process equipment listed in Table 2, SGPP also operates the following fuel burning devices that meet the permitting applicability:

Table 3- Summary of Additional Fuel Burning Equipment Rated Above Permitting Thresholds

Emission Emission Unit Description Installation Maximum Design Capacity &

Unit m• Date Permitted Fuel Types 1•

EU20 Clarke fire pump -Model JU4H-UFAD58 2015

1.20 MMBtu/hr (110 bhp; 82 kW) John Deere engine- Model 4045 Serial #PE4045L273937 ULSD- equivalent to 8. 7 gal/hr

EU2I Kohler emergency generator set- Modei40REOZJC

2015 0.47 MMBtu/hr (80 bhp; 60 kW)

John Deere engine- Model 4024HF285B Serial #SGM32DG5J ULSD- equivalent to 3.4 gal/hr

POLLUTION CONTROL EQUIPMENT

BACT Analysis

Pursuant to RSA 125-C: I 0-b, I( a), Best Available Control Technology (BACT) means an emission limitation based on the maximum degree of reduction for each air contaminant that would be emitted from any device that the department, on a case-by-case basis, taking into account energy, environmental, public health, and economic impacts and other costs, determines is achievable for such device through application of production processes or available equipment, methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such air contaminant.

The objective of a BACT analysis is to identifY all potential control technologies and then evaluate the control options for technical feasibility, control effectiveness, average cost effectiveness, incremental cost effectiveness, environmental impacts and energy impacts. EPA's "Top Down" approach, described in EPA's draft "New Source Review Workshop Manual", and consisting of a five step approach was used in determining BACT for PFC emissions. The five steps are listed below:

I. IdentifY all potentially available control options (Table 4);

2. Eliminate technically infeasible control options (Table 4);

3. Rank remaining control technologies by control effectiveness (Table 4);

4. Evaluate the most effective controls and document the results (Tables 4 and 5); and

5. Select BACT.

Table 4 lists the potential control technologies and the BACT analysis information submitted as part of the application. Table 5 is the cost effectiveness information also submitted by SGPP in the application.

10

This space intentionally left blank.

EUI8 and EUI9 (2 fire pumps with Detroit Diesel engines) are owned by the property owner but historically operated by SGPP. SGPP decommissioned the engines on or about August 28, 2015, returned them to the property owner, and replaced them with EU20 and EU21. The hourly fuel rates presented in Table 3 are set assuming a heating value of 137,000 Btu/gal for ultraMlow sulfur diesel (ULSD). The fuel consumption and maximum power ratings for each engine come from their respective engine specification sheets which also state that both engines arc US EPA Tier 3 certified.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation En2ineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054

AFS#: 3301100165 I Application#: I 18-0227 Date: 02/11/2020 I Page 6 of28

Table 4- Best Available Control Technology (BACT) Analysis .

. Potentially Evaluate Most Effective Controls Available

TypicaiVOC

Control Technically Feasible? (Y /N)11 Control Energy Environmental Cost

Options . Effectiveness" Impact . Impacts Effectiveness

Pollutants are Y - Provides projected Significant Resulting in

Regenerative oxidized at high high destruction amount of

emissions of Thennal criteria Oxidizer

temperature to efficiency with best 95-99% natural gas pollutants

$46,700/lb

(RTO) form combustion thermal efficiency of and

including NOx, products the oxidizer options electricity

VOCs and CO,

Pollutants are Y- Similar control Less thermal efficiency than

oxidized at high efficiency as R TO; Regenerative Thermal

Oxidizer for same % reduction Recuperative temperature to however, significantly

in PFCs. Additionally, reduced Thermal form combustion lower thermal 95-99% Oxidizer products efficiency which would

thermal efficiency would result in an increase in fuel

(Includes heat result in operating costs usage which would increase

recovery) well in excess ofRTO criteria pollutant emissions.

Similar to RTOs but process gas N - Catalytic systems

passes from flame are susceptible to

Catalytic area through catalyst poisoning,

Oxidation catalyst bed to blinding and fouling 90-99%

lower the especially in activation applications with

temperature for particles and moisture oxidation

Designed to <90% based on

remove fine Y- Utilized at other NH stack Limited

particulate matter similar facility; limited testing High

component life; Filtration efficiency during 20 18 electrical Systems

(fiberbed mist stack test; questionable 88% total for and energy

disposal issues $44,000/lb collection system

effectiveness for all measured PF AS demand for components

piloted at facility in PFCs based on NY and spent water

2018) stack testing

Gas molecules pass N - Effluent streams through a bed of that contain particulates

solid particles and moisture create the

Adsorption where they are potential for

90-95% adsorbed onto the compromising the

adsorbent adsorbent material (typically activated which reduces

carbon) efficiency ·.

" Technical feasibility for BACT is evaluated based on technology that must both be available and applicable. If a technology is deemed infeasible, it is no longer considered part of the BACT analysis. Those controls identified as infeasible in Table 4 have shaded columns once that technology has been eliminated in the BACT analysis.

12 Since control equipment has not historically been evaluated for PFC removal, the control effectiveness values are based on typical VOC control values except for filtration systems. Information obtained on VOC control effectiveness comes from EPA Air Pollution Control Technology Fact Sheets and EPA Control Techniques for VOC Emissions from Stationary Sources. For the filtration system, SGPP piloted a fiberbed mist collection system in April, 2018 that demonstrated emission reductions for some PFCs but for other PFCs the device did not achieve significant levels of control. NY also had stack testing conducted in 2016 on a PTFE coating line controlled by a fiberbed mist collection system.

PERMIT APPLICATION REVIEW SUMMARY

Facility: Saint-Gobain Performance Plastics Corporation Engineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054

AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 7 of28

Table 4- Best Available Control Technology (BACT) Analysis

Potentially Typical VOC Evaluate Most Effective Controls

Available Control

Technically Feasible? (Y /N) 11 Control Energy Environmental Cost

Options Effectiveness" Impact Impacts Effectiveness

N- Similar issues as Unknown but

Concentrate adsorption technologies expected to be

Concentrator organic compounds plus the potential low due to PFC .

System with in air stream to inability to desorb any chemical and

Oxidation reduce volume captured pollutants physical

prior to oxidizer thereby reducing properties

efficiency

Transfers soluble Y- While Electrical Disposal issues

Spent water

Absorption components of gas concentration in gas

demand for for spent PFCs treatment

(Scrubber) stream into liquid stream is low, PFCs 70-99%

pumping contaminated costs in

through mass have a high solubility in water water generated

excess of transfer water $21M/yr

. Converts a gas or

Unknown but vapor to liquid by

expected to be sufficiently

N- Technology is only low since lowering its

effective under high exhaust is a .

temperature and/or concentration gradients combination of

Condensation increasing its which the influent gas particulate and

pressure - depends stream in this vapor and low

on condensation point of the

application is not inlet

compound being concentration of .

contaminants controlled .

Gases containing N - Large footprint,

biodegradable maintenance intensive,

organic compounds operates in narrow

are vented through bands of temperature

a bed of active Bio-filtration

material that and pressure, not adept 80-90%

biodegrades the at responding to swings

organics to carbon in pollutant loading and

dioxide (C02) and are primarily used for

odor control water (H,O) .

Material Change the use of N - Lack of suitable

Substitution raw materials substitute materials

or containing PFCs to although SGPP is Variable

Reformulation materials that do committed to further not contain PFCs R&D

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Engineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02/11/2020 I Page 8 of 28

Cost Effectiveness Data13

Table 5- Cost Effectiveness of Control Equipment

Control Capital Annual Operating Total Annualized Control Cost Effectiveness Alternative Investment Cost14 Cost Efficiency" ($/lb)

RTO $3.0 MM $450 K $840 K 90% $46,700

Fiberbed mist $2.4 MM $480 K $792 K 90% $44,000

collection system

SGPP Proposed BACT: Regenerative Thermal Oxidizer

SGPP is proposing to install a regenerative thermal oxidizer as BACT that will be used to reduce emissions of PFCs from several existing sources at the facility (EU01-EU08, EU12, EU13, EUI5, EU16 and EU22-EU26). The process vent emission streams will be collected and tied into a header system that will deliver process exhaust from the facility to a centralized control system proposed for location to the rear of the site. By using this approach, SGPP would eliminate the process vent discharges currently located on the roof. A significant co-benefit of the RTO is its ability to reduce emissions of PF AS, regardless of their carbon chain length. Therefore, an RTO would be effective for the current PFCs that have AGQS, as well as those for which either AGQS or surface water quality standards (SWQS) are promulgated in the future.

Properly designed thermal oxidizers include the following:

1. A sufficiently high design temperature for the combustion chamber to ensure rapid and complete oxidation. 2. Adequate turbulence to obtain good mixing between combustion air, pollutants, and hot combustion products

from the burner. 3. Sufficient residence time at thermal oxidizer temperature for complete combustion.

With the correct operating parameters, most organic compounds can be oxidized. Since the process vent emission streams will contain VOCs, the resultant emissions from the destruction ofVOCs will be CO, and water. For the non-VOC component of the process vent emission streams (i.e. PFCs and other PFAS), complete destruction of fluorinated compounds will result in HF emissions as well.

SGPP states in the application that they are engaged with vendors to explore the use of a three-chamber design for the purpose of maximizing the efficiency of the unit by minimizing any short-circuiting of the RTO. When employing a twochamber system, there are two beds which alternate in service from "treatment" to "heat recovery" and then switch at a pre-determined frequency. During each chamber switch, there is a brief transition period where a small volume of untreated air may bypass the treatment zone and vent direct to the atmosphere. This is inherent to the two-chamber RTO design. In a three-chamber system, there is a third bed which serves to receive the small volume of untreated air that is then introduced to the treatment bed during the subsequent cycle. Therefore, there are no losses during a chamber transition and emission reduction is maximized.

SGPP is proposing to have the RTO vendor design the RTO with a combustion chamber temperature of 1600°F with a minimum pollutant residence time of0.75 seconds. According to the application, the design bid documents will also specify that the RTO be designed with the capability to operate at temperatures in excess of 1600°F and upwards of !800°F to ensure the desired level of destruction is achieved.

NHDES has reviewed literature and networked with state and federal agencies throughout the U.S. and has not identified the application of a RTO for PFC destruction from a fabric coating operation like SGPP. SGPP also states in Attachment C of their application that they did an investigation into potentially available control technologies for the BACT analysis and did not identify equivalent operations in their search. The closest comparison would be the thermal oxidizer with 4-stage scrubber system being installed at the Chemours facility in Fayetteville, NC. However, that facility is not a fabric coating operation but a manufacturer of products such as dispersions and the design of the thermal oxidizer in NC is

IJ

14

15

Specific information and basis of economic feasibility is provided in Attachment C of the application. Operating costs are based on 8, 760 hours/year of operation. Control efficiency used for estimating purposes only, given actual data regarding removal efficiencies for PFCs arc currently not well defined.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation En!!ineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 9 of 28

different than that proposed at SGPP. In addition to the differences between the processes at Chemours and SGPP, the regulatory requirements associated with each location are different.

The Chemours thermal oxidizer is required by permit and a Consent Order to be operational by December 31, 2019 with initial performance testing results required to be submitted to NC Department of Environmental Quality within 90 days of installation. The Chemours thermal oxidizer is designed to operate at 1800°F with a residence time of> 1.2 seconds. The performance test in NC will provide insight into what the minimum operating temperature will be necessary for the Chemours thermal oxidizer with its designed residence time in order to achieve the destruction efficiency of99.99% as mandated by the permit and Consent Order issued to Chemours.

Studies of potential sources ofPFAS in the atmosphere from waste incineration offluorotelomer-based polymers in two laboratory-scale studies16 17 and PTFE in a rotary kiln test facility" have indicated that operating at typical waste incineration conditions (approximately 1000°C or 1832°F for 2 seconds residence time) does not result in a detectable level of PFOA or a significant source of studied PFAS. These studies were for the incineration of solid materials. In addition, these operating conditions of time and temperature were set for the laboratory scale studies to evaluate typical waste incineration conditions and not to determine the minimum operating temperature and residence time for PFAS destruction. NHDES believes the laboratory-scale studies may have been the result of the 2005 Enforceable Consent Agreement for Laboratory-scale Incineration Testing of Fluoropolymers between EPA and the Fluoropolymer Manufacturers Group 19•

NHDES' Determination Pursuant to RSA 125-C: I 0-e

RSA 125-C: 10-e has a two-part requirement for sources that are subject to the regulation. First, BACT must be established pursuant to RSA 125-C: I 0-b, I( a). Second, the application of BACT cannot cause or contribute to or have the potential to cause or contribute to an exceedance of an AGQS or SWQS as a result of the deposition of the contaminant from the air. Therefore, the following outlines NHDES' determination for both parts of the regulation:

NHDES' BACT Determination

Based on the review of the limited information on incineration ofPFC compounds and in consultation with EPA, NHDES agrees that a three-chamber RTO would constitute the best available control technology for the control ofPFCs from the facility. The RTO parameters of residence time and turbulence will be inherent to the design of the RTO as proposed by the vendor that SGPP selects and the emission limitations and degree of emission reductions required by the permit. SGPP's proposed RTO operating temperatures of 1600- 1800°F are within the parameters suggested by the afore mentioned research. Therefore, NHDES has determined that the RTO shall be required to meet a minimum temperature of 1800°F with the ability to reduce that temperature if stack testing conducted in accordance with Env-A 800 and the permit indicates that the device can achieve the permitted performance requirements outlined below at a lower temperature.

!6

17

]9

I. The RTO is limited by permit condition to a minimum control efficiency of90%, by weight for each PFC. Stack testing using Modified Method 5 (MM5) has been conducted at SGPP in the past. The MM5 methodology and existing analytical standards for PFOA, PFOS, PFNA and PFHxS allow for the quantification of inlet and outlet emission rates and therefore, a control efficiency for the RTO can be calculated from stack test information for these four PFCs. However, the lower the inlet concentration of an individual PFC to the RTO, the more difficult it is to measure an accurate control efficiency for the RTO for that PFC. A possible surrogate for individual PFC control efficiency could be a total organic fluoride (TOF) inlet and outlet measurement since the amount of total PFAS loading is expected to be sufficient to the RTO for measuring an accurate destruction efficiency. However, since this stack testing methodology for TOF is still in the development stages, it is not a requirement in the

Taylor, P.H, Yamada, T., Stricbich, R.C, Graham, J.L., & Giraud, R.J. (2014). Investigation of waste incineration offluorotelomer-based polymers as a potential source of PFOA in the environment. Chemosphere II 0, 17-22. Yamada, T., Taylor, P.H., Buck, R.C., Kaiser, M.A. & Giraud, R.l (2005). Thermal degradation offluorotelomer treated articles and related materials. Chcmosphere 61,974-984. Aleksandrov, K., Gehrmann, H.J., Hauser, M., M3.tzing, H., Pigeon, D., Stapf, D. &Wexler, M. (2019). Waste incineration of polytetrafluoroethylcnc (PTfE) to evaluate potential formation of per- and poly-fluorinated alkyl substances (PFAS) in flue gas. Chcmosphere 226, 898-906. Final Enforceable Consent Agreement and Testing Consent Order for Four Formulated Composites ofFiuoropolymer Chemicals: Export Notification. 40 CFR Part 799 [OPPT-2003-0071].


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02/11/2020 I Page 10 of 28

permit at this time but an option for the future. [See Deposition Modeling (PFCs) later in the permit application review summary for the basis of the 90% efficiency limit.]

2. Given the possible issues associated with calculation of control efficiency as explained in #1 above, an alternative post-controlled emission limitation for PFOA, PFOS, PFNA and PFHxS was established based on the detection levels for PFAS observed during the three most recent stack tests conducted at SGPP. The samples collected during these stack tests were analyzed by two different labs and represent samples that were taken both with and without the use of an XAD resin. Typical detection levels of l.OE-12lb/dscfwere seen and given the proposed maximum air flow of 70,000 scfm for the proposed RTO, this equates to a post-controlled emission level of 4.0E-06 lb/hr for each PFC. The following equation was used to calculate this post-controlled emission limitation:

Post -controlled emission limit c::) = lxl0-12 (d!~f) • 70,000 c:;!n) • 60 (:~n) The permit allows for the facility to demonstrate compliance with either# 1 or #2 above, based on stack testing results. [See Additional Future Stack Testing Requirements later in the permit application review summary for a detailed explanation of methods and sampling locations of initial and periodic stack testing requirements.]

NHDES Cause or Contribute Determination [RSA 125-C: I 0-e]

To address the issue of"Cause or Contribute", the permit also contains limits on annual maximum allowable PFC emissions which were developed for each of the PFCs for which an AGQS currently exists. These limits are derived from the current method detection limits for the isotope dilution method for PFAS in groundwater, precipitation and infiltration rates for the Town of Merrimack, and the results of the air deposition modeling conducted by Barr and revised by NHDES (modeling memo) based on the maximum predicted deposition scenario. [See Deposition Modeling (PFCs) later in the permit application review summary for detailed explanation of how these emission limitations were developed.]

The maximum annual PFC emission limits are 0.075 lbs/yr PFOA, 0.048 lbs/yr PFOS, 0.024 lbs/yr PFNA, and 0.015 lbs/yr PFHxS.


Pursuant to Env-A 810, Air Pollution Control Equipment Monitoring Plan, an air pollution control monitoring plan was submitted with the application as Attachment G. Because the proposed control device is in the preliminary design phase, not all information was provided in the plan. Some of the items (model and serial number of control device) are not critical to the design and functionality of the control equipment. However, because some design and operating parameters of the proposed control device are yet to be determined, NHDES is requiring as a condition of the permit, a monthly update report of the Air Pollution Control Equipment Monitoring Plan which shall include the following information:

1. Manufacturer of Control Device: SGPP shall submit a status update on selection of the manufacturer of the air pollution control device.

2. Model and Serial Number of Control Device: SGPP shall submit information once model and serial numbers are known.

3. Description of Control Device and How It Operates in the Process: SGPP shall submit documentation from the manufacturer of the air pollution control device including schematics, documentation pertaining to the design and detailed description of the control device and how it will be operated.

4. The Capture Efficiency of the Device and Method of Determination: Attachment D of the application describes the assessment of tower capture efficiency prepared by Environmental Resources Management (ERM) based on information obtained by SGPP staff for the devices that will be tied into the RTO (EU01-EU08, EU12, EU 13, EU 15, EU 16, EU22-EU26). This assessment was conducted to ensure maximizing capture efficiency into the existing equipment to minimize or eliminate fugitive emissions. EUO l-EU05, EU I 5, EU 16, and EU24 were found to have sufficient capture. EU07 and EU08 are located in the same room which is operated as an enclosure with inward velocity of greater than 200 ftlmin. EU25 and EU26 have no openings in equipment and their inherent design provides for total capture. EU22 had sufficient inward air velocity and capture. The remaining devices required improvements to maximize capture as outlined below:

20


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02/11/2020 I Page II of28

a. Tower improvements were determined to be necessary for the MP (EUI3), MG (EUI2) and QX Towers (EU06) as well as the Chemsil Coater (EU23). Additionally, the MA and MB Towers required upgrades that were completed in 2018.

b. Tower improvements were scheduled for MP and MG Towers in 2019. c. QX Tower improvements are scheduled in conjunction with the control device connection. d. No date was given for improvements to the Chemsil Coater. e. SGPP shall conduct capture efficiency testing pursuant to Env-A 805 during stack testing. In addition,

SGPP shall submit a status update on tower improvements for maximizing PFC capture efficiency conducted to date and going forward until construction is complete.

f. The permit includes an annual inspection of the thermal oxidizer and the ductwork from each source (EUOI-EU08, EUI2, EUI3, EUI5, EU16, EU22-EU26) leading to the RTO. SGPP shall also submit a Total Enclosure Monitoring and Capture Efficiency Verification Plan (for each device, as applicable) so that fugitive emissions are minimized or eliminated.

5. The Control Efficiency of the Device and Method of Determination: Once the manufacturer of the RTO has been selected, SGPP shall submit documentation from the manufacturer of the air pollution control device regarding control efficiency guarantees and proposed methods of determination of the control efficiency of the device. In addition, SGPP has requested that the facility have the flexibility to use the control device for compliance with Env-A 1200, Volatile Organic Compounds (VOCs) Reasonably Available Control Technology (RACT). Env-A 1207.03(c) requires a minimum VOC control efficiency of90%. Therefore, additional VOC testing requirements outlined in Env-A 800 will be required to allow for this option.20

6. Operational Parameters of the Device, and Normal Ranges, and Range During Start-up or Shutdown Conditions: In the application, SGPP proposed a minimum combustion chamber temperature of 1600°F and maximum inlet flow rate of 70,000 scfm along with proposed start-up and shutdown procedures. However, as noted above, NHDES has determined that the minimum combustion chamber temperature shall be 1800°F unless stack testing demonstrates otherwise. The permit requires SGPP to operate the RTO at all times the coating towers or auxiliary equipment (EUOI-EU08, EUI2, EUI3, EUI5, EUI6 and EU22-EU26) are operating and in accordance with the start-up and shutdown conditions outlined in the monitoring plan. SGPP shall submit updated operational parameters of the device and normal ranges from the manufacturer of the air pollution control device.

7. Description of Data Recording or Recordkeeping, Parameter Setpoints and Alarms, and Operator Re.sponses to Malfunctions of the Control Device to Prevent Uncontrolled Emissions: The proposed operating parameter monitoring of at least once every 15 minutes for combustion chamber temperature and inlet flow rate that was submitted as part of the application is currently sufficient. SGPP shall submit updated information pertaining to data recording or recordkeeping, parameter setpoints and alarms, and operator responses to malfunctions from the manufacturer of the air pollution control device.

8. Manufacturer's Recommended Procedures for Operation: SGPP stated in the application that it intends to implement the operational recommendations ofthe selected RTO manufacturer to ensure the control device achieves the highest level of control possible. SGPP shall submit documentation from the manufacturer of the air pollution control device regarding recommended procedures for operation.

9. Manufacturer's Recommended Schedule for Service, Maintenance and Calibration of the Device:

a. SGPP intends to develop and implement a service, maintenance and calibration program based on the selected RTO manufacturer's recommendations. SGPP shall submit documentation from the manufacturer of the air pollution control device regarding recommended schedule for service, maintenance and calibration of the device.

b. In addition to the maintenance of the RTO, SGPP shall submit additional information pertaining to the maintenance of the process vent emission streams that will be collected and tied into a header system.

It should also be noted that the raw materials SGPP currently uses meet the VOC content limits ofEnv-A 1207. The inlet concentration of VOCs to the RTO will likely be low which leads to difficulty in measuring an accurate destruction efficiency for the RTO for VOCs.


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 330 II 00165 I Application#: I 18-0227 Date: 02111/2020 I Page 12 of28

This information shall include methods for keeping the vents clear of char material, including but not limited to insulation, cleaning ports, cleaning frequency and methodology and any proposed operation and maintenance of auxiliary equipment necessary to ensure the process vent emission streams remain clear of char material.

I 0. Other Operational Parameters Affecting the Ability of the Device to Control Emissions: As the design process begins, SGPP acknowledges that any parameters that are identified during the process will be included in subsequent versions of the monitoring plan and will be necessary to submit to NHDES.

a. SGPP shall submit documentation from the manufacturer of the RTO regarding any other operational parameters affecting the ability of the device to control emissions, as necessary.

b. SGPP conducted a wet-weather and source investigation sampling event in September 2018 on the stormwater system. As a result of the event, multiple work practices were put in place as outlined in both the December 20, 2018 roof cleaning SOP that SGPP submitted and the January 22, 2018 letter with supporting documentation regarding work practices SGPP implemented for roof inspections, cleanings and maintenance of stormwater systems.

c. During the November 28, 2018 meeting with SGPP, NHDES suggested further analysis of the roofing material to determine the level of residual PFAS that might be leaching off the roof and contributing to the PF AS levels in the storm water system. In the January 22, 2018 letter, SGPP was concerned about a number of technical challenges to sampling the roofing material, such as a lack of standard test methods and likely matrix interferences in the analysis of roofing material. SGPP also stated that "SGPP is currently evaluating the installation of air emissions controls that would mitigate potential PFAS emissions and eliminate the potential for char to be deposited on the rooftop. If the installation and operation of air emissions controls do not adequately address PFAS concentrations in rooftop stormwater, SGPP will consider further evaluations to characterize rooftop conditions such as pursuing unconventional analytical techniques to assess PF AS absorption by roofing materials and potential leachability."

d. NHDES sent a letter to SGPP on February 22, 2019 regarding the September 2018 Unvalidated WetWeather and Source Investigation Sampling Event Data Submittal. In the letter NHDES conveyed concern over the results of the roof drain sampling containing highly elevated levels of PFAS that are an order of magnitude (or more) greater than the 70 ng/L standard for PFOA and PFOS. NHDES went on to state that the cause of the high levels ofPFAS in the roof runoff may be due to accumulated dry deposition on the roof(including air emissions and char deposits), leaching ofPFAS that absorbed onto building materials from long-term air emissions, or some other source. The roof runoff containing elevated PFAS has the potential to contaminate groundwater via infiltration into the ground where water drips/flows off the roof onto the ground surface and where exfiltration from the stormwater system where the infrastructure is/was cracked or otherwise compromised.

e. SGPP states in the BACT application that control of the applicable process sources via a centralized control system "would eliminate process vent discharges currently located on the roof level and thereby reduce the potential for target compounds in roof storm water runoff."

f. If PFAS contaminates storm water (and in turn groundwater) by a process other than ongoing air deposition from the existing stacks, installation of air emission controls alone may not eliminate the source of PFAS in stonnwater from the roof of the facility.

g. As part of the implementation of the BACT requirements and to verifY SGPP's assertion that air pollution controls will mitigate the storm water issue, NHDES requires that SGPP conduct another round of storm water source sampling (e.g. all previous stonnwater sampling sites including the roof drains) and roof wipe analysis. This analysis and submittal of a final report shall be done within 6 months of the BACT controls becoming operational in order to ascertain if continued elevated PF AS compounds are found in the stormwater and to determine ifthere is an ongoing source ofPFAS (e.g. evaluation of the roofing material) other than from the stacks.

SGPP shall submit a final approvable Air Pollution Control Equipment Monitoring Plan to the department no later than 60 days after completion of construction and installation of the RTO.


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HF Scrubber

• See the May I and June 20, 2019 letters to SGPP regarding NHDES' concerns about the potential for HF emissions coming from the utilization of a RTO for the destruction of PFAS compounds.

• See EMISSION CALCULATIONS/EMISSION STACK TESTING RESULTS: Coating Towers- Total PFAS, PFOA, Total Fluoride and Hydrogen Fluoride Emission Rates for further HF calculations and emission rates.

• Based on the Env-A 1400 compliance demonstration for HF outlined in Dispersion Modeling (RTAPs) and Table 12 below, an HF scrubber has been determined to not be required to be installed at this time. However, NHDES remains concerned that the calculations of current PFAS emissions from the facility and potential HF emissions from the RTO are an underestimation as outlined in EMISSION CALCULATIONS/EMISSION STACK TESTING RESULTS: Coating Towers- Total PFAS, PFOA, Total Fluoride and Hydrogen Fluoride Emission Rates below.

• As stated in the May I, 2019 letter to SGPP, in order to ensure the expeditious installation of BACT controls, NHDES requested SGPP submit a pre-test protocol for the stack testing ofHF emissions from the proposed RTO. SGPP submitted the protocol as part of the May 30,2019 submittal to NHDES. A more thorough and detailed pre-test protocol will be required to be submitted pursuant to the draft permit and in accordance with Env-A 800.

• The draft permit includes a requirement that SGPP conduct stack testing for HF emissions from the RTO in accordance with Env-A 802, with NHDES staff present and in accordance with a division approved pre-test protocol. In addition, the draft permit requires SGPP update and submit an Env-A 1400 compliance demonstration based on final as-built RTO emission parameters and the results of the stack testing for HF. SGPP should proceed with the design of an HF scrubber as part of the RTO design process to ensure the facility is ready to implement the HF scrubber as expeditiously as possible, if needed.

Additional Future Stack Testing Requirements

The following stack testing requirements were discussed in previous sections of this summary:

I. Capture efficiency of the towers (EUOJ-EU08, EUI2, EU13, EUI5, EUJ 6, EU22-EU26) to minimize fugitive PFAS emissions pursuant to Env-A 805 (Method 204);

2. Pre- and post-RTO stack testing to determine the control efficiency of the RTO, post-control emission rates for PFOA, PFOS, PFNA and PFHxS, and to establish operating parameters for the RTO (Modified Method 5 and any NHDES approved alternatives);

3. Stack testing post-RTO for HF emissions for the Env-A 1400 compliance evaluation (Method 26A); and 4. Capture and control testing requirements for VOC RACT purposes (Method 204 and Method 25 or 25A) (EUO I-

EU08, EUI2, EUI3, EUI5-EUI7).

Additional initial and periodic stack testing requirements are included in the permit. Given that stack testing methodologies are currently being developed for PFAS, the permit allows the owner or operator or their stack testing representative flexibility in the stack testing approaches including proposing altematives to the stack testing methodologies through coordination with NHDES as part of the pre-test process.


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02111/2020 I Page 14 of 28

EMISSION CALCULATIONS/EMISSION STACK TESTING RESULTS

Coating Towers- Historical PFOA Emission Rates

• See the September 26, 2018 NHDES letter issued to SGPP for historical PFOA emissions and stack test results.

Estimated Historical PFOA Emissions lW-.J

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Coating Towers- Total PFAS, PFOA, Total Fluoride and Hydrogen Fluoride Emission Rates

• Stack testing was conducted at SGPP in April and May, 2018 by Barr with analysis conducted by SGS Laboratories. The testing was conducted on the MA and MS Tower exhausts as well as on the QX Tower. The testing on the QX Tower was simultaneously at the inlet and outlet of a pilot-scale control device to determine the control efficiency of the pilot-scale fiberbed mist collection system rented from Air Clear, LLC by SGPP forthe stack test. The inlet stream to the pilot-scale control device is considered indicative of the uncontrolled emissions from the QX Tower.

• During the same stack test in 2018, samples were sent to EPA Office of Research and Development (EPA ORO) for non-targeted analysis ofPFAS compounds. On October 4, 2018, NHDES received Report #4 which contained results of SUMMA canister samples. The analysis of the SUMMA canisters tentatively identified 12 PFAS compounds. On June 20, 2019, NHDES received Report #6 from EPA ORO which contained stack test results of front half filter, XAD resin trap and back half filter analysis conducted by EPA ORO. Across the three towers sampled, EPA ORO detected 190 PFAS compounds and tentatively identified 89 of them.

• On June 20, 2019, NHDES issued a letter to SGPP regarding the EPA ORD analytical results. In the letter, NHDES quantified the 89 PF AS compounds that were tentatively identified by EPA ORO in Report #6. The letter outlined why NHDES believes this is an underestimation of the current PFAS emissions from the facility. NHDES used the same methodology as the application to convert PFAS compounds to HF, but based the calculation on the estimated 89 PFAS compounds that were tentatively identified by EPA ORO.

• In the SGPP letter dated August I, 2019, SGPP's consultant, C.T. Male Associates questioned the validity of the PFAS emission calculations presented in the NHDES letter dated June 20,2019. In Table I of the submittal, C.T. Male recalculated the total fluoride emission rate using the current estimated fluoride emission rate of 0.0718 lb/hr and the I 0 PFAS compounds contribution at 0.0168 lb/hr. The PF AS compound contribution reflects the

2l

22

23

25

26

27

28

29

70


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totallb/hr PFAS emissions reported in Attachment B.7 of the application at an assumed 70% fluoride contribution based on the 4 highest detected PFAS ranged from 62- 68% from the 2018 stack test report. The total fluoride emission rate of 0.0886 lb/hr is the value Barr used in the air dispersion modeling submitted August 1, 2019.

• Table 6 below contains comparisons of the SGPP application submittal and NHDES' calculations for hourly, actual and potential emissions of total PFAS, PFOA, total fluorides and hydrogen fluoride based on the various calculation methodologies outlined above and in the footnotes.

Table 6- Comparison of Estimated Emissions"

SGPP March 26, 2019 NHDES June 20, 2019 SGPP August 1, 2019 Revised

Pollutant Application Emission Rates Calculated Emission Rates" Emission Rates"

Hourly Actual Potential24 Hourly Actual Potential Hourly Actual Potential

(lb/hr) (lbs/yr) (lb/hr) (lbs/yr) (lb/hr) (lbs/yr)

Total PFAS 0.024 78.0525 210 0.27 864 2,326 N/A N/A N/A

PFOA (as Ammonium 2.28E-04 0.7426 2.0 N/A N/A N/A N/A N/A N/A Pertluorooctanoate)

Current27 0.0718 235 629 0.0718 235 629 0.0718 N/A 629

Total Current 0.047628 N/A 417 N/A N/A N/A N/A N/A NIA

Fluorides Post RTO 0.0158 N/A 138 0.17 N/A 1,472 0.0168 N/A 147 (F)

TOTAL 0.0635 N/A 555 0.24 N/A 2,101 0.0886 N/A 776

F"

Hydrogen Current 0.05 N/A 441 0.076 N/A 664 N/A N/A NIA

Fluoride Post RTO 0.017 N/A 146 0.18 576 1,550 N/A N/A N/A (HF)

TOTAL30 0.0670 N/A 587 0.26 N/A 2,278 N/A N/A N/A

N/A in Table 6 means either the information wasn't submitted by SGPP or wasn't calculated by NHDES for the purpose of this table. See NHDES letter dated June 20, 2019 for basis of calculations for PFAS and HF from PFAS contribution through RTO. NHDES also assumed current total fluorides consistent with the emissions reported by Barr in the 2018 Barr stack test report. The June 20, 2019 NHDES letter presented HF emission rates, but after review of Env-A 1400 it was determined that the ambient air limits are established for hydrogen fluoride as fluoride and therefore Table 6 presents both total fluoride and HF emission rates. See C.T. Male Associates letter dated August I, 2019 where revised hydrogen fluoride as F emission rates were submitted for use in air dispersion modeling. Potential annual emissions in Table 6 above were calculated by NHDES and are based on all the devices operating 24 hours/day and 365 days/yr. Attachment 8.6. of the application contains lb/hr and lb/yr estimates of the I 0 PF AS compounds along with the assumptions and methodology of the emission calculations and are based on the September 2018 Barr stack test report submitted by SGPP. Annual actual emissions are calculated from short-term emission rates based on average operating hours per tower over the period 20 I2 - 2017. Where the application didn't estimate emissions for Table 6, NHDES calculated them and reported them in italics. PFOA emissions were repo11ed by Barr in the 20I8 Barr stack test report which NHDES approved in a letter dated May I, 2019. During the 2018 stack test, Barr utilized EPA Method 138 to determine current fluoride emissions from the MS Tower. Attachment B.6. of the application contains lb/hr and Jb/yr estimates of the total fluoride emissions as reported in the September 2018 Barr stack test report submitted by SGPP. These calculations utilized fluoride emission stack test result from the MS Tower (lb/dscf) in conjunction with each tower's stack flow rates. Attachment B. 7. of the application contains a different methodology to calculate fluoride emissions. In this case, the fluoride emission stack test result from the MS Tower in lb/hr was applied to all towers at SGPP based on the maximum processing rate of each tower (ft2/hr). Changes to the coating tower parameters in August, 2019 had an effect on these calculations and therefore the values in Table 6 should be 0.453 lb/hr and 396lbs/yr based on the new coating tower parameters submitted by C.T. Male on August 29,2019. Total F would then change accordingly. However, this had no impact on the rest of the analysis since this method was less conservative than the method outlined in Footnote 28. SGPP March, 2019 application used the lower of the two methods for calculating current fluoride emissions plus the contribution of 10 PFAS compounds through the RTO to calculate total fluoride emissions. The August I, 2019 submittal from C.T. Male used the higher of the two methods for calculating current fluoride emissions and therefore the changes made in the August 29,2019 submittal did not affect this analysis. Installation and operation of an RTO for PFAS destruction will result in additional HF emissions. Therefore, Attachment 8.7. also includes Hr


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Coating Towers- Ammonia (NHJ) Emissions CRTAP)

• During the 2018 stack test, Barr utilized EPA Method CTM 027 to determine ammonia emissions from the MS Tower. In the same manner that the application contained two approaches to calculating facility-wide fluoride emissions as outlined above, the application also used the same two approaches to calculate facility-wide ammonia emissions. The first approach results in a predicted facility-wide NH3 emission rate of 0.0825 lb/hr or 270 lbs/yr (based on average hours of operation) and a potential annual emission level of 723 lbs/yr if all the devices operated 24 hrs/day and 365 days/yr. The second approach results in a predicted facility-wide NH3

emission rate of0.054lb/hr or 474 lbs/yr for all towers combined31

Coating Towers- Additional RTAPs/HAPs

3 I

32

• Attachment B.S. of the application contains the summary of additional RTAP/HAP emissions including the assumptions and calculations for estimating these emissions from the coating towers beyond those RT APs/HAPs already outlined above. Actual annual emissions are calculated based on actual annual raw materials used (20 12-20 18), maximum individual RTAP/HAP concentration listed in the material safety data sheets for each raw material and assumes I 00% gets released to the atmosphere. NHDES concurs with this methodology for calculating the actual annual emissions of the remaining RTAPs/HAPs.

• RSA 125-1, Air Toxic Control Act states that "No person shall operate any device or process at a stationary source that emits a regulated toxic air pollutant without a temporary or operating permit issued by the department in accordance with this chapter or RSA 125-C, provided, however, that no permit or permit application shall be required for any device or process at a stationary source exempted under RSA 125-1:3, Ill, or whose uncontrolled emissions of regulated toxic air pollutants do not exceed ambient air limits at or beyond the compliance boundary ... "

• Uncontrolled emissions are defined as "any emission of a regulated toxic air pollutant from a device or process at a stationary source that is not subject to treatment or removal by pollution control equipment prior to being emitted to the ambient air, or is emitted to the ambient air in amounts which have not been limited by conditions in an enforceable permit or document." The assumption is that if uncontrolled emissions (i.e. no limit on hours of operation, no assumptions for bottlenecks, no accounting for destruction efficiency of a control device etc.) do not exceed the AALs, then no permit containing operating limits or installation of control equipment would be necessary to comply with the law.

• In Attachment B.8 of the application and later revised in the August 29, 2019 submittal, SGPP calculated potential RTAP emissions (i.e. uncontrolled emissions) to use in the Env-A 1400, Regulated Toxic Air Pollutants compliance demonstration by applying an annual scaling factor to actual RTAP emissions. However, this methodology employed an 80% bottleneck factor due to product changes and equipment limitations.

• On September 30,2019, SGPP submitted a revised Env-A 1400 demonstration without the inclusion of the bottleneck factor. Table 7 below presents the highest actual and potential emission rates of each RTAP during the 2012- 2018 timeframe without the bottleneck factored into the calculations.

• In addition, the emission rates detailed in the text above for PFOA, HF and NH1 are included in the table below. Since PFOA (as Ammonium Perfluorooctanoate), HF and NH, are RTAPs, they must be evaluated against Env-A 1400, Regulated Toxic Air Pollutants standards.32

• See REVIEW OF REGULATIONS: State Regulations later in the permit application review summary for the Env-A 1400, RTAP compliance demonstration.

emission calculations based on accounting for each fluorine atom from the PFAS converting to HF. Changes to the coating tower parameters in August, 2019 had an effect on these calculations as well and are reflected in the information submitted by C.T. Male on August 29, 2019. Changes to the coating tower parameters in August, 201 9 had an ctTcct on these calculations and therefore the values for the second approach should be 0.0514 lb/hr and 451 lbs/yr based on the new coating tower parameters submitted by C.T. Male on August 29, 2019. This did not change the Env-A 1400 compliance evaluation since the second approach was less conservative than the first approach. Sec REVIEW OF REGULATIONS: State Regulations later in the permit application review summary for Env-A 1400 evaluation (Table 14).


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02/11/2020 I Page 17 of28

Table 7- Coating Towers- RTAP and HAP Emissions33

Highest Actual Emission Rate Potential Emission Rate RTAP/HAP CAS# (2012- 2018)

(lbs/yr) (lbs/yr) (lb/hr) 34

Ethylene Glycol 107-21-1 3,733 8,208 0.937 Toluene 108-88-3 1,329 2,922 0.334

Isopropanol 67-63-0 132.9 292.2 0.0334 Ethanol 64-17-5 3.I8 7.72 0.000881

I, 4-Dioxane 123-91-1 6.68 14.69 0.00168 Benzene 71-43-2 0.032 0.096 0.000011

Polyethylene Glycol 25322-68-3 724.6 1,593 0.182 Tetrafluoroethylene 116-14-3 I ,153 2,642 0.302

Methanol 67-56-1 45.37 130.39 0.0149 Methyl Ethyl Ketone 78-93-3 49.60 142.5 O.OI63

n-Methyl-2-pyrrolidone 872-50-4 43.30 124.43 0.0142 Hexane I I 0-54-3 2.65 7.62 0.000869

PFOA (as Ammonium Perfluorooctanoate) 3825-26-1 N/A 2.0 2.28E-04 Hydrogen Fluoride35 7664-39-3 N/A 2,278 0.26

Ammonia 7664-41-7 270 723 0.0825

Antenna Cover Fabrication Area- RTAPs/HAPs

33

)4

JS

36

• Attachment 8.2. of the application contains the assumptions used in the calculations and a summary of RT AP and HAPs emissions from the antenna cover fabrication area. Actual emissions are calculated based on actual raw materials used (2012- 2018), maximum individual RTAP/HAP concentration listed in the material safety data sheets for each raw material and assumes 100% gets released to the atmosphere36 NHDES concurs with this methodology for calculating the actual annual RT AP/HAP emissions from the antenna cover fabrication area.

• Attachment B.2. of the application lists actual RTAP/HAP emissions (lbs/yr) for each year from 2012-2018. Table 8 below presents the highest actual emission of each RTAP/HAP during that six-year period.

• Attachment B.5 of the application lists actual and potential total HAP emissions from each year with potential emissions calculated by scaling up from typical operations of one 8-hr shift/day and 5 days/week to 24 hr/day and 7 days/week. NHDES concurs with this methodology for calculating the potential annual RTAP/HAP emissions from the antenna cover fabrication area. Table 8 below uses the same scaling methodology to calculate potential emissions from the highest actual emission rates listed.

All compounds listed in Tables 7 and 8 are RTAPs. However, HAPs are denoted in italics. Hourly RTAP/HAP emissions (lb/hr) were calculated from annual RTAP/HAP emissions (lb/yr) using 8,760 hours/yr conversion except as noted for hydrogen fluoride and ammonia in the text on the previous pages. HF emission rates represent total I-IF (current HF +contribution from PF AS converting to HF from RTO). On September 30,2019, C. T. Male submitted a revised Attachment B.2. regarding the conditions under which methylene diphenyl isocyanate (MDI, CAS # 10 1-68-8) would become emitted from a process. Previously, SGPP had assumed that 100% of the MDI contained within the product was emitted in the antenna cover fabrication area. However, given that this compound is applied at room temperature and not at temperatures greater than l00°F per the literature and manufacturer, it is not anticipated that MDI is liberated from the material in use at SGPP.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint -Gobain Performance Plastics Corporation Engineer: Catherine Beahm

Location: 70 I Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02111/2020 I Page 18 of28

Table 8- Antenna Cover Fabrication Area - RT AP and HAP Emissions

Highest Actual Emission Rate Potential Emission Rate

RTAP/HAP CAS# . (2012 - 2018) .

(lbs/yr) (lbs/yr)'' (lb/hr)

Ethyl Acetate 141-78-6 12.48 52.4 0.04 Toluene 108-88-3 1,021.68 4,292.8 3.44 Xylene 1330-20-7 1.56 6.6 0.005

Methyl Ethyl Ketone 78-93-3 247.20 1,038.7 0.83 Hexane 110-54-3 31.54 132.5 0.11

Ethyl Benzene 100-41-4 0.31 1.3 0.001 Benzene 71-43-2 0.03 0.1 8.0E-05

Facility-wide Hazardous Air Pollutants (HAPs)

The facility has been limited by permit conditions since the issuance of PO-BP-2607 and PO-BP-2697 on February 6, 1996 to synthetic minor status for hazardous air pollutants ( < I 0 tons of any one HAP and <25 tons of any combination of HAPs during any consecutive 12-month period). Based on current products used, the facility-wide potential to emit HAPs in total is 7.9 tpy with the highest contribution coming from toluene (3.3 tpy), ethylene glycol (3.3 tpy), and hydrogen fluoride ( 1.1 tpy based on future projected emissions after installation and operation of RTO).

Facilit)'-wide Volatile Omanic Comoounds CVOCsl

37

Table 9- Historical Actual VOC Emissions

Year VOC Emissions (tpy)

1994 0.8 1995 0.8 1996 1.5 1997 3.2 1998 2.0 1999 2.0 2000 1.8 2001 0.6 2002 14.0 2003 13.4 2004 15.0 2005 37.3 2006 38.5 2007 27.5 2008 30.5 2009 21.1 2010 32.1 2011 30.5 2012 29.4 2013 21.3 2014 22.3 2015 21.7 2016 32.2 2017 9.4 2018 10.8

so

10

0

Historical Actual Facility-Wide VOC Emissions

Facility-wide Permit limit SO tpy VOCs

Device-specific Permit Limit

10 tpy VOCs

l'lJ4 1'1% 1')<)8 )0)0 )00( 200;1 7006 2008 2010 201) 2014 2016 201.8

Year

Actual facility-wide VOC emissions are calculated based on a c

i f: d I

r c

ombination of actual formulation usage, VOC content listed in material safety data sheets and EPA Method 24 analysis of the raw materials for the coating towers and antenna fabrication area. Starting n 2016 when EU20 and EU21 were installed and permitted, the actual acility-wide VOC emissions also included contribution from these evices. However, they are rarely used and therefore, their contribution s negligible. Going forward it will be clearer in the permit that the

VOC emissions from the process equipment bumers will also be equired to be included in annual emission calculations to demonstrate ompliance with the facility-wide emission limits for VOCs.

Hourly RTAP/HAP emissions (lb/hr) were calculated from annual RTAP/1-IAP emissions (lb/yr) using antenna cover fabrication area operating 8 hrs/shift; 1 shift/day; 3 days/week; 52 weeks/yr ( 1,248 hr/yr) conversion.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Ene:ineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 19 of 28

Prior to issuance of PO-BP-2607 and PO-BP-2697 in 1996, the permitted devices had device-specific annual VOC emission limits. Beginning in 1996, the facility was limited by permit conditions to synthetic minor status for VOCs (<50 tons during any consecutive 12-month period) and was been limited by process to I 0 tpy ofVOCs for each individual device. The permit limit of I 0 tpy ofVOCs for each individual device was removed when permit FP-T-0075 was issued in 200 I for installation of 9 additional coating towers, thus subjecting the coatings to VOC RACT limitations. However, the facility-wide VOC emission limit of 50 tpy remained.

Criteria Pollutants from Combustion Units

Attachment B.3. of the March 26,2019 application contains the summary of facility-wide and individual device criteria pollutant emissions as well as the emission factors and calculations. However, NHDES identified areas that needed correction as noted in the August 23, 2019 email to SGPP. In addition, SGPP submitted revised maximum heat input values for the process equipment on August 20, 2019. Updated emission calculations were submitted by C.T. Male on August 29, 2019, reviewed and corrected by NHDES and are included as Attachment I of this document and summarized in Table I 0 below.

Table 10- Facility-wide Emission Summary (Potential to Emit)

NOx so, . co PM voc Combustion Sources

(lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy)

Process Equipment 6.46 28.3 0.039 0.17 5.43 23.77 0.49 2.15 0.36 1.56 Burners38

RTO Burner 0.97 4.25 0.0058 0.026 0.82 3.57 0.07 0.32 0.05 0.23

Clarke Fire Pump (EU20) 1.13 0.28 1.8E-03 4.5E-04 1.41 0.35 0.085 0.02 1.13 0.28

Kohler Emergency 0.51 0.13 0.0007 1.7E-04 0.55 0.14 0.04 0.01 0.51 0.13 Generator (EU21)

#2 Fuel Oil-fired Boiler 0.22 0.98 0.0024 0.01 0.056 0.24 0.022 0.10 0.0038 0.017

NOx so, co PM voc Process Sources

(lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy)

Process Equipment39 ... 47.7

Facility-wide Annual PTE 33.9 0.21 28.1 2.6 . 49.9

Title V Threshold 50 100 . 100 100 50

DEPOSITION MODELING (PFCs)

38

39

• Historical air deposition modeling was conducted by NHDES and Barr as part of the initial PFAS investigation.

• On May 30, 2019, SGPP submitted an air deposition modeling report in accordance with the protocol submitted in Application# 18-0227. The purpose of the air deposition model was to address the "Cause or Contribute" requirement ofNH Statute RSA 125-C: 1 0-e: Requirements for Air Emissions of Peljluorinated Compounds Impacting Soil and Water.

• NHDES reviewed the May 30,2019 Barr modeling and summarized the conclusions in a modeling memo dated August 1, 2019. The NHDES modeling memo includes both Method I and Method 2, maximum and average unit impact rates for the reasonably likely design and the maximum predicted deposition scenarios modeled by Barr. The maximum predicted deposition scenario using Method 2 predicts the worst case deposition potential and was used in the following analysis. This is a very conservative approach to predicting potential future, post-control, deposition rates given the uncertainty of the inputs to and the methodology for deposition modeling, the use of the

EUOI-EU06, EUI2, EUI3, EUI5, EUI6, EU22, EU24 & EU26 EUOI-EU08, EUI2, EUI3, EU15-EU17, EU22-EU26

40

41

42

43


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02111/2020 I Page 20 of28

worst case exhaust parameters proposed by SGPP, and the evaluation of the impacts for an entire geographical area based only on the highest predicted deposition rate for one location. This worse case unit impact rate can be used to calculated maximum predicted deposition rates for various PFCs using the following formula:

Maximum Deposition Rate ((f.lgfmAZ )fyr) =Emission Rate (~) * 0.386 ((gfmAZ )fyr per gjs) * 1,000,000 (11:)

• The Barr analysis (as summarized in Table 4 of the NHDES modeling memo) determined annual deposition rates based on annual PFC emission rates for the four PFCs that have a current AGQS (PFOA, PFOS, PFNA, PFHxS). The emission rates were calculated using the average annual operating hours of the coating towers from 2012 -2017. Operating hours during that time period were consistent from year to year and reflect the facility's inability to operate the coating towers 24 hrs/day and 356 days/yr.

• Based on annual total precipitation in the Merrimack area of 46 inches/year,'0 NHDES estimated that 21 inches/year (0.53 m/yr) infiltrates the ground in each m2 area. The maximum deposition rate per year can be used in conjunction with this precipitation infiltration rate per year to conservatively calculate the maximum concentration of each compound which is expected to infiltrate to groundwater using the following formula:

(119 ) Maximum Deposition Rate ((f.lgfmAZ )fyr)

Maximum Concentration of PFC Infiltrating to GW 3 or ppt = m m 0.53 (-)

yr

Table 11 - PFC Maximum Predicted Deposition Rate Analysis Post RTO Installation

Controlled Modeled Modeled Maximum Maximum Method Emission Emission Annualized Annualized

I · Deposition Concentration of . Detection PFC Rate Rate Emission Emission Rate Rate42 PFC Infiltrating Limit for Lab

(lb/yr) (lb/yr)41 Rate (g/s) (Method 2) to Groumlwater · Analysis"

(lb/hr) (!Jg/m1/yr) (ppt) (ppt)

PFOA 0.74 0.074 8.45E-06 1.06E-06 0.411 0.775 0.79

PFNA 0.19 0.019 2. 17E-06 2.73E-07 0.105 0.198 0.25

PFHxS 0.041 0.0041 4.68E-07 5.90E-08 0.0228 0.043 0.16

PFOS 0.045 0.0045 5.14E-07 6.47E-08 0.025 0.047 0.50

• In the May 30, 2019 SGPP air deposition modeling report, Barr referenced the 2018 Barr modeling report in which historical air emissions from SGPP were modeled to predict groundwater impacts from air deposition modeling results. Barr states that based on the methodology presented in that report, the values of maximum deposition rate of each compound listed in Table II above would not be likely to result in an exceedance of a current AGQS or MCL.

• Based on the proposed stack parameters and the 90% destruction efficiency of the proposed RTO, the application of the proposed RTO as BACT is not predicted to result in emission of any air contaminant subject to RSA 125-C: I 0-e to cause or contribute to an exceedance of an AGQS.

• In order to ensure that the maximum concentration of each PFC infiltrating to groundwater remains less than the current maximum detection limit for lab analysis, the maximum annual emission rate for each PFC shall be limited based on the following equation:

h ttps:/ /www. bestp laces. net/climate/city/new ham psh i rc/ mcrri mack For the purpose of the air deposition modeling conducted by Barr, the RTO was assumed to destroy 90% of all PF AS. Maximum Predicted Deposition Scenario (Scenario E: Stack height= 45ft; Stack diameter= 6 fi; Exhaust temperature= 250°F; Exhaust flow= 53,585 ACFM). The method detection limit (MDL) listed in Table 11 is for the isotope dilution method. Labs using Method 537 will likely have higher detection limits.


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(lbs) J19 IR * 60 (,~;;~) * 60 ('~~n) * 8760 (~:)

Maximum Annual Controlled Emission Limit yr =MDL (ppt or m') * --------,11-;:-------,--,~'-'--1,000,000 ( :) * u lR * 454 (&) Where:

MDL Method Detection Limit for water (ppt) for each PFC [See Table II]

JR Annual infiltration rate of precipitation (m/yr) [0.53 m/yr for Merrimack]

UIR Worse case unit impact rate from the deposition modeling (g/m2/yr per I g/s) [0.386 (g/m2/yr per g/s) from deposition modeling conducted to date]

The maximum annual controlled PFC emission limits are 0.075 lbs/yr PFOA, 0.048 lbs/yr PFOS, 0.024lbs/yr PFNA, and 0.015 lbs/yr PFHxS.

DISPERSION MODELING (RTAPs)

44

• In addition to air deposition modeling, air dispersion modeling was required for HF emissions from the proposed RTO. The purpose of the air dispersion model was to address the requirements ofNH Statute RSA 125-C: I 0-e: Requirements for Air Emissions of Perjluorinated Compounds Impacting Soil and Water. Specifically, the statute states in part that "In no event shall application of best available control technology result in emission of any air contaminant that would exceed the emissions allowed by any applicable standard under RSA 125-C or RSA 125-l or rules adopted pursuant to either chapter." Env-A 1400, Regulated Toxic Air Pollutants is adopted pursuant to RSA 125-1 and sets ambient air limits for inhalation exposure for specific RTAPs.

• There were two air dispersion models conducted for hydrogen fluoride as F for Env-A 1400. NHDES' was summarized in the August I, 2019 modeling memo. Barr's air dispersion model was summarized in the August I, 2019letter from C.T. Male.

• NHDES modeled emissions of HF from the proposed RTO at a rate of0.228 lb/hr. This emission rate was later revised to 0.24 lb/hr (as described in Table 6) based on the addition of HF emissions currently being emitted and after review ofEnv-A 1400 where it was determined that the ambient air limits are established for hydrogen fluoride as F.

• The overall results of the NHDES air dispersion modeling is outlined in Table 12. Because there will be only one emission point after the proposed RTO is installed, the maximum predicted impact rate (!!g/m3) for any RTAP can be calculated from the individual RTAP emission rates (daily and annual) with the following formulas:

Maximum predicted RT AP impact (!!g/m3) = RT AP emission rate (lb/hr) x maximum predicted unitized impact (!!g/m3 per lb/hr)

Where:

RTAP

Maximum predicted unitized 24-hr impact= 5.1754 !!g/m3 per lb/hr Maximum predicted unitized annual impact= 0.6579 !!g/m3 per lb/hr

Table 12- Env-A 1400 RTAP Maximum Predicted Concentration Analysis

Maximum Predicted Ambient Air Limits

CAS# Emission Impact (!lg/m3) (llg/m3)

Rate (lblbr) Annual 24-hr Annual 24-br

Hydrogen Fluoride (as F) 7664-39-3 0.24 0.16 1.24 0.98 1.5

.

Complies witlt AAL?

Annual 24-hr

Yes Yes44

Maximum predicted 24-hr impact is 83% of 24-hr AAL. As noted in the June 20, 2019 NHDES letter to SGPP regarding the EPA ORO analytical results, NHDES believes the quantification of the 89 PFAS compounds that were tentatively identified by EPA ORD in Report #6 is an underestimation of the current PFAS emissions from the facility and by default, an underestimation of the potential HF (as F) emissions from the proposed R TO.


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02111/2020 I Page 22 of28

• Barr modeled emissions ofHF from the proposed RTO at a rate of0.0886 lb/hr (See EMISSION CALCULATIONS/EMISSION STACK TESTING RESULTS section and Table 6). NHDES is in the process of reviewing the August I, 2019 Barr modeling. However, the Barr model does not affect the Env-A 1400 compliance determination.

• Based on the NHDES emission rate for hydrogen fluoride (as F) as estimated and the air dispersion modeling conducted by NHDES, the maximum predicted annual and short-term impacts from the emission rate ofHF (as F) complies with the Env-A 1400 AALs as shown in Table 12. See POLLUTION CONTROL EQUIPMENT: HF Scrubber section above for further discussion on HF emissions, Env-A 1400 compliance and future stack testing requirements.

DISPERSION MODELING (Criteria Pollutants)

No modeling for criteria pollutants is required at this time, because the devices which emit criteria pollutants are below the permitting thresholds of Env-A 607.0 I. In addition, since facility-wide potential emissions of criteria pollutants are below the thresholds listed in Env-A 606.02(c)(5), the facility a true minor source for CO, NOx, SO, and PMJO. Therefore, the facility would not need to be included in any interactive modeling for the surrounding area.

COMPLIANCE STATUS

Emission Testing

Historical emission stack testing conducted at the facility has primarily been voluntary or informational other than the required stack test in 2007 as a result of the Administrative Order by Consent ARD 06-006. The AOC required stack testing to be conducted by SGPP on or before April 30, 2007 and test report submitted to NHDES on or before July 31, 2007 for use in determining compliance with Env-A 1400 AALs for ammonium perfluorooctanoate (CAS #3825-26-1 ). The stack test was conducted April26, 2007, the report was received by NHDES on July 30, 2007. SGPP submitted a letter to NHDES on July 30, 2007 indicating that air dispersion modeling results predicted a 24-hr impact of 0.021 11g/m3

compared to the AAL of 0.050 11g/m3 based on average 2007 processing day rates. Heavier processing days were also evaluated and the results were still below the NHDES RTAP 24-hr and annual AALs. NHDES issued a Notice of Compliance for AOC ARD 06-006 on October 31,2007.

Other previous stack tests have been conducted at the facility on the following dates for the following towers:

Table 13- Historical StackTesting Events

Stack Test# Test Date Device(s) Test Description Documents

16-0038 May 4, 2016 MA Tower PFOA Testing ReQort dated Ju1x 2016

16-0075 August 10-11 and MA Tower PFOA Method MM5 ReQort dated December 2016 October 5, 2016

18-0040 April 26 - May 2, 2018 MA, MSand PFOA Method MM5 MA Tower ReQort dated SeQtember 20 18 and 18-0041 QX Towers PFOA Method MM5 MS Tower revised Max 2019 18-0042 PFOA Method MM5 QX Tower

Inspections

The last Full Compliance Evaluation conducted by NHDES, Air Resources Division at the facility was on April I, 2016. Issues were identified by NHDES and noted below. SGPP responded in a letter dated May 27,2016 and the responses are also noted below.

I. I.ssue noted by NHDES: Env-A 1400 compliance demonstration used de minimis and adjusted in-stack concentration methods for the antenna cover fabrication area which are not valid approaches based on the design of the exhausts (horizontal).

SGPP response: A revised Env-A 1400 compliance demonstration using the in-stack concentration method was submitted.


Location: 70 I Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 23 of28

NHDES conclusion: The revised Env-A 1400 compliance demonstration submitted by SGPP on May 27, 2016 demonstrated compliance with Env-A 1400 for the antenna cover fabrication area using the in-stack concentration method for all RTAPs except methyl diphenyl isocyanate (MDI, CAS #101-68-8). On September 30,2019, C.T. Male submitted information on MDI emissions (See footnote 36) and an air dispersion modeling analysis of remaining RTAP emissions from the antenna cover fabrication area. Since there are RTAPs that overlap between EU 17 and the remainder of the devices that will be routed to the RTO, NHDES is in the process of reviewing the air dispersion model using the potential RTAP emission rates listed in Tables 7 and 8 for the entire facility. At this time, it is not anticipated that the review will result in the need for additional permit conditions.

2. Issue noted by NHDES: SGPP used coatings with VOC content in excess of the Env-A 1200, VOC RACT limit applicable pre-20 16 (2.9 lbs VOC/gallon of coating as applied excluding water and exempt compounds) for the facility. The facility began using a daily bubbling method approach in May, 2015 to demonstrate compliance with VOC RACT after State Permit to Operate SP-0072 was issued with bubbling calculations included. However, SGPP did not have records demonstrating compliance pre-May, 2015. The same issue was identified in the previous inspection report covering 2008 -May 1, 2015.

SGPP response: Prior to using the bubbling approach, all coatings used at SGPP were evaluated using a two-step process- VOC content from the MSDS and further analysis using Method 24 testing. Only one coating used during the relevant time period did not meet the VOC RACT limit based on step one (data from the MSDS) but later was determined to be below the VOC RACT limit based on step two (Method 24 testing).

NHDES conclusion: Issue has been resolved.

3. Issue noted by NHDES: SGPP was not keeping records of the reason the emergency engine and fire pump had been operated since installation of the emission units in November 2015. A requirement of the permit is to keep track of hours of operation for emergency situations and for maintenance and testing situations as two separate records.

SGPP response: SGPP created a log to record these hours as a result of the inspection.

NHDES conclusion: Issue has been resolved.

4. Issue noted by NHDES: Previous Env-A 1400 compliance demonstrations for the coating towers assumed operation of stack dilution fans. However, a malfunction with the MS Tower fan resulted in a one-month period of time when the fan was not operational. NHDES requested SGPP conduct an RTAP evaluation for that time period.

SGPP response: SGPP submitted an Env-A I400 compliance demonstration for the RTAPs emitted during the malfunction period. The Env-A 1400 compliance demonstration used both de minimis and adjusted in-stack concentration methods but since some RT APs are common between the coating towers and the antenna cover fabrication area, these methods are not completely correct for this situation. Only the in-stack concentration method or air dispersion modeling reflecting emissions of overlapping RTAPs from both processes is allowed.

NHDES conclusion: Issue needs further evaluation.

Reports

In the past 5 years, SGPP as submitted NOx and VOC Emission Statements Reports and Annual Emission Reports on time for all years but 2017 (2 days late). The NSPS reporting requirements in Table 5, Item 4 of the current permit have not been triggered to date. Due to past opacity issues, NHDES requested and the facility submitted an Opacity Corrective Action Plan (August 18, 2016 with revisions November 8, 20 16).

Fees

The facility is up-to-date with emission based fees.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-022 7

REVIEW OF REGULATIONS & STATUTE

NH Statute

En~?ineer:

Date:

Catherine Beahm

02/11/2020 I Page 24 of28

RSA 125-C: 1 0-e Requirements for Air Emissions of Perfluorinated Compounds Impacting Soil and Water- Applicable (EUO 1-EUOS, EU 12, EU 13, EU 15, EU 16 and EU22-EU26)- A device that emits to the air any PFCs or precursors that have caused or contributed to an exceedance of an ambient groundwater quality standard or surface water quality standard as a result of the deposition of any such PFCs or precursors from the air, shall be subject to the determination and application of best available control technology.

State Regulations

Env-A 100- Organizational Rules

I 01.671 -Applicable (EU20 & EU21)- Definition of emergency generator. 1302.17- Applicable (EU20 & EU21)- Definition of emergency as it relates to emergency generator definition.

Env-A 600- Statewide Permit System

604.02- Applicable (EUOI-EUOS, EU 12, EU 13, EU 15-EUI7 and EU20-EU22)- The facility is synthetic minor for VOCs and HAPs. 606.02(a)(4)- Applicable (EUOI-EUOS, EUI2, EU 13, EUI5-EUI7 and EU22)- The facility is using air dispersion modeling as the compliance demonstration method specified in Env-A 1405.02. 606.02(b)- Applicable (EUOI-EUOS, EUI2, EUI3, EUI5-EUI6 and EU22-EU26)- The facility is making modifications to the exhaust parameters. 607.0 I (a)- NOT Applicable- Boiler is< 10 MMBtu/hr com busting #2 fuel oil; burners on towers and other process equipment are each < 10 MMBtu/hr com busting natural gas. 607.01(d)(l)- Applicable (EU20 & EU21)- Fire pump (EU20) and emergency generator engine (EU21) combust liquid fuel (ULSD) and are each> 0.15 MMBtu/hr and total > 1.5 MMBtu/hr. 607.0l(g)- Applicable (EUOl-EUOS, EU12, EU13, EU15-EU17 and EU20-EU22)- Total actual VOCs > I 0 tpy. 607.01(n)- Applicable (EUOl-EUOS, EU12, EU13, EU15-EU17 and EU20-EU22)- The facility has taken a 50 tpy VOC limit and a 10/25 tpy HAP limit for synthetic minor status. 607.01(t)- NOT Applicable- Compliance with Env-A 1400 was demonstrated without restrictions. Verification of this compliance status specifically for hydrogen fluoride (CAS #7664-39-3) will be confirmed with stack testing. 607.01(u)- NOT Applicable- The facility is subject to 40 CFR Part 63 subparts. However, these rules do not require a title V permit. 607.0l(v)- NOT Applicable- The facility's theoretical potential to emit for NOx is< 50 tpy. 607.0l(y)- NOT Applicable- The facility is a synthetic minor HAP source. 609.01- NOT Applicable- The facility is not any of the source types in Env-A 609.0l(a).

Env-A 700- Permit Fee System- Applicable (EUOl-EUOS, EU12, EU13, EU15-EU17, EU20-EU26)

705.02- Applicable- The annual emission fee is comprised of an emission-based fee and a baseline emission fee. 705.05 -Applicable- Payment of the emission fee is due by May 15 of each year. 705.07(a)- Applicable- Each source that emits VOCs or RTAPs that are subject to Env-A 1400 from noncombustion processes shall pay a $750 annual baseline fee for the first VOC or RTAP emission unit, and a $500 annual fee for each additional non-combustion VOC or RTAP emission unit, up to a maximum of I 0 noncombustion VOC or RTAP emission units. The facility has 14 VOC emissions units (EUOl-EUOS, EU12, EUI3, EU 15, EU 16, EU 17 & EU22) so the annual baseline emission fee is $5,250.


Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227 Date: 02!11/2020 I Page 25 of28

Env-A 800- Testing and Monitoring Procedures"

802- Applicable- Compliance stack testing procedures for stationary sources. 804.03 -Applicable- MSDS information for VOC content of coatings. 804.04- Applicable- Use of Method 24 to determine VOC content of coatings.

EPA Method 24 gives the following: Volatile matter content, W, = lbs volatiles/lb coating Water content, Ww = lbs water/lb coating Exempt solvents, W, = lbs exempt solvents/lb coating Coating density, d = lbs coating/gal coating Volume of solids, V, =gal solids/gal coating

From this information, one can calculate weight ofVOCs: Wvoc = W,- Ww- W, = lbs VOC/lb coating

or wt of solids: Wr = 100- Ws = lbs solids/lb coating

and Wvoc/Wr= lb VOC/lb solids

804.05- Applicable- Calculation ofVOC Content of a Coating Formulation 804.06- Applicable- Calculation of Daily Weighted Average for a Coating Line Using Multiple Coatings 804.07- Applicable- Calculation of Emission Standard for Sources Complying with VOC RACT Using Either a Bubble or Add-On Controls (same as Env-A 1205.01) 804.08 -Applicable- Calculation of Daily-Weighted Average for Coating Lines with Bubble or Control Device 804.09- Applicable- Calculation of Required Overall Emission Reduction Efficiency of a Control System46

804.10 -Applicable- Calculation of Actual Overall Emission Reduction Efficiency of a Control System 804.11 -Applicable- Compliance Determination of a Control System 804.12 -Applicable- Initial Compliance Stack Testing for VOCs 804.13 -Applicable- Periodic Compliance Stack Testing for VOCs 804.14- Applicable- Test Methods for Compliance Stack Testing for VOCs 805- Applicable- The facility must demonstrate capture efficiency of the devices exhausted to the RTO. 810- Applicable- Monitoring Plans for Air Pollution Control Equipment

Env-A 900, Owner or Operator Recordkeeping and Reporting Obligations

902- Applicable- Availability of records. 903 -Applicable- General recordkeeping requirements. 904- Applicable- VOC Emission Statements recordkeeping requirements. 905 -Applicable- NOx Emission Statements recordkeeping requirements. 906- Applicable- Additional recordkeeping requirements. 907- Applicable- General reporting requirements. 908- Applicable- VOC Emission Statements reporting requirements. 909- Applicable- NOx Emission Statements reporting requirements. 910- Applicable- Additional reporting requirements. 911.02(b)- Applicable- Additional recordkeeping and reporting specific to non-title V sources.

Env- A 1200- Volatile Organic Compounds (VOCs) Reasonable Available Control Technology (RACT)- Applicable (EU01-EU08, EU12, EUI3, EU15-EU17)

45

46

1202.21 -"Bubble" means a technique of aggregating certain emissions so as to impose controls

SGPP has requested that all options available to coating facilities be afforded to them for VOC RACT compliance. Therefore, SGPP can buy or formulate compliant coatings using Method 24 to demonstrate compliance, OR SGPP can bubble the VOC content (lb/lb) of multiple coatings and calculate a daily weighted average to demonstrate compliance, OR SGPP can use the control efficiency determined during stack testing of the RTO for those coating lines tied to the RTO along with daily uncontrolled emissions from EU 17 to demonstrate compliance. Env-A 804.05 through 804.09 referto the standards in Env-A 1200 in terms oflbs VOC/gal of coating. However, since 2016, SGPP has been required to meet lb VOC/Ib solids or lb VOC/Jb coating standards. Therefore, these calculations shall be converted accordingly.

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation Ene:ineer: Catherine Beahm Location: 701 Daniel Webster Highway, Merrimack, NH 03054

AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 j Page 26 of28

that are more stringent than RACT-level on certain emissions units at a particular source, while simultaneously imposing controls that are less stringent than RACT-Ievel on other emissions units, including the option of no controls on such units. 1205.02(a)- Applicable- Compliance with emission limits [e.g. Env-A 1207] can be achieved through implementation of add-on control techniques or bubble 1205.07- Applicable- A source subject to this chapter shall comply with the applicable testing requirements as listed for each source category pursuant to Env-A 804. When compliance with the applicable emission standards is achieved by using a capture and control system, a capture efficiency test shall be performed according to the procedures in Env-A 805. 1207, Paper,fabric,fi/m and foil substrates coating- Applicable- The facility is subject to the requirements of Env-A 1207 because the combined actual VOC emissions are greater than 3 tons per consecutive 12-month period. 1207.02- Applicable- work practice standards 1207.03(c)- Applicable- TPE >25 tpy; emission limits [0.40 lb VOC/Ib solids or 0.08lbVOC/Ib coating] or control efficiency [90%] 1220, Miscellaneous Industrial Adhesives- NOT Applicable- The facility is not subject to the requirements of Env-A 1220 because sources who use industrial adhesives associated with fabric coating are exempt pursuant to Env-A 1220.0 I (b). 1222, Miscellaneous and Multicategory Stationary VOC Sources- NOT Applicable- The facility is not subject to the requirements of Env-A 1222 because the combined theoretical potential emissions of VOCs from the facility is limited by permit conditions to less than 50 tpy.

Env-A 1300- Nitrogen Oxide (NOx) Reasonable Available Control Technology (RACT) -NOT Applicable

1301.03- The facility has either had theoretical potential emissions less than 50 tons during any consecutive 12-month period or a permit limit which exempts the source from Env-A 1300.

Env-A 1400- Regulated Toxic Air Pollutants

The facility is able to show compliance using uncontrolled, potential emissions. (See Table 14 below)

Env-A 1600- Fuel Specifications

1602.01- Applicable to small boiler that is not above the permitting threshold- #2 fuel oil is a listed fuel 1603.03(a)- Applicable- #2 fuel oil sulfur limit of0.0015% by weight- requirement doesn't need to be included in the permit since this fuel sulfur limit applies to all #2 fuel oil imported and distributed in the state ofNH

Env-A 2000- Fuel Burning Devices

2001.02- Applicable- any stationary fuel burning device that is a source of particulate matter or visible emissions 2002.02- Applicable (EU20, EU21 & PCEO I)- all fuel burning devices at facility were installed after May 13, 1970; opacity limit(< 20%) 2003.03- Applicable (EU20, EU21 & PC EO I)- particulate matter emission limitation (0.30 lb/MMBtu)

Env-A 2100- Particulate Matter and Visible Emissions Standards 210 I, 2102 and 2103 -Applicable- any stationary device not specifically regulated pursuant to any other chapter, part, or section of the air regulations that operates in NH and is a source of particulate matter discharged to the ambient air through a stack or through an exhaust and ventilation system or any device that is a source of visible emissions 2103.02- Applicable- opacity limit (<20%)

PERMIT APPLICATION REVIEW SUMMARY Facility: Saint-Gobain Performance Plastics Corporation

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application#: I 18-0227

Federal Regulations

40 CFR Part 60- New Source Performance Standards

Subpart De -Industrial-Commercial-Institutional Steam Generating Units

§60.40c- NOT Applicable- Boiler< I OMMBtu/hr

Subpart VVV- Polymeric Coating of Supporting Substrates

Engineer:

Date:

Catherine Beahm

02111/2020 I Page 27 of28

§60.740- Applicable- (EUOI-EU08, EUI2, EUI3, EUI5 & EUI6)- Affected facility is each coating operation and any onsite coating mix preparation equipment used to prepare coatings for the polymeric coating of supporting substrates. Any affected facility for which the amount ofVOC used is less than 95 Mg per 12-month period is subject only to the requirements of §§60.744(b), 60.747(b), and 60.747(c). This subpart applies to any affected facility for which construction, modification, or reconstruction begins after April 30, 1987, except for coating mix preparation equipment or coating operations during those times they are used to prepare or apply waterborne coatings so long as the VOC content of the coating does not exceed 9% by wt of the volatile fraction.

§60. 744(b)- Each owner or operator of an affected facility that uses less than 95 Mg ofYOC per year shall make semiannual estimates of the projected annual amount ofVOC to be used for the manufacture of polymeric coated substrate at the affected coating operation in that year and maintain records of actual VOC use.

§60. 74 7(b)- Applies only to the first year of operation.

§60. 747( c)- Each owner or operator of an affected facility initially using less than 95 Mg of VOC per year shall:

(I) Record semiannual estimates of projected VOC use and actual 12-month VOC use; (2) Report the first semiannual estimate in which projected annual VOC use exceeds the applicable cutoff;

and (3) Report the first 12-month period in which the actual VOC use exceeds the applicable cutoff.

Subpart III!- Stationary Compression Ignition Internal Combustion Engines

§60.4200(a)- Applicable- EU20 Clarke fire pump manufactured after July 1, 2006; EU21 Kohler emergency generator set manufactured after April 1, 2006

§60.4202(a)(2)- Applicable (EU21)

§60.4202( d)- Applicable (EU20)

40 CFR Part 61 -National Emissions Standards for Hazardous Air Pollutants- No applicable subparts

40 CFR Part 63 -National Emissions Standards for Hazardous Air Pollutants at Stationary Sources

Subpart JJJJ- Paper and Other Web Coating

§63.3290- NOT Applicable- Facility is a synthetic minor HAP source

Subpart 0000- Printing, Coating and Dyeing of Fabrics and Other Textiles

§63.4281(b)- NOT Applicable- Facility is a synthetic minor HAP source

Subpart ZZZZ- Stationary Reciprocating Internal Combustion Engines

§63.6585 -NOT Applicable- EU 18 and EU 19 were decommissioned in 2015

Subpart DDDDDD -Industrial, Commercial, and Institutional Boilers and Process Heaters

§63.7485- NOT Applicable- Facility is a synthetic minor HAP source

Subpart HHHHHH- Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

§63.11170- NOT Applicable- Facility does not spray coat metal or plastic parts

Subpart JJJ.J.JJ -Industrial, Commercial and Institutional Boilers at Area Sources

§63 .11193 -Applicable- Boiler is located at an area HAP source- initial notification received 08/29/2011

PERMIT APPLICATION REVIEW SUMMARY Facilitv: Saint-Gobain Performance Plastics Corporation Engineer: Catherine Beahm

Location: 701 Daniel Webster Highway, Merrimack, NH 03054 AFS#: 3301100165 I Application #: I 18-0227 Date: 02/11/2020 I Page 28 of28

Table 14- Facility-wide Env-A 1400 Compliance Determination

Devices from Vertical and Emission Rate Compliance

RTAP CAS# which the Unobstructed? Determination Method RTAPis YIN Annual 24-Hr Emitted . (lbs/yr) (lbs/day)

Ethvl Acetate I 4 I -78-6 Antenna N 52.4 0.14 Air Dispersion Modeling Xvlene 1330-20-7 Antenna N 6.6 0.02 Air Dispersion Modeling

EthYl Benzene I 00-41-4 Antenna N 1.3 0.004 Air DisPersion Modeling Ethvlene Glvcol I 07-2 I -I Coaters y 8,208 22.49 Air Dispersion Modeling

Toluene 108-88-3 Both N 7,214.8 19.77 Air Dispersion Modeling Isollrooanol 67-63-0 Coaters y 292.2 0.80 Air Dispersion Modeling

Ethanol 64-17-5 Coaters y 7.72 0.02 Air Dispersion Modeling I A-Dioxane 123-91-1 Coaters y 14.69 0.04 Air Dispersion Modeling

Benzene 71-43-2 Both N 0.196 0.00054 Air Disoersion Modeling PolYethVIene Glvcol 25322-68-3 Coaters y 1,593 4.36 Air Dispersion Modeling Tetrafluoroethvlene I 16-14-3 Coaters y 2,642 7.24 Air Dispersion Modeling

Methanol 67-56- I Coaters y 130.39 0.36 Air Dispersion Modeling Methvl Ethvl Ketone 78-93-3 Both N 1,181.2 3.24 Air Dispersion Modeling

n-Methyl-2-872-50-4 Coaters y 124.43 0.34

Air Dispersion Modeling pyrrolidone

Hexane I I 0-54-3 Both N 140.12 0.38 Air Dispersion Modeling PFOA (as Air Dispersion Modeling

Ammonium 3825-26-1 Coaters y 2.0 0.005 Perfluorooctanoate) Hydrogen Fluoride

7664-39-3 Coaters/ RTO y 2,278 6.24 Air Dispersion Modeling

(as F) Ammonia 7664-4 I -7 Coaters y 723 1.98 Air Disoersion Modeling

4

Statement of Basis

Dailun America, Inc. Morgan County

Decatur, Alabama 712-0061

Daikin America, Inc. ("Daikin") has applied for renewal of Major Source Operating Permit No. 712-0061. This proposed Title V Major Source Operating Permit is issued under the provisions of ADEM Admin. Coder. 335-3-16. The above named applicant has requested authorization to perform the work or operate the facility shown on the application and drawings, plans, and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of the permit.

Background

This facility is a chemical production plant which produces fluoropolymers. The facility is allowed to operate 8,760 hours per year unless otherwise specified. Based on the Title V permit application, this facility is a major source for particulate matter (PM) and volatile organic compounds (VOC).

Changes from existing permit:

I. Revised emission calculations were submitted by for the facility. The emissions from the adjacent facility, MDA Manufacturing, Inc. were included in Daikin's plant wide emission totals.

2. Updated Title V Permit to include source specific requirements of 40 CFR Part 63, Subpart DDDDDD for all applicable equipment.

3. Administratively changed unit title from Methanol tank to TFE Unit Tanks.

4. Administratively added storage tank M2-V 561 to TFE Unit Tanks.

5. Administratively added C7-V301 to OIME Tanks.

6. Administratively incorporated air Permit No. 712-0061-X023 for ETFE/FEP/EFEP Unit with Scrubber (N2-15) and Back-Up (N2-15B).

7. Administratively added the product "TV Polymer" to the ETFE/FEP/EFEP Unit.

8. Updated Title V Permit to include additional continuous compliance testing requirements of ADEM Admin. Coder. 335-3-3-.05 ("CISWI").

9. Administratively changed the compliance indicator for all particulate matter (PM) emission points of the ETFE/FEP/EFEP/TV and ETFE Batch units from daily visual observations to weekly.

10. Administratively deleted emission points N2-7 and N2-12. The emission points vent inside buildings and/or are not vented to the atmosphere.

II. Administratively deleted emission point Nl-8. The emission point was a duplicate and is encompassed in the ETFE Batch unit.

12. Administratively deleted emission point N2-15B. The emission point N2-15 is routed to a scrubber for control. The scrubber associated with this emission point has a back-up. The scrubber can only operate in parallel. Therefore, emission point N2-15 encompasses the scrubber and back-up.

Each of the individual production units is described below:

TFE Unit

The unit utilizes two natural gas fired 5.75 MMBtu/hr process furnaces (MI-l and Ml-9) which share a common stack and an 11.2 MMBtu/hr process furnace. The HCL storage tank (Ml-2) and distillation columns (Ml-3 through Ml-8) are required to be routed to the T-Thermal oxidizer for control ofVOC, HAP, and CFC. The neutralization pit associated with the waste acid control system is routed to scrubber C!-TIOI (Jl-6) for control of VOC. This unit is subject to minor PSD limitations for PM, NOx, VOC, HAP, and CFC.

Emission Standards

Opacity

The state opacity requirement is applicable to the process furnaces associated with this unit and the T-Thermal incinerator.

Particulate

The furnaces are subject to the state allowable particulate limit for fuel burning equipment. Based on 5.75 lb/MMBtu fuel input, the PM emissions from the furnaces, which share a common stack are required to be limited to 0.64 lb/MMBtu for each furnace. The PM emissions from the 11.2 MMBtu/hr process furnace are required to be limited to 0.48 lb/MMBtu.

NOx

In order to maintain synthetic minor status with respect to PSD and Title V, the furnaces (M1-1 and M1-9) are required to limit the NOx emissions to 0.48 lb/hr for each unit.

S02

The furnaces are subject to the state allowable S02 limit for fuel burning equipment. The furnaces are required to emit less than 4 lb/MMBtu for each unit.

voc

The emissions from the distillation columns (M1-3 through M1-8) are required to be routed to the T-Thermal incinerator in order to achieve a 99.99% destruction removal efficiency (DRE) of VOC. The facility is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV for fugitive VOC emissions in this unit.

The scrubber, C1-Tl 01 (J1-6), is associated with an adjacent facility, MDA Manufacturing (MDA). The unit is required to route all emissions from the neutralization pit to the scrubber and maintain VOC emissions from Jl-6 to less than 0.42 lb/hr.

HAP

The emissions from the HCL storage tank (Ml-2) are required to be routed to the TThermal incinerator in order to achieve a 99.99% DRE of HAP.

CFC

Ih!U!EJ!~si~!J§J'ron1J~gl~!t!£.!Lci!~itM.l::~!N£~~9Ml-J!l!!f~regUired·to be routed to the T-Thermal incineratorin otdertoachieve a99;99%DRE ofCFC.

Periodic Monitoring

Opacity/Particulate

Since the furnaces are permitted to fire natural gas only, the units would meet the opacity and particulate limits inherently. Therefore, no periodic monitoring is required.

NOx

Since the furnaces N Ox limits are based on good combustion practices, the facility is required to conduct annual inspections of the burner and implement a standard operating procedure.

S02

Since the furnaces are permitted to fire natural gas only; the units would meet the S02 limits inherently. Therefore, no periodic monitoring is required.

voc

The unit would be required to maintain the records equivalent to those listed in the requirements of 40 CFR Part 60, Subpart VV. The monitoring requirements for the TThermal incinerator are discussed under the T-Thermal incinerator unit section.

HAPICFC

Jh!"!H!?»!l8Uilg,I~fll:lif.~!Jl~!];!§JW the T-Thermal incinerator are discussed under the. TThermal incinerator unit section.

TFE Storage Tanks

The TFE unit utilizes 2 tanks (Ml-VSO! and M2-V561) which store VOC/HAP. The tanks are subject to synthetic minor PSD limitations for VOC and HAP.

Emission Standards

VOCIHAP

In order to remain synthetic minor for PSD, the tanks are required to be equipped with a conservation vent.

The tanks are stored at temperatures which would result in a vapor pressure below the thresholds for ADEM Admin. Code r. 335-3-3-.06 (VOC loading). In order to remain below this level, Daikin would be required to calculate and maintain the vapor pressure below 1.5 psia.

Periodic Monitoring

VOC/HAP

The vapor pressure of the material stored in the tank is required to be calculated and maintained for the life of the tanks.

PTFE-FD Unit

The PTFE-FD unit emission points include a polymerization reactor and product dryer. The product dryer is required to be routed to a packed bed scrubber for control. The unit is subject to synthetic minor PSD limitations for VOC.

Emission Standards

Opacity

The state opacity requirement is applicable to the product dryer associated with this unit.

Particulate

The dryer is subject to the state process weight curve. Based on the process weight the particulate limit for the polymerization reactor is 3.0 lb/hr.

voc

In order to remain synthetic minor with respect to PSD and Title V for VOC, the polymerization reactors (PTFE-FD-JA-0) are limited to 0.0011 lb VOC/lb of PTFE at polymerization and 4.2 tpy total. Additionally, the unit is required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

Periodic Monitoring

Opacity/Particulate

As an indicator of compliance with the PM and opacity limits associated with this unit, the facility is required to conduct daily visual observations of the packed bed scrubber (PTFEFD-2). If emissions greater than normal are noted, the facility must take corrective action within 2 hours.

voc

To ensure that the polymerization reactors are in compliance with the VOC limits, the facility is required to maintain a vacuum (?. I psig) during final polymerization reactor recovery. Additionally, the unit would be required to comply with the monitoring requirements for an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

PTFE-M Unit

The PTFE-M unit emission points include a polymerization reactor and product dryer. The product dryer is required to be routed to a packed bed scrubber for control. The unit is subject to synthetic minor PSD limitations for PM and VOC.

Emission Standards

Opacity

The state opacity requirement would be applicable to the product dryer associated with this unit.

Particulate

The dryer would be subject to the state process weight curve; however, in order to remain a synthetic minor source with respect to PSD, the facility has taken a more restrictive PM limit of 1.0 lb/hr. voc

In order to remain a synthetic minor source with respect to PSD and Title V for VOC, the polymerization reactors (PTFE-M-1) are limited 3.8 lb/hr. Additionally, the unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

Periodic Monitoring

Opacity/Particulate

As an indicator of compliance with the PM and opacity limits associated with this unit, the facility is required to conduct daily visual observations of the packed bed scrubber.

voc

To ensure that the polymerization reactors are in compliance with the VOC limits, the facility is required to maintain a vacuum (2: 1 psig) during final polymerization reactor recovery (i.e. not open to the atmosphere). Additionally, the unit would be required to comply with the monitoring requirements for an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

ETFE/FEP/EFEP/TV Unit

The ETFE/FEP/EFEP/TV unit consists of several pieces of particulate handling process equipment. The particulate emission points associated with this unit include N1-2, N1-4,

Nl-5, Nl-6, Nl-9/Nl-9B, Nl-lOA, B, and C, Nl-11, Nl-12/Nl-12B, Nl-16, Nl-17, Nl-18, Nl-19/Nl-19B/Nl-19C, Nl-23, and Nl-25/Nl-25B. The unit also consists of several VOC emission points. The VOC emission points associated with this unit include N 1-4, Nl-14/Nl-14B, Nl-20, Nl-21, AND Nl-22. The unit is subject to synthetic minor PSD limitations for PM and VOC.

Emission Standards

Opacity

The state opacity requirement would be applicable to emission points with the potential to emit particulate matter (Nl-2, Nl-4, Nl-5, Nl-6, Nl-9/Nl-9B, Nl-lOA, B, and C, Nl-11, Nl-12/Nl-12B, Nl-16, Nl-17, Nl-18, Nl-19/Nl-19B/Nl-19C, Nl-23, and Nl-25/Nl-25B) in this unit.

Particulate

All particulate matter emission points are subject to the state process weight curve; however, in order to avoid PSD review, the facility has committed to more stringent PM limits on each particulate point. The limits for each emission point are listed in the table below.

Emission Point PM limit (lb/hr) Nl-2 0.10 N1-4 0.22 Nl-5 0.22 N1-6 0.05 Nl-9 0.30 N1-9B 0.06 Nl-10A, B, C 0.05 Nl-11 0.05 N1-12/Nl-12B 0.15 N1-16 0.10 N1-17 0.20 Nl-18 0.10 Nl-19 0.08 Nl-19B/C 0.08 Nl-23 0.01 Nl-25/Nl-25B 0.46

voc

In order to remain synthetic minor forVOC, the emission point Nl-4 has a VOC emissi()n

limit of 2.0 lblhr. J:9£,.,<t£!Ji~i2IlR~t~~.l'il:H1.Jil:JJ!!tJU:~~ .. ~l:±l~~~£LJD;17-~~ ~ifsd to be vented to the'T ~Thermalipcuwrator to ensl.!re a 99.99'lfo DE£ forVOC atJ,d CFC. The unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

Periodic Monitoring

Opacity/Particulate

The facility was previously required to conduct daily visual observations for the following PM emission points: N1-4, N1-5, Nl-6, N1-9, N1-9B, Nl-10A, B, C, Nl-11, N1-l2, N1-12B, N1-16, Nl-17, N1-18, N1-19, N1-19B/C, N1-23, N1-25, and N1-25B. The facility has proposed to conduct weekly visual observations for each emission point listed above. Based on the unit's operation and past visual inspections, the Department has determined that weekly visual inspection for these emission points would be appropriate. Additionally, weekly visual observations are also required for emission points N1-2 and N1-23. Therefore, weekly visual observations are required for all emission points within the ETFE/EFEP/FEP/TV unit.

voc

The T-Thermal monitoring requirements are discussed under the T-Thermal incinerator unit section below. The unit would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 60, Subpart VV.

ABCO Boilers

The two ABCO boilers are 35.7 MMBtu/hr natural gas fired boilers with No. 2 fuel oil backup utilized to provide process heat. The boilers are equipped with low NOx burners. The unit is subject to synthetic minor PSD limitations for PM, S02, and NOx.

When firing No. 2 fuel oil, the boiler would be subject to 40 CFR Part 63, Subpart JJJJJJ. The boilers would be classified as existing oil fired units. Since the boilers would be classified as existing with respect to Subpart JJJJJJ, no emission limits would be applicable to the boilers while firing No. 2 fuel oil. The facility would be required to conduct an initial tune-up and biennial tune-ups of the boilers.

Opacity

The boilers are subject to the requirements of 40 CFR Part 60, Subpart De. The boilers are limited to discharge with an opacity no greater than 20% (6-minute average), except for one 6-minute period per hour of not more than 27% opacity. The state opacity requirement would be applicable to the boilers; however, the Subpart De requirement is more stringent.

Particulate

The boilers are subject to the state requirement for particulate matter from indirect heating equipment. Based on the equation, the allowable particulate from the boilers are 0.29 lb/MMBtu each. Since the boilers are permitted to bum No. 2 fuel oil, the facility has committed to an ash limit in the No. 2 fuel oil of less than 0.1% by weight in order to remain synthetic minor with respect to PSD. NOx

In order to remain synthetic minor with respect to PSD and Title V for NOx, the boilers are limited to 8.5 lb/hr total while firing No.2 fuel oil. Additionally, the boilers are limited to 3,819,798 gal/yr of fuel oil.

S02

The boilers are subject to the state requirement for sulfur emissions from fuel burning sources. The boilers would be limited to 4 lb/MMBtu each.

Subpart De requires the facility to utilize fuel oil in these units with a sulfur content less than 0.5 %by weight; however, the boilers have a more stringent limit for sulfur content in the fuel of less than 0.1% by weight in order to remain a synthetic minor source with respect to Title V and PSD for S02.

Periodic Monitoring

Opacity/Particulate

The ash content of the No.2 fuel oil fired in this unit is maintained and recorded. When firing No.2 fuel oil, visual observations of the boiler stacks would be performed.

NOx

As an indicator of compliance with the NOx limitations, the facility has implemented standard operating procedures, maintenance procedures, and performs inspections of the low NOx burners within 15 months of the last completed inspections.

As an indicator of compliance with the NOx limits when firing No. 2 fuel oil, the records of the amount of fuel fired in the units are maintained.

so2

As an indicator of compliance with the S02 limits when firing No. 2 fuel oil, the sulfur content of the fuel oil fired in the units is maintained.

Nebraska Boilers

The Nebraska boiler is a 73.8 MMBtu/hr natural gas fired boiler with No. 2 Fuel oil back up utilized to provide process heat. The unit is subject to synthetic minor PSD limitations for NOx and S02.

When firing No.2 fuel oil, the boiler would be subject to 40 CFR Part 63, Subpart JJJJJJ. The boiler would be classified as an existing oil fired unit. Since the boiler would be classified as existing with respect to Subpart JJJJJJ, no emission limits would be applicable to the boiler while firing No. 2 fuel oil. The facility would be required to conduct an initial tune-up and biennial tune-ups of the boiler.

Opacity

The boiler is subject to the requirements of 40 CFR Part 60, Subpart De. The boiler is limited to discharge with an opacity no greater than 20% ( 6-minute average), except for one 6-minute period per hour of not more than 27% opacity. The state opacity requirement would be applicable to the boiler; however, the Subpart De requirement is more stringent.

Particulate

The boiler is subject to the state requirement for particulate matter from indirect heating equipment. Based on the equation, the allowable particulate from the boiler would be 0.21 lb/MMBtu. Since the boiler is permitted to burn No.2 fuel oil, the facility has committed to an ash limit in the No. 2 fuel oil of less than 0.1% by weight in order to remain synthetic minor with respect to PSD.

NOx

In order to remain synthetic minor with respect to PSD and Title V for NOx, the boilers are limited to firing 2,687,068 gal/yr.

S02

The boiler is subject to the state requirement for sulfur emissions from fuel burning sources. The boiler would be limited to 4 lb/MMBtu.

Subpart De requires the facility to utilize fuel oil in this unit with a sulfur content less than 0.5 % by weight; however, the boiler has a more stringent limit for sulfur content in the fuel of less than 0.1% by weight in order to remain a synthetic minor source with respect to Title V and PSD for S02.

Periodic Monitoring

Opacity/Particulate The ash content of the No. 2 fuel oil fired in this unit is maintained and recorded. When burning No. 2 fuel oil, visual observations of the boiler stacks would be performed.

NOx

As an indicator of compliance with the NOx limits when firing No. 2 fuel oil, the records of the amount of fuel fired in the unit are maintained.

S02

As an indicator of compliance with the S02 limits when firing No. 2 fuel oil, the sulfur content of the fuel oil fired in the unit is maintained.

OIME Storage Tanks

The utilities area within the facility utilizes 2 storage tanks (C2-V004 and C7-V30 1) which store OIME (VOC). C2-V004 is subject to BACT limitations for VOC. C7-V301 is subject to synthetic minor PSD limitations for VOC.

Emission Standards

voc

Storage tank C2-V004 is required to be vented to a water seal pot as determined by BACT. The V OC content of the water is limited to ~ l 0% by weight.

In order to remain synthetic minor with respect to PSD for VOC, storage tank C7-V301 is required to be equipped with a conservation vent.

Emission Monitoring

voc

The facility is required to conduct monthly monitoring of the water in the water seal pot of tank C2-V004 for a phase split to ensure the VOC content of the water does not exceed 10%. Additionally, the facility is required to conduct daily monitoring of the seal pot to ensure that the water level is above the discharge of the vent pipe.

The tank C7-V30 I is equipped with a conservation vent. No additional monitoring is required.

ETFE Batch

The ETFE Batch process was permitted as an expansion to the original ETFE/FEP/EFEP/TV process. The ETFE Batch unit consists of several pieces of particulate handling process equipment. The particulate emission points associated with this unit include N2-2, N2-7, N2-8, N2-9/N2-9B, N2-10/N2-IOB, N2-ll, N2-12, and N2-15/N2-15B. The unit also consists of multiple VOC emission points. The VOC emission points associated with this unit include N2-5 and N2-13. The unit is subject to synthetic minor PSD limitations for PM and VOC.

Opacity

Each particulate emission point within this unit is subject to the state opacity regulations.

Particulate

All particulate matter emission points are subject to the state process weight curve; however, in order to avoid PSD review, the facility has committed to more stringent PM limits on each particulate point. The limits for each emission point are listed in the table below.

Emission Point PM limit (lblhr) N2-2 0.023 N2-7 2.7 N2-8 0.057 N2-9/N2-9B 0.15 N2-10/N2-IOB 0.23 N2-11 0.057 N2-12 0.06 N2-15/N2-15B 0.05

voc

~.L45l,Ltl?~,£~l;!,l~iD~n£h~tic.lllillt!rJ££,.Yg9,dl.t:tL~~\2p._l)i)JnL!:l,?,:2 .• ~!MliJ'!~lt~!~. auil¢ to be vented to the T "T)lerma} iJ:lcillerator to ensure l! 99.99%D~foryoc and CFC . .The unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VVa.

Periodic Monitoring

Opacity/Particulate

The facility was previously required to conduct daily visual observations for N2-2, N2-7, N2-8, N2-9/N2-9B, N2-l O/N2-l 08, N2-ll, N2-12, and N2-15/N2-15B. The facility has proposed to conduct weekly visual observations for each emission point listed above. Based on the unit's operation and past visual inspections, the Department has determined that weekly visual inspection for these emission points would be appropriate. Therefore, weekly visual observations are required for all emission points within the ETFE batch unit.

voc

The T-Thermal monitoring requirements are discussed under the T-Thermal incinerator unit section below. The unit would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 60, Subpart VVa.

Unidyne

The primary emission point from the Unidyne unit is the Unidyne thermal oxidizer (U 1-1 ).

Emission Standards

Opacity

The state opacity requirement would be applicable to the Unidyne thermal oxidizer (U 1-1 ).

PM

The unit is subject to the state requirements for incinerators. The Unidyne thermal oxidizer (Ul-1) is subject to a PM limitof0.2lb/IOO lb charged.

HAPIVCM

The Unidyne process unit is subject to 40 CFR Part 63, Subpart DDDDDD (PVC MACT for Area Sources). Subpart DDDDDD requires the unit to control the HAP and VCM

emissions from each emission source based on the type of resin being produced as listed in the table below.

Additionally, Subpart DDDDDD also requires the implementation of an LDAR program equivalent to 40 CFR 63.1020 through 63.1025, 63.1027, 63.1029 through 63.1032, and 63.1034 through 63.1039 of Subpart UU for equipment in HAP service as stated in 40 CFR 63.11915(a). In addition to the requirements of Subpart UU, the requirements for pumps, compressor, and agitators and pressure relief devices listed in 40 CFR 63.11915(b) and (c), are required.

Vent Classification Pollutant Emission Limit PVC-only process vents Vinyl chloride- 5.3 parts per million by

All resin types volume (ppmv) PVC-only process vents Total Hydrocarbons or 46 ppmv measured as

total organic HAP propane or 140 ppmv, respectively.

PVC-only process vents Dioxins/furans (toxic 0.13 ng/dscm equivalency basis)-All resin types

Stripped Resin Process Vents Vinyl Chloride- 1,500 ppmw Dispersion resin

Stripped Resin Process Vents Total non-vinyl chloride 230 ppmw organic HAP -Dispersion resin

Process Wastewater Vinyl Chloride- 2.1 ppmw All resin types

Periodic Monitoring

Opacity/PM

Since the Unidyne thermal oxidizer (U1-1) is permitted to fire natural gas and process gas only, the unit should meet the opacity requirement inherently.

HAPIVCM

Process Vents

As a determiner of compliance, Subpart DDDDDD requires the facility to conduct performance testing every 5 years for each pollutant listed in Table! of Subpart DDDDDD.

Additionally, daily vinyl chloride concentration in stripped resin and the monthly concentration of non-vinyl chloride organic HAP is required to be measured and maintained.

Ambient Monitoring

As a determiner of compliance, a Vinyl chloride monitoring system is required to be installed in accordance with the requirements of 40 CFR 63.11956.

Wastewater

As a determiner of compliance, the facility is required to measure and maintain the concentration of vinyl chloride and non-vinyl chloride organic HAP in each wastewater stream that must be treated according to the requirements of 40 CFR 63.11965(b). Additionally, annual performance tests are required to be performed for each wastewater stream which is determined not to be treated according to the requirements of 40 CFR 63.11970(b).

Equipment Leaks

The facility would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 63, Subpart UU and the applicable requirements of Subpart DDDDDD.

T ·Thermal Incinerator

Elllission Standards

Opacity

The state opacity requirement would be applicable to the T ·Thermal incinerator. The incinerator is routed to a wet scrubber prior to venting to the atmosphere.

PM

The state PM requirement for incinerators would be applicable to the T ·Thermal incinerator. The incinerator would be required to maintain particulate emissions below 0.1

lb/1 00 lbs refuse charged if the charging rate is greater than 50 tons per day and 0.2 lb/1 00 lbs of refuse charged for charging rates less than or equal to 50 tons per day.

The unit would also be subject to synthetic minor PSD limitations for PM since the TThermal incinerator would be capable of firing No.2 fuel oil. In order to maintain synthetic minor status for PM, the T-Thermal incinerator would be required to fire No. 2 fuel oil in the unit with an ash content of less than 0.1% by weight.

so2

The unit would be subject to synthetic minor PSD limitations for SOz since the T-Thermal incinerator would be capable of firing No. 2 fuel oil. In order to maintain synthetic minor status for S02, the T-Thermal incinerator would be required to fire No.2 fuel oil in the unit with a sulfur content of less than 0.1% by weight. NOx

The unit would be subject to synthetic minor PSD limitations for NOx since the T-Thermal incinerator would be capable of firing No. 2 fuel oil. In order to maintain synthetic minor status for NOx, the T-Thermal incinerator is required to limit the NOx emissions to 0.27 lb/hr while firing No. 2 fuel oil.

CJSWI

The unit would be classified as an existing unit (constructed before November 30, 1999). The emission limitations for existing units is listed in the table below.

~()~~t .• l\nt • •······ ·· • • ::: . . ... ••.L. im·;·:: .. lf.tu .... ~:~i.t·s·}•ta.; 7~;.oxl'····~···e···n. ;.··.~rr. J>~s~~~ . . . . • .•. · ........ ·•... .... • .... < .ex~ept (}pacit&) ·.·· o> . ••>ii· •• • •.••.•.

Cadmium 0.004 mg/dscm Carbon Monoxide 157 ppmvd Dioxins/furans 0.41 ng/dscm Hydrogen Chloride 62 ppmdv Lead 0.04 mg/dscm Mercury 0.47 mg/dscm Nitrogen Oxides 388 ppmdv Particulate Matter 70 mg/dscm Sulfur Dioxide 20 ppmdv Opacity l 0 percent (6-minute averages)

VOCICFC

Periodic Monitoring

Opacity! PM

Since the emissions from the T-Thermal incinerator are routed to a wet scrubber for control, no monitoring would be required while firing natural gas only.

As an indicator of compliance while firing No.2 fuel oil, the records of the ash content are required to be maintained.

CISWI

Since a wet scrubber is utilized for control, the facility has established operating limits for 4 parameters in order to indicate compliance. The parameters monitored, operating limit set during the most recent compliance testing, and the averaging time for each value are listed below.

Parameter Operating Limit Averaging Time

Charge Rate <II 0% of rate during 3-hour rolling compliance testing

Scrubber Pressure Drop > 1.85 in H20 3-hour rolling Scrubber Liquor Flow 2:55 gpm 3-hour rolling Rate Scrubber Liquor pH >7 3-hour rolling

The facility would also be required to inspect the control device annually. Additionally, performance testing is required annually and within 60 days of a process change made to the unit.

VOC/CFC

I,n.,ord]FJ££2!n.EAY~~!l1.Jh~.~lQ!!i-!l11c nllll2!liml!~JlgnsJJ,!I2lQ£.~~32F.¢~ili~.J;;J:h~:rmal in.eJp~f.l!!2~i~.!~lliJHx~L!.9.~~11t!l!ll:.~Jk~12.2~.temE~!~tm:~.91.~£~!S.t1h~!L£lJ;,equal to. 2300. 'F,. The firebox temperature is to be recorded continuously and l!l.aintaille<l;

As an indicator of compliance while firing No. 2 fuel oil, the facility would maintain records of the sulfur content of the fuel.

NOx

The facility would be required to conduct performance testing in order to determine compliance with the NOx limit while firing No. 2 fuel oil.

Generators

The description, date installed, and operating capacity of the emergency generators and firewater pumps utilized by the facility are listed in the table below. All generators are utilized as emergency use only. All engines are diesel fired compression ignition reciprocating internal combustion engines (RICE) and are subject to 40 CFR Part 63, Subpart ZZZZ.

Generator ID Installation Operating Date Capacity

Administration 2005 149

Building Generator Utility Generator# 1 1993 1332 Unidyne Emergency

2000 438 Generator Fire Pump#! 1993 412 Utility Generator #2 1999 1199 Fire Pump #2 1993 305

Emission Standards

Opacity

All emergency generators and firewater pumps associated with this facility are subject to the state opacity requirements.

HAP

The engines are subject to the emission limitations listed in Table 2c of Subpart ZZZZ. In order to remain classified as emergency, the engines would be required to operate according to the requirements of 40 CFR 63.6640(1)(1)-(4).

Periodic Monitoring

HAP

As an indicator of compliance, records of operation of the engines in emergency and nonemergency service, which is recorded through a non-resettable hour meter, are required to be maintained for each engine.

Compliance Assurance Monitoring (CAM)

Based on compliance assurance monitoring (CAM) applicability criteria, the facility has determined that two emission points would potentially be subject to CAM: PTFE-M-1 and PTFE-FD-1-A-G. Each emission point is controlled by compressor and vacuum systems. The facility has stated that each emission point would have an uncontrolled potential to emit greater than 100% of the major source threshold for VOC. However, since the facility has stated that the compressor and vacuum system is for recovery of TFE material, the emission points would not be considered control devices as defined in CAM. Therefore, the emission points listed above would not be subject to the requirements of CAM.