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The State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES ____________
Thomas S. Burack, Commissioner
DES Web site: www.des.nh.gov
P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095
Telephone: (603) 271-1270 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964
December 9, 2013
William Dannhauer
Operations Manager
Kalwall Corporation
PO Box 237
Manchester, NH 03105
RE: On-Site Full Compliance Evaluation Report
Dear Mr. Dannhauer:
The New Hampshire Department of Environmental Services, Air Resources Division
(“DES”) has completed a Full Compliance Evaluation of Kalwall Corporation – Bow Flat Sheet
Division (“Kalwall”) in Bow. The compliance evaluation included an on-site inspection
completed on November 8, 2013. This is a copy of the On-Site Full Compliance Evaluation
Report for your review and records.
DES identified deficiencies during this compliance evaluation, as detailed in this report.
The results of this compliance evaluation may be forwarded to the Enforcement Section for
further review. If you have any questions, please contact Daniel Hrobak at (603) 271-1987 or
email at [email protected].
Sincerely,
Greg Helve
Compliance Assessment Section Supervisor
Air Resources Division
cc: Chairman, Board of Selectmen, Town of Bow, 10 Grandview Road Bow, NH 03304
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 2 of 37
Abbreviations and Acronyms AAL Ambient Air Limit
acf Actual cubic foot
ags Above ground surface
ASTM American Society of Testing and Materials
Btu British thermal units
CAS Chemical Abstracts Service
cfm Cubic feet per minute
CFR Code of Federal Regulations
CO Carbon Monoxide
CO2e Carbon dioxide equivalent
DER Discrete Emission Reduction
DES New Hampshire Department of Environmental Services
Env-A New Hampshire Code of Administrative Rules – Air Resources Division
ERC Emission Reduction Credit
FGD Flue Gas Desulphurization
ft Foot or feet
ft3 Cubic feet
gal Gallon
HAP Hazardous Air Pollutant
hp Horsepower
hr Hour
lb Pound
LPG Liquefied Petroleum Gas
MM Million
MSDS Material Safety Data Sheet
MSW Municipal Solid Waste
MW Megawatt
MWC Municipal Waste Combustor
N/A Not applicable
NAAQS National Ambient Air Quality Standard
NG Natural Gas
NOx Oxides of Nitrogen
NPV Notice of Past Violation
NSPS New Source Performance Standard
PM10 Particulate Matter < 10 microns
ppm Parts per million
PSD Prevention of Significant Deterioration
psi Pounds per square inch
RACT Reasonably Available Control Technology
R&D Research and Development
RSA Revised Statues Annotated
RTAP Regulated Toxic Air Pollutant
scf Standard cubic foot
SO2 Sulfur Dioxide
TSP Total Suspended Particulate
tpy Tons per consecutive 12-month period
USEPA United States Environmental Protection Agency
VOC Volatile Organic Compound
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 3 of 37
I. Facility Description
DES conducted an On-Site Full Compliance Evaluation of Kalwall and the results are presented
herein. The compliance evaluation covers the period of 2012 to November 8, 2013.
Kalwall operates a continuous lamination manufacturing process for making flat reinforced
plastic (fiberglass) sheet or panels. The sheets may be opaque or translucent depending on
customer specifications. Among the most common applications of the sheet product are
construction panels, glazing panels, truck trailer paneling, refrigerator liners, sanitary paneling,
solar collector covers, road signs, and other similar products.
Resin is gravity fed to the applicator bath from a mezzanine mixing tank area onto a carrier
surface. Rolls of fiberglass roving are chopped and mechanically distributed onto the resin to
produce a uniform mat. The impregnated mat runs through a squeeze roll to remove excess resin
compacting the fiber bundles into the mat and controlling the sheet thickness. A second film is
applied from above to sandwich the resin-impregnated fiberglass between the two sheets. The
sheet then passes through a curing oven, which accelerates the chemical reaction, to cure and
harden the finished material. The resulting “fiberglass” sheet is cooled before stripping away the
top carrier film. The process proceeds without interruption provided that raw materials are
supplied to the feed end of the equipment. In practice, Kalwall “injects” resin supply to the
applicator bath tank in 500-pound batches, which classifies the process as intermittent.
Kalwall is subject to 40 CFR Part 63 subpart WWWW – National Emissions Standards for
Hazardous Air Pollutants: Reinforced Plastic Composites Production and, therefore, requires a
Title V permit. Kalwall is also required to obtain a permit to limit its VOC emissions to less than
50 tpy.
Facility name and address Kalwall Corporation – Bow Flat Sheet Division
40 River Rd
Bow, NH 03304
County Merrimack
Telephone 603-224-6881
AFS# 3301300051
Source Type Title V
Inspection Date/Time November 8, 2013; 9:00 AM
Inspection Type On-Site Full Compliance Evaluation
Inspection Period 2012 – November 8, 2013
Weather 40o F., sunny, wind 5 mph
Inspected by Daniel Hrobak, Senior Compliance Assessment Engineer
Source Contact(s) William Dannhauer, Operations Manager
Kathleen Harvey, Environmental, Health & Safety Manager
Jeff Hicks, Plant Manager
Kenny Welch, Maintenance Supervisor
Last Inspection July 24, 2012
No deficiencies identified
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 4 of 37
Permit Number: TV-0027 Issued: October 12, 2012
Expires: October 31, 2017
TV-OP-027 Issued: February 10, 2006
Expired: February 28, 2011
The on-site inspection included an opening meeting to discuss the purpose of the inspection as
well as the rules pertaining to claims of confidentiality and facility safety concerns. Kalwall
agreed to the inspection and authorized access to the facility. Material provided and operations
conducted by the facility at the time of the inspection were not claimed as confidential.
II. Emission Unit Identification and Facility Wide Emissions
Table 1 below, taken from the permit, lists the permitted emission units
Table 1 Significant Activity
Emission
Unit ID Description of Emission Unit or Process Manufacturer
Installation
Date
Maximum Design
Capacity and Permitted
Fuel Types
EU01 Fiberglass Reinforced Plastic Lamination
Process Kalwall 1970 Glass Fiber – 621.5 lb/hr
EU02
Fire Pump Engine
Model # 3208
Serial # 03Z04769
Caterpillar 1986 235 horse power
Diesel – 14.1 gal/hr
DES observed the devices identified in this table and the facility has made no changes to these
devices. During the inspection, neither of the devices was in operation. The facility has made no
changes to these devices and has not added any devices classified as significant activities.
Kalwall has identified the following insignificant activities:
Insignificant Activity List
Item # Insignificant Activity
1 Customer sample preparation
2 Muffler furnace for lab-scale fire tests (0.075 MMBtu/hr)
3 (Six) Oil-fired heating furnaces (0.45 MMBtu/hr each unit)
4 (Four) Dual fuel fired space heating air units (0.625 MMBtu/hr each unit)
5 Storage tanks of such a size and vapor pressure as not to emit VOC or HAP
6 (Eighteen) gas-fired process production line burners (0.50 to 0.80 MMBtu/hr each)
7 (Three) Make-up air gas fired burners (0.5 MMBtu/hr each unit)
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 5 of 37
The table below lists the facility-wide reported annual emissions for the review period.
Facility-Wide Emissions (tons)
TSP SO2 NOx CO VOC HAPs/RTAPs
Permitted Limits — — — — 48.5 —
2012 0.02 0.24 0.83 0.45 1.49 20.41
Note: There are no permit limits for HAPs. The RTAP limits are identified in Env-A 1450. The
facility did not exceed any RTAP limits.
III. Control Equipment
Table 3 below, taken from TV-0027, lists the relevant required control equipment for the
facility’s devices.
Table 3- Operational and Emission Limitations
Pollution Control
Equipment ID Description Purpose
Emission Unit
Controlled
PCE01 Regenerative Thermal Oxidizer
CCM Group, LLC Model: 1300-M-95 For control of HAPs EU01
IV. Stack Criteria
Table 2 below, taken from TV-0027, lists the permitted stack requirements for the facility’s
devices.
During the inspection, DES observed the stacks were oriented as specified below, with Stack 1
and Stack 5 being above the roofline and unobstructed.
Table 2- Stack Criteria
Stack
Number Emission Unit ID
Maximum Height
(feet above ground surface)
Maximum Exit
Diameter (feet) Stack Orientation
1 Regenerative Thermal
Oxidizer [RTO] 31 2.83 Vertical
2 West Wall Fan 16 3.0 Horizontal
3 West Roof Fan 27.9 4.65 Vertical
4 Recovery Room 12 1.5 Horizontal
5 RTO By-pass 31 2.83 Vertical
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 6 of 37
V. Compliance with Operating and Emission Limitations
Table 4, below lists the state only operational and emission limitations requirements for the
facility from TV-0027 and any deficiencies noted during the evaluation.
Table 4- State-only Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission Unit
Regulatory
Citation Compliant
1.
24-hour and Annual Ambient Air Limit
The emissions of any regulated toxic air pollutant (RTAP)
shall not cause an exceedance of its associated 24-hour or
annual ambient air limit as set forth in Env-A 1450.01, Table
Containing the List Naming All Regulated Toxic Air
Pollutants.
Facility Wide Env-A 1400 Yes
2.
Revisions of the List of RTAPs
In accordance with RSA 125-I:5, IV, if DES revises the list of
RTAPs or their respective AALs or classifications under RSA
125-I:4, II and III, and as a result of such revision the Owner
or Operator is required to obtain or modify the permit under
the provisions of RSA 125-I or RSA 125-C, the Owner or
Operator shall have 90 days following publication of notice of
such final revision in the New Hampshire Rulemaking
Register to file a complete application for such permit or
permit modification.
Facility Wide RSA 125-I:5 IV Yes
Table 5, below lists the federally enforceable operational and emission limitations requirements
for the facility from TV-0027 and any deficiencies noted during the evaluation.
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
1.
Facility-Wide VOC Emission Limitation
The total VOC emissions from the Facility shall not exceed 48.5
tons per calendar year.
Facility Wide
Temporary
Permit
FP-T-0052
Yes
2.
Particulate Emission Standards
The maximum allowable particulate matter emission rate shall not
exceed the maximum allowable particulate matter emission rate as
calculated in a) or b) below:
A process weight rate up to 30 tons/hr: ( )67.005.5 PE ∗=
A process weight rate In excess of 30 tons/hr:
( ) 480.66 11.0−∗= PE
Where:
E = the maximum allowable particulate matter emission rate in
pounds per hour; and
P = the process weight rate in tons per hour.
EU01
Env-A
2102.04(b)
effective
11-24-2004
Unknown
Finding: Compliance with particulate matter emission standards can only be determined through stack testing for
particulate matter, which has not been required for these devices, to date.
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 7 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
3.
Visible Emission Standards
The average opacity shall not exceed 20 percent for any
continuous 6-minute period, except for one period of 6 continuous
minutes in any 60-minute period during startup, shutdown, or
malfunction.
EU01
Env-A
2103.02(a)
effective
11-24-2004
Unknown
Finding: Compliance with this permit condition was not determined as the facility was not operating EU01 during the on-
site portion of the compliance evaluation.
4.
Reinforced Plastic Composites Production Emission Limitation
All continuous lamination operations emitting less than 100 tpy of
HAP, and repair operations must meet the following requirements:
a) Reduce total organic HAP emissions by at least 58.5 weight
percent; or
b) Not exceed an organic HAP emissions limit of 15.7 lb of
organic HAP per ton of neat resin plus and neat gel coat plus.
EU01
40 CFR
63.5805(a)(2)
&
63.5805(g)
subpart WWWW
Yes
Finding: The facility has chosen to reduce the total organic HAP emissions by 58.5 % using a RTO. With this control
device, on June 20, 2007, Kalwall demonstrated a HAP removal efficiency of 98 % and on July 24 and 25, 2012, a HAP
removal efficiency of 95%.
5.
Compliance Options
a) Compliant line option - Demonstrate that each continuous
lamination line complies with the limitation specified in Table
5, Item 4; or
b) Add-on control device option - Where the Facility must meet
the emissions limitation specified in Table 5, Item 4.a) above,
the Facility has the option of demonstrating that
PCE01achieves 95% reduction of all wet-out area organic
HAP emissions.
EU01
40 CFR
63.5820(a) & (c)
subpart WWWW
Yes
Finding: See Table 5, Item #4.
General Compliance Requirements
a) Work Practice Standards –
1. Cleaning Operations – Must not use cleaning solvents that
contain HAP, except that styrene may be used as a cleaner
in closed systems, and organic HAP containing cleaners
may be used to clean cured resin from application
equipment;
2. HAP-containing Material Storage – Keep containers that
store HAP-containing material closed or covered except
during the addition or removal of materials. Bulk HAP-
containing material storage tanks may be vented as
necessary for safety.
EU01
40 CFR
63.5835(a)
subpart WWWW
6.
b) Add-on Control Device Compliance –
The Owner or Operator must be in compliance with the emission
limitations specified in Table 5, Item 4 that are met using an add-
on control device, except during startup, shutdown, or
malfunction.
PCE01
40 CFR
63.5835(b)
subpart WWWW
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 8 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
c) Operation and Maintenance - General Duty –
1. At all times, including periods of startup, shutdown, and
malfunction, the Owner or Operator must operate and
maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in
a manner consistent with safety and good air pollution
control practices for minimizing emissions;
2. During a period of startup, shutdown or malfunction, the
Owner or Operator has a general duty to minimize
emissions from the affected source to the greatest extent,
which is consistent with safety and good air pollution
control practices;
3. The general duty to minimize emissions during a period
of startup, shutdown or malfunction does not require the
Owner or Operator to achieve the emission levels in
Table 5, Item 4 at other times if this is not consistent
with safety and good air pollution control practices, nor
does it require the Owner or Operator to further reduce
emissions if levels required in Table 5, Item 4 have been
achieved.
EU01
40 CFR
63.5835(c)
subpart WWWW
&
63.6(e)(1)(i)
subpart A
d) Startup, Shutdown and Malfunction Plan (“SSMP”) –
1. The Owner or Operator shall develop and implement a
written SSMP that describes in detail the following:
i) Procedures for operating and maintaining the
source during periods of startup, shutdown, and
malfunction;
ii) A program of corrective action for malfunctioning
process, air pollution control, and monitoring
equipment used to comply with the emission
limitations specified in Table 5, Item 4;
2. The Owner or operator may use the Facility’s
standard operating procedures (SOP) manual, or an
Occupational Safety and Health Administration or other
plan, provided the alternative plans meet all the
requirements of 40 CFR 63.1111(a), and are made
available for inspection upon request;
6.
cont
3. Periodic revisions to the SSMP may be made as
necessary to reflect changes in equipment or procedures
without prior approval of the Division; and
4. The Owner or Operator must revise the SSMP
within 45 days after an event if the event meets the
characteristics of a malfunction, and the plan fails to
address, or inadequately addresses the malfunction, and
was not included in the SSMP at the time the plan was
developed. The revision must include detailed
procedures for operating and maintaining the source
during similar malfunction events and a program of
corrective action for similar malfunctions of process or
air pollution control and monitoring equipment.
EU01
&
PCE01
40 CFR
63.5835(d)
subpart WWWW
&
63.6(e)(3)
subpart A
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 9 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
7.
Equipment and Operating Requirements
The Owner or Operator shall operate PCE01 at all times emissions
from EU01 are vented to it.
PCE01
40 CFR
63.988(a)(2)
subpart SS
Yes
Closed Vent System
Except for closed vent systems operated and maintained under
negative pressure, these provisions apply to the closed vent
system:
a) Equipment and Operating Requirements:
1. Collection of Emissions: Each closed vent system shall
be designed and operated to collect the regulated
material vapors from the emission point, and to route
the collected vapors to PCE01;
2. Period of Operation: Closed vent system shall be
operated at all times when emissions are vented to or
collected by them;
3. Bypass Monitoring: Except for equipment needed for
safety purposes such as pressure relief devices, low leg
drains, high point bleeds, analyzer vents, and open-
ended valves or lines, the Owner or Operator shall
secure the bypass line valve in the non-diverting
position with a car-seal type configuration or a lock-
and-key type configuration.
40 CFR
63.983(a) subpart
SS
b) Leak Repair Provisions:
1. If there are visible, audible, or olfactory indications of
leaks in the closed vent system, at the time of the
annual visual inspection required in Table 6, Item 7:
Eliminate the leak; or
Monitor the closed-vent equipment according to the
procedures in Table 6, Item 7;
40 CFR
63.983(d)
subpart SS
2. Leaks, as indicated by an instrument reading greater
than 500 parts per million by volume above
background or by visual inspections, shall be repaired
as soon as practical, except as provided in 3) below:
i. A first attempt at repair shall be made no later
than 5 days after the leak is detected; and
ii. Repairs shall be completed no later than 15 days
after the leak is detected or at the beginning of
the next introduction of vapors to the system,
whichever is later;
8.
3. Delay of repair of a closed vent system for which leaks
have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible or
unsafe without a closed vent system shutdown, or if the
Owner or Operator determines that emissions resulting
from immediate repair would be greater than the
emissions likely to result from delay of repair. Repair
of such equipment shall be completed as soon as
practical, but not later than the end of the next closed
vent system shutdown.
EU01
&
PCE01
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 10 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
9.
Operation of the Continuous Parameter Monitoring Systems
(CPMS)
a) Except for system breakdowns, repairs, maintenance periods,
instrument adjustments, or checks to maintain precision and
accuracy, calibration checks, and zero and span adjustments,
the CPMS shall be in continuous operation when emissions
are being routed to PCE01;
b) Data recorded during monitoring malfunctions, associated
repairs, and required quality assurance or control activities,
including data averages and calculations or fulfilling a
minimum data availability requirement, may not be used;
c) At all times, maintain necessary parts for routine repairs of
the monitoring equipment;
d) Maintain, calibrate, and operate the CPMS [PCE01
combustion temperature monitor] according to manufacturer’s
specifications or other written procedures that provide
adequate assurance that the equipment would reasonable be
expected to monitor accurately;
e) Maintain and operate the CPMS in a manner consistent with
good air pollution control practices and ensure the immediate
repair of replacement of CPMS parts to correct “routine” or
otherwise predictable CPMS malfunctions, and the necessary
parts for routine repairs of the affected equipment shall be
readily available;
f) Develop and implement a CPMS quality control program. At
a minimum the written protocol shall include the following
operations:
1) Initial and any subsequent calibration of the CPMS;
2) Preventive maintenance of the CPMS including spare
parts inventory;
3) Data recording, calculations and reporting;
4) Accuracy audit procedures; and
5) Program of corrective action for a malfunction of the
CPMS;
EU01
&
PCE01
40 CFR
63.5895(b)
subpart
WWWW,
63.996(c) subpart
SS
&
40 CFR 63.8(d)
subpart A
Yes
10.
Pollution Control Equipment Operation and Maintenance
a) Operate and maintain PCE01 per the manufacturers’
recommendations to control the emissions from the wet-out
area associated with EU01 to minimize emissions and to meet
the requirements of Table 5, Item 4.
b) The combustion chamber temperature shall be maintained at a
temperature not below the minimum operating temperature
determined during the most recent performance stack test as
required in Table 6, Item 3, based on a 15 minute block
average;
c) At a minimum, PCE01 shall be subject to annual inspection
according to the requirements in Table 6, Item 12.
PCE01 Env-A 604.01 Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 11 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
11.
Pollution Control Equipment Operation and Maintenance
a) Calibrate, operate and maintain a temperature monitoring
device located in the fire box or in the ductwork immediately
downstream of the fire box of PCE01;
b) The temperature monitoring device shall:
1) Have a minimum accuracy of ±1 percent of the
temperature being monitored expressed in degrees
Celsius (°C) or ±1.2 °C, whichever is greater; and
2) Provide a continuous temperature record;
c) Calibrate, operate and maintain a flow or pressure differential
gauge in the capture device vent at the wet-out area of EU01
leading to PCE01; and
d) The flow or pressure drop in the process vents leading to
PCE01 from the wet-out area shall be maintained within the
range determined during performance testing required in
Table 6, Item 3.
EU01 &
PCE01
Env-A 604.01
&
40 CFR
63.988(c),
63.981 subpart
SS
&
63.5875 subpart
WWWW
No
Finding: Kalwall did not maintain a flow or differential pressure gauge at the wet-out area of EU01.
12.
Accidental Release Program Requirements
The quantities of regulated chemicals stored at the facility are less
than the applicable threshold quantities established in 40 CFR
68.130. The facility is subject to the Purpose and General Duty
clause of the 1990 Clean Air Act, Section 112(r)(1). General
Duty includes the following responsibilities:
a) Identify potential hazards which result from such releases
using appropriate hazard assessment techniques;
b) Design and maintain a safe facility;
c) Take steps necessary to prevent releases; and
d) Minimize the consequences of accidental releases that do
occur
Facility-
Wide CAAA 112(r)(1) Yes
13.
Permit Deviation
In the event of a permit deviation, the Owner or Operator of the
affected device, process, or air pollution control equipment shall
investigate and take corrective action immediately upon discovery
of the permit deviation to restore the affected device, process, or
air pollution control equipment to within allowable permit levels.
Facility Wide Env-A 911.03 Yes
14.
Sulfur Content Limitations for Liquid Fuels
The sulfur content of No 2 fuel oil and diesel fuel shall not exceed
0.4 percent sulfur by weight.
EU02
40 CFR 52
&
Env-A 402.03
(SIP approved)
Yes
15.
Fire Pump Engine
The fire pump engine shall only operate during normal
maintenance and testing as recommended by the manufacturer,
and to operate the sprinklers in the case of a fire incident at the
facility.
EU02
Env-A 1302.15
(effective 10-31-
2010; formerly
Env-A
1211.02(o))
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 12 of 37
Table 5- Federally Enforceable Operational and Emission Limitations
Item
# Applicable Requirement
Applicable
Emission
Unit
Regulatory
Citation Compliant
16.
Fire Pump Engine Operating Requirements
After May 2, 2013, the engine shall be operated as follows:
a) Change oil and filter annually;
b) Inspect air cleaner annually;
c) Inspect hoses and belts annually;
d) Minimize idle time during startup and minimize startup time
to a period needed for appropriate and safe loading, not to
exceed 30 minutes; and
e) Operate and maintain the engine according to the
manufacturer’s emission-related operation and maintenance
instructions.
EU02 40 CFR 63.6603
subpart ZZZZ Yes
17.
Emergency Engines Manufactured Prior to June 12, 2006
The emergency engine shall be limited to 500 hours of operation
during any consecutive 12-month period.
Beginning May 3, 2013, the fire pump engine, in addition to the
above limitation, shall be limited as detailed in 40 CFR
63.6640(f)(1)(ii) and (iii).
EU02
40 CFR 63.6640
subpart ZZZZ &
Env-A
1301.02(j)(1)
Yes
Visible Emissions Standard for Fuel Burning Devices Installed
After May 13, 1970
a) The Owner or Operator shall not cause or allow average
opacity from fuel burning devices installed after May 13,
1970 in excess of 20% for any continuous 6-minute period.
Env-A 2002.02
18.
b) The average opacity shall be allowed to be in excess of those
standards specified in a) above for one period of 6 continuous
minutes in any 60-minute period during startup, shutdown, or
malfunction.
EU02
Env-A
2002.04(c)
Unknown
Finding: DES could not verify this permit condition since at the time of the on-site inspection, EU02 was not operating.
19.
Particulate Emission Standards for Fuel Burning Devices
Installed On or After January 1, 1985
The Owner or Operator shall not cause or allow emissions of
particulate matter from fuel burning devices installed on or after
January 1, 1985, to exceed 0.3lb/MMBtu.
EU02 Env-A
2002.08(c)(1) Unknown
Finding: Compliance with particulate matter emission standards can only be determined through stack testing, which has
not been required for this device, to date.
20.
Sulfur Content Limitations for Gaseous Fuels
Gaseous fuel shall contain no more than 5 grains per 100 cubic
feet of sulfur, calculated as H2S at standard conditions.
Facility Wide
40 CFR 52
&
Env-A 402.03
(SIP approved)
Yes
Finding: Kalwall maintains documentation from the fuel supplier that the sulfur content of the propane, as delivered,
does not exceed state or federal standards for the fuel.
21.
Permanent Total Enclosure
a) Install, operate and maintain a gauge to monitor the building
static pressure to assure that the building is maintained as a
permanent total enclosure for the capture of HAP emissions;
and
b) The static pressure of the building shall be greater than or
equal to 0.007 inches of water to demonstrate compliance
with the permanent total enclosure requirements.
EU01 &
PCE01 Env-A 604.01 Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 13 of 37
VI. Compliance with Monitoring and Testing Requirements
Table 6, below lists the testing and monitoring requirements for the facility from TV-0027 and
any deficiencies noted during the evaluation.
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
1. To be
determined
When conditions warrant, the Division may require
the Owner or Operator to conduct stack testing in
accordance with USEPA or other Division approved
methods.
Upon
request by
the Division
Facility
Wide
RSA 125-C:6,
XI Yes
Finding: The facility has conducted stack testing in July 2012. See Table 5, Item #4.
2.
Sulfur
Content of
Liquid
Fuels
Conduct testing in accordance with appropriate
ASTM test methods or retain delivery tickets in
accordance with Table 7, Item 9 in order to
demonstrate compliance with the sulfur content
limitation provisions specified in this permit for
liquid fuels.
For each
delivery of
fuel oil to
the facility
Facility
Wide
Env-A 806.02 &
Env-A 806.05
(effective
10-31-2010)
Yes
a) Performance testing to evaluate compliance
with the emission reduction requirements
specified in Table 5, Item 4 shall be planned
and carried out in accordance with the following
schedule:
1). A pre-test protocol shall be submitted to
the Division at least 30 days prior to the
commencement of testing, and contain the
information required pursuant to Env-A
802.04;
2). The Divisions shall require rescheduling
of any compliance stack test if the staff
necessary to observe the test is not
available; and
3). The Owner or Operator and any contractor
retained by the Owner or Operator to
conduct the test shall meet with a Division
representative at least 15 days prior to the
test date to finalize the details of the
testing.
40 CFR 63.5845
subpart
WWWW,
63.988
subpart SS
&
Env-A 802
(effective
10-31-2010)
b) The compliance test shall not be conducted
during periods of startup, shutdown or
malfunction.
40 CFR
63.5850(d)
subpart
WWWW
3.
HAP
Emissions
Testing
Within 5
years of the
last
performance
stack test
EU01 &
PCE01 Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 14 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
c) The following test methods, or Division
approved alternatives, shall be used:
1). USEPA Methods 1-4 for volumetric flow
rate, percentage of oxygen, carbon
dioxide and moisture;
2). USEPA Method 25A for total gaseous
organic emissions at the inlet and outlet to
PCE01 to determine HAP destruction
efficiency;
3). A temporary total enclosure must be
constructed and verified for the wet out
area using USEPA Method 204 of
appendix M of 40 CFR part 51 and
capture efficiency testing must be
determined using USEPA Method 204B
through E of Appendix M of 40 CFR part
51 for a duration of at lease 3 hours per
test run; and
4). Measure the mass flow rates of the
organic HAP in the exhaust streams going
to the atmosphere and to the control
device from the wet out area.
40 CFR
63.5850(e)
subpart
WWWW
63.997(e)(2)
subpart SS
&
Env-A 802
40 CFR 63.5875
&
63.5850(a)
subpart
WWWW
d) The performance test shall be conducted at
maximum representative operating conditions
for the process
40 CFR
63.997(e)(1)(i)
subpart SS
e) The performance test must consist of three runs:
1). Each sampling run must last at least one
hour;
2). For grab sampling, a minimum of four
grab samples must be taken at
approximately equal intervals during the
sampling run;
3). Each run must represent normal
production conditions; and
4). Each run must represent maximum
potential emissions with respect to the
organic HAP content of the materials
being applied and the material application
rates;
40 CFR
63.5850(f)
subpart
WWWW
63.998(a)(2)(ii)
&
63.997(e)(2)
subpart SS
f) During the test monitor and record the amounts
of production resin applied inside the enclosure
that is vented to PCE01:.
40 CFR
63.5850(h)
subpart
WWWW
3.
cont
HAP
Emissions
Testing
g) Record the flow or pressure differential [∆P]
measured at the wet-out area of EU01 every 15
minutes during the performance test;
Within 5
years of the
last
performance
stack test
EU01 &
PCE01
40 CFR
70.6(a)(3)
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 15 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
h) The CPMS [PCE01 temperature monitor] shall
be operational and the data verified either prior
to or in conjunction with the performance
testing; and
40 CFR
63.996(c)(3)
subpart SS
i) Record the combustion chamber temperature
averaged over the full period of the performance
test.
40 CFR
63.998(a)(2)(ii)
subpart SS
Finding; Kalwall conducted testing in 2007 and 2012. See Table 5, Item #4.
HAP concentrations shall be calculated as follows:
a) Concentration of either TOC [minus methane
and ethane] or total organic regulated material
shall be calculated using Equation 1:
∑∑
=
==
x
i
n
j
ji
TOCX
C
C1
1 [Eq 1]
Where:
CTOC = concentration of TOC minus methane and
ethane, dry basis, in parts per million by volume
[ppmv];
x = number of samples in the sample run;
n = number of components in the sample;
Cji = concentration of sample components j of
sample i dry basis [ppmv]; 4.
HAP
Emissions
Testing b) Correction of TOC or total organic regulated
species shall be corrected to three percent
oxygen if supplemental combustion air is used
to combust the emissions, using Equation 2:
−=
d
mTOCO
CC2%9.20
9.17 [Eq 2]
Where:
CTOC = concentration of TOC or organic regulated
material corrected to 3% O2, dry basis [ppmv];
Cm = concentration of TOC [minus methane and
ethane] or organic regulated material, dry basis
[ppmv];
%O2d = concentration of oxygen, dry basis, [% by
volume];
Each
emissions
performance
test
EU01 &
PCE01
40 CFR
63.997(e)(2) (iii)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 16 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
5. HAP
Emissions
Calculate percent reduction as follows – use
Equation 3:
( ) ( )
( )100×
+++
+−+=
uciuci
cococici
OOWAEWAE
OWAEOWAEPR [Eq 3]
Where:
PR = percent reduction
WAEci = wet-out area organic HAP emissions
vented to PCE01 [lb/yr];
Oci = oven organic HAP emissions vented to
PCE01 [lb/yr];
WAEu = wet-out area organic HAP emissions not
controlled [lb/yr];
Ou = oven organic HAP emissions not controlled,
[lb/yr];
WAEco = wet-out area organic HAP emissions
from PCE01 outlet [lb/yr]; and
Oco = oven organic HAP emissions from PCE01
outlet [lb/yr]Error! Bookmark not defined.
;
Annually EU01
40 CFR
63.5885(a)
subpart
WWWW
Yes
6. HAP
Emissions
Calculate an organic HAP emissions factor – use
Equation 4 below:
( )GR
OOWAEWAEE cucu
+
+++= [Eq 4]
Where:
E = HAP emissions factor of resin and gel coat,
[lb/ton];
WAEu = uncontrolled wet-out area organic HAP
emissions, [lb/yr];
WAEc = controlled wet-out area organic HAP
emissions, [lb/yr];
Ou = uncontrolled oven organic HAP emissions,
[lbyr];
Oc = controlled oven organic HAP emissions,
[lb/yr]
R = total usage of neat resin plus, tpy; and
G = total usage of gel coat plus, tpy
Annually EU01
40 CFR
63.5890(a)
subpart
WWWW
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 17 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
7.
Closed
Vent
System
Inspection
Except for any closed vent systems that are
designated as unsafe or difficult to inspect by the
Owner or Operator, the closed vent system
constructed of duct work shall be inspected as
follows:
a) Closed vent system inspections shall be
conducted according to USEPA Method 21 of
40 CFR part 60, appendix A;
b) The detection instrument shall meet the
performance criteria of Method 21 of 40 CFR
part 60, appendix A, except the instrument
response factor criteria in §3.1.2(a) of Method
21 must be for the representative composition of
the process fluid and not of each individual
VOC in the stream. For process streams that
contain nitrogen, air, water or other inerts that
are not organic HAP or VOC, the representative
stream response factor must be determined on
an inert-free basis. The response factor may be
determined at any concentration for which the
monitoring for leaks will be conducted;
c) If no instrument is available at the plant site that
will meet the performance criteria of Method 21
specified in Table 6, Item 7.b) above, the
instrument readings may be adjusted by
multiplying by the representative response
factor of the process fluid, calculated on an
inert-free basis as described in Table 6, Item
7.b) above;
d) The detection instrument shall be calibrated
before use on each day of its use by the
procedures specified in Method 21;
Annually EU01 &
PCE01
40 CFR
63.5895(a) &
(b) subpart
WWWW
63.983(b)(1)(ii)
&
63.983(c)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 18 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
7.
cont
Closed
Vent
System
Inspection
e) Calibration gases shall be as follows:
1). Zero air [less than 10 ppmv hydrocarbon
in air];
2). Mixtures of methane in air at a
concentration less than 10,000 ppmv. A
calibration gas other than methane in air
may be used if the instrument does not
respond to methane or if the instrument
does not meet the performance criteria
specified in Table 6, Item 7.b) above. In
such cases, the calibration gas may be a
mixture of one or more of the compounds
to be measured in air;
3). If the detection instrument’s design
allows for multiple calibration scales,
then the lower scale shall be calibrated
with a calibration gas that is no higher
than 2,500ppmv;
f) The owner or operator may elect to adjust or not
adjust instrument reading for background. If an
owner or operator elects not to adjust readings
for background, all such instrument readings
shall be compared directly to 500ppmv to
determine whether there is a leak. If an owner
or operator elects to adjust instrument readings
for background, the owner or operator shall
measure background concentration using the
procedures in g) and h) below. The owner or
operator shall subtract the background reading
from the maximum concentration indicated by
the instrument;
g) If the owner or operator elects to adjust for
background, the arithmetic difference between
the maximum concentration indicted by the
instrument and the background level shall be
compared with 500 ppmv for determining
whether there is a leak;
h) To adjust for background, the arithmetic
difference between the maximum concentration
indicated by the instrument and the background
level shall be compared with 500 ppmv for
determining whether there is a leak;
i) The instrument probe shall be traversed around
all potential leak interfaces as described in
Method 21;
j) Inspections shall be performed when the process
equipment is in normal operation or in use with
any other detectable gas or vapor.
Annually EU01 &
PCE01
40 CFR
63.5895(a) &
(b) subpart
WWWW
&
63.983(c)
subpart SS
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 19 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
8.
Closed
Vent
System
Inspection
Any parts of the closed vent systems that are
designated as unsafe to inspect as described in Table
7, Item 16.a) and b) are exempt from the inspection
requirements of Table 6, Item 7 if as follows:
a) If the equipment is determined to be unsafe-to-
inspect because the inspecting personnel would
be exposed to an imminent or potential danger
as a consequence of complying with Table 6,
Item 7;
b) A written plan is in place that requires
inspection of the equipment as frequently as
practical during safe-to-inspect times;
c) If the equipment is determined to be difficult-to-
inspect, and the equipment cannot be inspected
without elevating the inspecting personnel more
than 7 feet [2 meters] above the support surface;
and
d) A written plan requires inspection of the
difficult-to-inspect equipment at least once
every 5 years.
Annually EU01 &
PCE01
40 CFR
63.983(b)(2)
subpart SS
Yes
9.
Continuous
Compli-
ance
Monitoring data shall be collected as follows:
a) Conduct all monitoring required in Table 6,
Items 10, 11 and 13.a) in continuous operation
(or collect data at all required intervals) at all
times that the affected source is operating,
except for monitoring malfunctions, associated
repairs, and required quality assurance or
control activities (including, as applicable,
calibration checks and required zero and span
adjustments); and
b) Data recorded during monitoring malfunctions,
associated repairs, and required quality
assurance or control activities, including data
averages and calculations, or fulfilling a
minimum data availability requirement, may not
be used.
Continu-
ously
EU01
&
PCE01
40 CFR
63.5895(b)
subpart
WWWW
No
Finding: The facility did not conduct the monitoring requirements of Table 6, Item 13.a.
10.
By-pass
Vent
Monitoring
For the by-pass line, visually inspect the seal or
closure mechanism at least once every month to
verify that the valve is maintained in the non-
diverting position, and the vent stream is not
diverted through the by-pass line.
Monthly
EU01
&
PCE01
40 CFR
63.983(b)(4)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 20 of 37
Table 6 – Monitoring/Testing Requirements
Item
# Parameter Method of Compliance Frequency
Applicable
Emission
Unit
Regulatory
Basis Compliant
Thermal
Oxidizer
Combus-
tion
Temper-
ature
a) Monitor and record the temperature in the
combustion chamber; Continuous
11.
b) If the block average temperature reading is less
than the minimum specified in Table 5, Item
10.b), then inspect the unit and take corrective
action to raise the temperature.
As noted by
the manufac-
turer
PCE01 Env-A 906 Yes
Conduct a visual external integrity inspection of the
thermal oxidizer which shall:
a) Include an evaluation of whether all emissions
are being vented through the dedicated stack
exit; and
b) Be conducted by plant personnel familiar with
the operation of the oxidizer and associated
equipment.
Annually
and as
conditions
indicate an
inspection is
warranted 12.
Thermal
Oxidizer
Inspection
c) The CPMS [i.e. temperature monitor] located in
the combustion zone of PCE01 shall be
maintained and calibrated according to
manufacturer’s specifications.
As noted by
the
manufacture
r
PCE01 RSA 125-C:6,
XI Yes
a) Monitor and record the flow or pressure
differential reading at the wet-out area; and
Once per
day
40 CFR
70.6(a)(3)
13. Wet-out
Area b) The flow meters and/or pressure gauges shall be
maintained and calibrated according to the
manufacturer’s specifications.
As noted by
the
manufacture
r
EU01 RSA 125-C:6,
XI
No
Finding: The facility has not been monitoring and recording flow or pressure differential at the wet-out area.
14. Hours of
Operation
The fire pump engine shall be equipped with a
non-resettable hour meter. Continuous EU02
40 CFR
63.6625
subpart ZZZZ
Yes
15.
Sulfur content
of gaseous
fuels
Conduct testing to determine the sulfur content in
grains of sulfur per 100 cubic feet of gaseous
fuel.
Upon written
request by
EPA or the
Division
Facility
wide
Env-A 806.03
(effective
10-31-2010)
Not
Applicable
Finding: The facility has not been requested to conduct testing to determine the sulfur content of the gaseous fuel.
a) Monitor and record the static pressure
reading; and Once per day
16.
Total
enclosure
monitoring b) The gauge shall be maintained and
calibrated according to the manufacturer’s
specifications
As noted by
the
manufacturer
Facility
wide
RSA 125-C:6,
XI Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 21 of 37
VII. Compliance with Recordkeeping Requirements
Table 7, below lists the recordkeeping requirements for the facility from TV-0027 and any
deficiencies noted during the evaluation.
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
1.
The Owner or Operator shall retain records of all
required monitoring data, recordkeeping and
reporting requirements, and support information
for a period of at least 5 years from the date of
origination.
Retain for a
minimum of 5 years Facility Wide
40 CFR
70.6(a)(3)(ii)
(B)
Yes
2.
Regulated Toxic Air Pollutants
Maintain records documenting compliance with
Env-A 1400.
Compliance was demonstrated at the time of
permit issuance as described in the Application
Review Summary prepared by the Division for
permit application 10-0134. The compliance
demonstration must be updated if:
a) There is a revision to the list of RTAPs
lowering the AAL for any RTAP emitted at
the facility;
b) The amount of any RTAP emitted is greater
than the amount that was evaluated in the
Application Review Summary (e.g., use of a
resin will increase);
c) An RTAP that was not evaluated in the
Application Review Summary will be emitted
(e.g., a new resin will be used); and
d) Stack conditions (e.g. air flow rate) change.
Update prior to
process changes and
within 90 days of
each revision of
Env-A 1400
Facility Wide
Env-A 902.01
(State-Only
Enforceable)
Yes
3.
Additional Recordkeeping Requirements -
Facility-wide Emission Limitations
Maintain a 12-month running total of Facility-
wide emissions of VOCs, which shall include
emissions from non-permitted devices, for the
purpose of demonstrating that the total emissions
of these pollutants are below the threshold
specified in Table 5, Item 1.
Monthly Facility Wide
Env-A 906
(effective
4-23-1999)
No
Finding: At the time of the inspection, Kalwall was not maintaining a 12-month running total of facility-wide emissions of VOCs.
However, since the time of the inspection, Kalwall generated a spreadsheet to maintain this running total.
4.
Recordkeeping of deviations from Permit
requirements shall be conducted in accordance
with Section XXVIII of this Permit.
Maintain up-to-date
data Facility Wide
Env-A 911
(effective
4-21-2007)
Yes
5.
Maintain records of actual emissions for each
significant and insignificant activity for
determination of emission based fees.
Annually Facility Wide Env-A 705.03 Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 22 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
VOC Recordkeeping Requirements
Record and maintain the following information:
a) Identification of each VOC-emitting process
or device except:
1). Process or devices associated
exclusively with non-core activities;
and
2). Processes or devices emitting only
exempt VOCs;
b) Operating schedule for each VOC-emitting
device/process identified in a) above,
including:
1). Days of operation per calendar week
during the normal operating schedule;
2). Hours of operation per calendar day
during the normal operating schedule
and for a typical high ozone season
day, if different from the normal
operating schedule; and
3). Hours of operation per year under
normal operating conditions;
6.
c) VOC emission data from all VOC-emitting
process/device identified in a) above,
including:
1). Actual VOC emissions for the calendar
year, in tons; and a typical high ozone
season day during that calendar year, in
pounds per day; and
2). The emissions factors and the origin of
the emission factors used to calculate
the VOC emissions
On a continuous
basis Facility Wide
Env-A 901.06
(SIP
Approved)
Not
Applicable
Finding: During the inspection period, VOC emissions have not met or exceeded 10 tpy.
7.
General Recordkeeping Requirements for Process
Operations
Maintain records regarding process operations
including the following information for each
process/device:
a) Monthly hours of operation;
b) Quantity of raw materials used per month;
and
c) Distribution of the process discharges if the
process discharges air pollutants through
more than one discharge point.
Monthly EU01
Env-A 901.04
(SIP
Approved)
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 23 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
8.
General Recordkeeping Requirements for
Combustion Devices
Maintain the following records of fuel
characteristics and utilization for the fuel used in
the combustion device:
a) Type (e.g. diesel fuel) and amount of fuel
burned in each device, or type of each fuel
burned in multiple devices and hours of
operation of each device to be used to
apportion fuel use between the multiple
devices;
b) Sulfur content of liquid fuel in terms of
percent sulfur by weight.
Monthly EU02
Env-A 903.03
(effective
10-21-2003)
&
FP-T-0052
Yes
9.
Liquid Fuel Oil Recordkeeping Requirements
A written statement from the fuel supplier that the
sulfur content of the fuel as delivered does not
exceed state or federal standards for that fuel.
Whenever there is a
change in fuel
supplier by at least
annually
EU02
Env-A 806.05
(effective
10-31-2010)
Yes
Reinforced Plastic Composites Production
Recordkeeping Requirements
Records of the following information:
a) A copy of each notification and report that
was submitted to the Division and the
documentation supporting each notification
and report;
10.
b) Performance tests as required in Table 6,
Item 3;
c) All data, assumptions and calculations used
to determine organic HAP emissions factors
or average organic HAP contents for EU01;
d) Certified statement that you are in
compliance with the work practice standards
required in Table 5, Item 6.)a);
e) When complying with the percent reduction
and/or lb/ton requirements specified in Table
5, Item 4:
Continuously EU01
40 CFR
63.5915
subpart
WWWW
&
63.10(b)
subpart A
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 24 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
1). Keep all data, assumptions, and
calculations used to determine percent
reduction and/or lb/ton as applicable;
2). Keep a brief description of the
rationale for the assignment of an
equation or factor to each formula;
3). When using facility-specific organic
HAP estimation equations, or factors,
you must keep all data, assumptions,
and calculations used to derive the
organic HAP emissions estimation
equations and factors and identification
and rational for the worst-case formula;
and
4). For all organic HAP emissions
estimation equations and organic HAP
emissions factors, you must keep
documentation that the appropriate
permitting authority has approved
them.
40 CFR
63.5915(e)
subpart
WWWW
f) Determine how much neat resin plus and neat
gel coat plus is applied to the line each year:
1). Track formula usage by end
product/thickness combinations;
2). Use in-house records to show usage.
This may be either from automated
systems or manual records;
3). Daily usage of each formula/end
product combination on each line,
recorded at the end of each run (i.e.,
when a changeover in formulation or
product is made), and at the end of the
shift;
4). Sum the amounts from the daily
records collected according to 3) above
to calculate annual usage of each
formula/end product combination by
line;
5). Resin and gel coat use, which may be
based on purchase records if the Owner
or Operator can reasonably estimate
how the resin is applied;
40 CFR
63.5880
&
63.5915(c)
subpart
WWWW
10
cont.
g) Organic HAP content, which may be based
on MSDS or on resin specifications supplied
by the resin supplier; and
h) The operation where the resin is used if you
are meeting any organic HAP emissions
limits based on an organic HAP emissions
limit in Table 5, Item 4.
Continuously EU01
40 CFR
63.5900(c)
subpart
WWWW
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 25 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
CPMS Recordkeeping Requirements
Keep the following records for the continuous
monitoring systems (CPMS):
a) All required CPMS measurements, including
monitoring data recorded during unavoidable
CPMS breakdowns and out-of-control
periods;
b) The date and time identifying each period
during which the CPMS was inoperative
except for zero (low-level) and high-level
checks;
c) The date and time identifying each period
during which the CPMS was out of control;
11.
d) The specific identification (i.e., the date and
time of commencement and completion) of
each period of excess emissions and
parameter monitoring exceedances, that
occurs during startups, shutdowns, and
malfunctions;
e) The nature and cause of any malfunction;
f) The corrective action taken or preventative
measures adopted;
g) The nature of the repairs or adjustments to
the CPMS that was inoperative or out of
control;
h) The total process operating time during the
reporting period; and
i) All procedures that are part of a quality
control program developed and implemented
for the CPMS under Table 5, Item 9.
Continuously PCE01
40 CFR
63.10(c)
subpart A
&
63.998(d)(5)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 26 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
Continuous Records and Monitoring System Data
Handling
a) CPMS combustion temperature of PCE01 as
follows:
1). Values measured at least once every 15
minutes or each measured value for
systems which measure more
frequently than once every 15 minutes;
or
2). Block average values for 15-minute or
shorter periods calculated from all
measured data values during each
period or from at least one measured
data value per minute if measured more
frequently than once per minute.
3). Where data is collected from an
automated CPMS, the Owner or
Operator may calculate and retain
block hourly average values from each
15-minute block average period or
from at least one measured value per
minute if measured more frequently
than once per minute, and discard all
but the most recent three valid hours of
continuous (15-minute or shorter)
records, if the hourly averages do not
exclude periods of CPMS breakdown
or malfunction. An automated CPMS
records that measured data and
calculates the hourly averages through
the use of a computerized data
acquisition system.
12.
b) Excluded CPMS data identified below shall
not be included in any average computed to
determine compliance with an emission limit:
1). Monitoring system breakdowns,
repairs, preventive maintenance,
calibration checks, and zero (low-level)
and high-level adjustments;
2). Periods of non-operation of the wet out
area for EU01and PCE01;
3). Startups, shutdowns, and malfunctions,
if the Owner or Operator operates the
source during such periods in
accordance with Table 5, Item 6 and
maintains the records in Table 7, Item
13 below.
Continuously PCE01
40 CFR
63.998(b)(1)
subpart SS
40 CFR
63.998(b)(2)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 27 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
12
cont.
c) Records of daily averages for the combustion
temperature of PCE01 shall:
1). Be calculated from data meeting the
requirements of Table 7, Item 12.a)
and b) above for each operating day;
2). Cover a 24-hour period if operation is
continuous, or the period of operation
per operating day if operation is not
continuous;
3). If all recorded values are greater than
or equal to the temperature in Table 5,
Item 10.b), the Owner or Operator may
record that all values were in
compliance rather than calculating and
recording a daily average for that
operating day, and must retain the
recorded values.
13.
Startup, Shutdown and Malfunction
Recordkeeping Requirements
Keep the following records related to startup,
shutdown, and malfunction:
a) Keep records of each startup, shutdown
and/or malfunction event if the procedures in
the SSMP were followed, including the
occurrence and duration of each startup,
shutdown or malfunction for the air pollution
control equipment;
b) Record the actions taken if an action taken
during a startup, shutdown, or malfunction
(including an action taken to correct a
malfunction) is not consistent with the
procedures specified in the SSMP, and the
source exceeds the applicable emission
limitation specified in Table 5, Item 4; and
c) Keep the written SSMP on record after it is
developed to be made available for inspection
upon request, for the life of the affected
source; and
d) If the SSMP is revised, previous versions of
the SSMP shall be kept for a period of 5
years and be made available for inspection
upon request.
Continuously
EU01
&
PCE01
40 CFR
63.5915(a)
subpart
WWWW,
63.998(d)(3)
subpart SS
&
63.6(e)(3)
subpart A
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 28 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
14.
Additional Recordkeeping Requirements -
Pollution Control Equipment
Maintain records of all air pollution control
equipment activities required in Table 6,
including:
a) Pressure differential and/or flow
measurements at the wet out area;
b) Air pollution control equipment inspection
and maintenance activities including
calibration and validation checks as specified
by the manufacturer; and
c) Corrective actions.
As specified in
Table 6 EU01 & PCE01
Env-A 906
&
40 CFR
63.998(b)(1)
subpart SS
No
Finding: Kalwall did not maintain pressure differential and/or flow measurements at the wet out area.
15.
Add-on Pollution Control Equipment
The Owner or Operator of any stationary source
or device with add-on VOC control equipment
shall maintain the following information:
a) The air pollution control device identification
number, type, model number, and
manufacturer;
b) Installation date;
c) Processes or devices controlled;
d) The type and location of the capture system,
capture efficiency percentage, and method of
determining capture efficiency;
e) Information as to whether or not the control
device is always in operation when the
processes or devices are in operation;
f) Pressure differential and/or flow
measurements for each capture
device/enclosure;
g) The destruction or removal efficiency of the
add-on pollution control equipment,
including:
1). Destruction or removal efficiency, in
percent;
2). Date tested;
3). The emission test results, including:
i) The inlet VOC concentration in
ppm;
ii) The outlet VOC concentration in
ppm; and
iii) The method of determination of
the inlet and outlet concentrations
in i) and ii) above; and
iv) The design combustion
temperature in °C.
Continuously
EU01
&
PCE01
Env-A 904.07
(SIP
Approved)
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 29 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
Closed Vent System Recordkeeping
a) The identification of all parts of the closed
vent system that are designated as unsafe or
difficult to inspect;
b) An explanation of why the equipment is
unsafe or difficult to inspect;
c) The plan for inspecting the equipment
required in Table 6, Item 7;
d) Leak inspections as required in Table 6, Item
7, record the following:
1). The date of the inspection; and
2). A statement that no leaks were
detected, if no leaks are detected,;
16.
e) When a leak is detected record the following:
1). The instrument and the equipment
identification number and the operator
name, initials or identification number;
2). The date the leak was detected and the
date of the first attempt to repair the
leak;
3). The date of successful repair of the
leak;
4). The maximum instrument reading
measured by the procedures in Table 6,
Item 7; after the leak is successfully
repaired or determined to be non-
repairable; and
5). “Repair delayed” and the reason for the
delay if a leak is not repaired within 15
days after discovery of the leak;
Continuously
EU01
&
PCE01
40 CFR
63.998(d)(1)
subpart SS
Yes
17.
By-pass system Recordkeeping:
a) Hourly records of:
1). Whether the flow indicator was
operating;
2). Whether a diversion was detected at
any time during the hour; and
3). The times of all periods when the vent
stream is diverted from the control
device; or
4). The flow indicator is not operating;
Continuously
EU01
&
PCE01
40 CFR
63.998(d)(1)
(ii) subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 30 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
17.
cont
Where a seal mechanism is used to comply with
Table 5, Item 3, hourly records of flow are not
required, but record:
1). The monthly visual inspection of the
seals or closure mechanisms has been
done; and
2). Occurrences of all periods when the
seal mechanism is broken, or the
bypass line valve position has changed,
or the key for the lock-and-key type
lock has been checked out, and records
of any car-seal that has been broken.
Continuously
EU01
&
PCE01
40 CFR
63.998(d)(1
)(ii) subpart SS
Equipment Leak Recordkeeping
a) Design specifications and performance
demonstrations as follows:
1). Detained schematics, design
specification of the control
device[PCE01] and piping and
instrumentation diagrams;
2). Dates and descriptions of any changes
in the design specifications; and
3). Description of the parameter or
parameters monitored, as required in
Table 6, to ensure that PCE01 is
operated and maintained in
conformance with its design and an
explanation of why that parameter was
selected for the monitoring;
For the life of the
equipment
40 CFR
63.998(d)(4)(i)
subpart SS
18.
Dates and durations of:
1). When the closed vent systems and
control device required are not
operated as designed as indicated by
the monitored parameters;
2). When the monitoring system or
monitoring device is inoperative; and
3). Startups, shutdowns, and malfunctions
of PCE01.
Retain for 5 years
EU01
&
PCE01
40 CFR
63.998(d)(4)
(ii) subpart SS
Yes
19.
Fire Pump Engine Operation Log
The Owner or Operator shall keep records of the
hours of operation of the engine that is recorded
through the non-resettable hour meter, and must
document:
a) How many hours are spent for emergency
operation, including what classified the
operation as emergency; and
b) How many hours are spent for non-
emergency operation.
Keep a running log EU02
40 CFR
63.6655
subpart ZZZZ
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 31 of 37
Table 7- Recordkeeping Requirements
Item
# Recordkeeping Requirement
Records Retention/
Frequency
Applicable
Emission Unit
Regulatory
Basis Compliant
20.
Gaseous Fuel Recordkeeping
Maintain one of the following:
a) Sulfur content as percent sulfur by weight or
in grains per 100 cubic feet of fuel; or
b) Documentation that the fuel meets state sulfur
limits.
For each delivery of
LPG fuel to the
Facility
Facility wide
Env-A 806.05
&
Env-A 903.03
Yes
21.
Additional Recordkeeping Requirements –
Permanent Total Enclosure
Maintain records of permanent total enclosure as
required in Table 6, Item 16 including:
a) Static pressure reading of the building;
b) Gauge inspection and maintenance activities
including calibration and validation checks as
specified by the manufacturer; and
c) Corrective actions.
As specified in
Table 6 EU01 & PCE01 Env-A 906 Yes
VIII. Compliance with Reporting Requirements
Table 8, below, lists the reporting requirements for the facility from TV-0027 and any
deficiencies noted during the inspection.
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
1.
Certification of Accuracy
Any report submitted to the DES and/or EPA shall
include the certification of accuracy statement
outlined in Section XXI.B of this Permit and shall be
signed by the responsible official.
As specified in
Section XXI.B. Facility Wide
40 CFR
70.6(c)(1) Yes
2.
Semi-annual Permit Deviation and Monitoring
Report
The Owner or Operator shall submit a semi-annual
permit deviation and monitoring report, which
contains:
a) Summaries of all monitoring and testing
requirements contained in this Permit; and
b) A summary of all permit deviations and
excursions that have occurred during the
reporting period.
Semiannually
received by DES no
later than July 31st
and January 31st of
each calendar year
Facility Wide
Env-A 911
&
40 CFR
70.6(a)(3)
(iii)(A)
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 32 of 37
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
3.
Annual Emissions Report
Submit an annual emissions report which shall
include the following information:
a) Each fuel burning device – Actual calendar year
emissions of NOx, CO, SO2, VOCs, and TSP;
b) Each process device – Actual calendar year
emissions of VOCs (speciated by individual
VOC), HAPs (speciated by individual HAP),
and RTAPs (reported by CAS number);
c) The methods used in calculating such emissions
in accordance with Env-A 705.02,
Determination of Actual Emissions for Use in
Calculating Emission-Based Fees; and
d) The information recorded in accordance with
Table 7, Items 6 and 7 compiled on a monthly
basis.
Annually (received
by DES no later than
April 15th
of the
following year)
Facility Wide Env-A
907.01 Yes
4.
VOC Reporting Requirements
If the actual annual emission for the facility are
greater than or equal to 10 tpy, the Owner or
Operator shall submit each year the following
information:
a) Facility information including:
1). Source name;
2). Standard Industrial Classification (SIC)
Code;
3). North American Industrial Classification
System (NAICS) code;
4). Physical address; and
5). Mailing address.
b) A break down of VOC emissions reported
pursuant to Table 7, Item 6 by month; and
c) All data recorded pursuant to Table 7, Item 7.
Annually (received
by DES no later than
April 15th
of the
following year)
Facility Wide
Env-A 908
(effective
4-21-2007)
Not
Applicable
Finding: During the inspection period, VOC emissions have not met or exceeded 10 tpy.
5.
Payment of Emission-Based Fee
Annual reporting of emission based fees shall be
conducted in accordance with Section XXIII of this
Permit.
Annually (received
by DES no later than
April 15th
of the
following year)
Significant
&
Insignificant
Activities
Env-A
705.04 Yes
6.
Permit Deviation
Prompt reporting of deviations from Permit
requirements shall be conducted in accordance with
Section XXVIII of this Permit.
Prompt reporting
(within 24 hours of
an occurrence)
Facility Wide
40 CFR
70.6(a)(3)(i
ii) (B)
Yes
7.
Annual Compliance Certification
Annual compliance certification shall be submitted in
accordance with Section XXI of this Permit.
Annually (received
by DES no later than
April 15th of the
following year)
Facility Wide 40 CFR
70.6(c)(1) Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 33 of 37
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
Semiannual Compliance Report
The semiannual compliance report shall contain the
following information:
a) Company name and address;
Statement by a responsible official with that
official’s name, title, and signature, certifying the
truth, accuracy, and completeness of the content of
the report;
b) Date of report and beginning and ending dates of
the reporting period;
c) If there was a startup, shutdown or malfunction
during the reporting period, and the Owner or
Operator took action consistent with the SSMP,
include the information in Table 8, Item 9.a)
below;
8.
d) If there were no deviations, a statement that:
1). There were no deviations from the
emission limitations specified in Table 5,
Item 4 during the reporting period;
2). There were no deviations from the work
practice requirements specified in Table 5,
Item 6.a);
3). There were no periods during which the
CPMS systems were out of control as
specified in Table 6, Item 9 during the
reporting period;
e) If there was a deviation from the emission
limitation specified in Table 5, Item 4 and/or for
each deviation from a work practice requirement
specified in Table 5, Item 6.a):
1). The information contained in Table 8,
Item 8.a), b) and c) above;
2). The total operating time of each affected
source during the reporting period; and
3). Information on the number, duration, and
cause of deviations (including unknown
cause, if applicable), as applicable, and
the corrective action taken.
Semiannually – no
later than July 31st
and January 31st of
each calendar year
to DES and EPA
EU01
&
PCE01
40 CFR
63.5910(c)
subpart
WWWW
&
63.999(c)
subpart SS
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 34 of 37
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
f) For the CPMS, the information recorded
required in Table 7, Item 12 when:
1). The daily average value is outside the
bounds specified in Table 5, Item 10.b);
or
2). The following data availability
requirements are not met:
i) The daily average value is outside the
permitted range;
ii) When the period of control device
operation is 4 hours or greater in an
operating day and monitoring data are
insufficient to constitute a valid hour
of data for at least 75 percent of the
operating hours;
iii) When the period of control device
operation is less than 4 hours in an
operating day and more than one of
the hours during the period of
operation does not constitute a valid
hour of data due to insufficient
monitoring data; and
iv) Monitoring data are insufficient to
constitute a valid hour of data, if
measured values are unavailable for
any of the 15-minute periods within an
hour;
1). Whether the excursion was excused or
unexcused; and
2). For excursions caused by lack of
monitoring data, specify the duration of
periods when monitoring data were not
collected.
g) For the closed vent system, the information
recorded in Table 7, Item 16.e);
8. cont
h) When emissions bypassed the add-on control
device during the semiannual reporting period:
1). Date and time period of any bypass of the
add-on control device;
2). Date and time period when:
i) When maintenance is performed on
car-seal valves;
ii) When the seal is broken;
iii) When the by-pass lime valve position
is changed; or
iv) The key for the lock-and-key type
configuration has been checked out.
Semiannually – no
later than July 31st
and January 31st of
each calendar year
to DES and EPA
EU01
&
PCE01
40 CFR
63.999(c)
subpart SS
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 35 of 37
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
Startup, Shutdown, Malfunction Report
Submit the following to USEPA Region 1 and the
Division if there was a startup, shutdown or
malfunction during the semiannual reporting period:
a) For actions consistent with the SSMP and if the
startup or shutdown causes the source to exceed
any applicable emission limitations specified in
Table 5, Item 4:
1). Summary of actions taken to minimize
emissions during such startups, shutdowns
and malfunctions;
2). The number, duration and a brief
description for each type of malfunction
which occurred during the reporting
period which caused or may have caused
an exceedance of the emission limits in
Table 5, Item 4;
3). The SSM report shall include the name,
title, and signature of the Owner or
Operator or other responsible official who
is certifying accuracy;
With the
Semiannual Report
40 CFR
63.5910(c)(
4) subpart
WWWW
&
63.10(d)(5)
(i) subpart
A
9. b) For actions inconsistent with the SSMP and the
startup or shutdown or malfunction causes the
source to exceed the applicable emission
limitations specified in Table 5:
1). Summary of actions taken to minimize
emissions during such startups, shutdowns
and malfunctions;
2). The number, duration and a brief
description for each type of malfunction
which occurred during the reporting
period which caused or may have caused
an exceedance of the emission limits in
Table 5, Item 4;
3). The SSM report shall include the name,
title, and signature of the Owner or
Operator or other responsible official who
is certifying accuracy;
4). Explanation of the circumstances of the
event;
5). The reasons for not following the SSM
plan describing all excess emission and/or
parameter monitoring exceedances which
are believed to have occurred; and
6). Actions taken to minimize emissions.
Within 2 working
days after
commencing
inconsistent actions
& a letter within 7
working days after
the end of the event
EU01
&
PCE01
Yes
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 36 of 37
Table 8- Reporting Requirements
Item # Requirement Frequency Applicable
Emission Unit
Rule
Citation Compliant
10.
Performance Test Reporting
Submit the performance test report to the Division
within 60 days after the completion of testing
required in Table 6, Item 3, which shall meet the
reporting requirements specified in Env-A 802.11,
including the following:
a) A brief process description;
b) The type and quantity of HAPs emitted, reported
in units and averaging times and in accordance
with the test methods specified in Table 6, Item
3;
c) Sampling site description;
d) Description of sampling and analysis procedures
and any modifications to standard procedures;
e) Quality assurance procedures;
f) Record of operating conditions during the test,;
g) Record of preparation of standards;
h) Record of calibrations;
i) Raw data sheets for field and laboratory
analyses;
j) Description of the air pollution control
equipment, and the control efficiency (percent);
k) Documentation of calculations;
l) Any other information required by the test
method;
m) The specific range of the monitoring parameter
(i.e. PCE01 combustion temperature, and wet-
out area and oven flow) based on parameter
values measured during the performance test
specified in Table 6, Item 3; and
n) Signed by the responsible official certifying the
accuracy and attesting to whether the Facility
has complied with the standard.
Within 60 days after
the completion of
testing
EU01
&
PCE01
Env-
A802.11,
40 CFR
63.999(a)
(2),
63.999(a)
(3)
subpart SS,
63.5905(a)
subpart
WWWW
&
63.9(h)
subpart A
Yes
IX. Permit Deviations
Kalwall is aware of the recordkeeping and reporting requirements for permit deviations.
However, during the inspection period, Kalwall did not report any permit deviations.
X. Other Findings
There were no other findings.
Kalwall Corporation - Bow Inspection Date: November 8, 2013
On-Site Full Compliance Evaluation Report Date: December 9, 2013
Page 37 of 37
XI. Enforcement History and Status
During the inspection period, there has been no enforcement action against Kalwall.
XII. Compliance Assistance, Recommendations and Corrective Actions
During the inspection, no compliance assistance was required and the facility made the following
corrective action:
• Kalwall set up a spreadsheet to track its 12-month running total of VOC emissions in order to
comply with Table 7, Item #3.
Based on the findings of this compliance evaluation, DES recommends the following action to
bring the facility into compliance with future reporting requirements:
• Within 30 days of the date of this report, submit to DES a plan to comply with the monitoring
and testing requirements of Table , Item #13.a; and
• Continue to maintain a 12-month running total of VOC emissions.
Report Prepared By: Daniel F Hrobak
Title:
Senior Compliance Assessment Engineer
Signed: