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									                                                                           STATEMENT OF BASIS
                                                                                  Page 1 of 5
                                                                         BAQ Engineering Services Division
                                                                            2600 Bull Street, Columbia, SC 29201
                                                                          Phone: 803-898-4123 Fax: 803-898-4079
 Company Name:                         Saint-Gobain ADFORS America, Inc.                        Permit Writer:        Katie R. Brown
 Permit Number:                                  TV-0560-0026                                       Date:                DRAFT

DATE APPLICATION RECEIVED:                     February 3, 2012

DATE OF LAST INSPECTION:                       February 2, 2011. No Violations noted.

FACILITY DESCRIPTION                           The facility produces fiberglass mat using a process involving the dispersion of chopped
fiberglass in a pulper containing white water. The white water is a mixture of water, viscosity modifier, antifoam, fibersizing, biocide, and
other chemicals. The dispersed fiberglass is formed into a mat by spreading it across a traveling screen, know as delta former. After excess
water is removed, binder is applied, and the mat is cured by conveying it through the Honeycomb Dryer. The cured fiberglass mat is then
trimmed prior to being shipped out to other facilities.

PROJECT DESCRIPTION                            Title V renewal (Major for VOC, Formaldehyde, and Methanol).

COLLOCATION DETERMINATION                      N/A

CHANGES SINCE LAST OP ISSUANCE                          No changes since last issuance.

SOURCE TEST REQUIREMENTS                     A source test was performed on the honeycomb dryer for formaldehyde on 6/22/10; all test
were passed. Performance tests will be performed per 40 CFR 63 Subpart HHHH.

SPECIAL CONDITIONS, MONITORING, LIMITS                            N/A

PUBLIC NOTICE             This Title V Permit will undergo a 30-day public notice period and a 45-day EPA comment period in accordance
with SC Regulation 61-62.1, Section II(N). This permit was placed in The Post & Courier on June 13, 2012. The comment period was open
from June 13, 2012 to July 12, 2012 and was placed on the BAQ website during that time period.

ADDITIONAL PUBLIC PARTICIPATION                         N/A

STACK DESCRIPTION
Stack ID        Stack Description
FP-01           Incline Table Blower – Left & Exhaust Hoods (previously Unit 01)
FP-02           Application Blower (AB)
FP-03           Binder/Fine Tune Blower (BFTB)
FP-04           General Plant Ventilation – S2 (GVPF)
FP-05           General Plant Ventilation – S3 (GVPF)
FP-06           General Plant Ventilation – S5 (GVPF)
FP-07           Incline Table Blower – Right (ITBR)
FP-08           Honeycomb Dryer & New RTO (Unit 01)

EMISSIONS
                             UNCONTROLLED POTENTIAL EMISSIONS (PROJECT ONLY)
      ID            Pollutant         lb/hr           TPY            Method for Estimating Emissions
                  Formaldehyde                                     Results from Facility’s 2000 Indoor Air
    FP-01                              1.10           4.82
                     (H/T/V)                                                    Quality Tests
                                                                   Results from Facility’s 2000 Indoor Air
    FP-01        Methanol (H/T/V)      0.21           0.92
                                                                                Quality Tests
    FP-01          VOC (total)         1.31           5.74          Sum of Formaldehyde and Methanol
                  Formaldehyde                                     Results from Facility’s 2000 Indoor Air
    FP-02                              0.10           0.44
                     (H/T/V)                                                    Quality Tests
                                                                   Results from Facility’s 2000 Indoor Air
    FP-02        Methanol (H/T/V)     0.087           0.38
                                                                                Quality Tests
    FP-02          VOC (total)        0.187           0.82          Sum of Formaldehyde and Methanol
                                                                           STATEMENT OF BASIS
                                                                                  Page 2 of 5
                                                                         BAQ Engineering Services Division
                                                                            2600 Bull Street, Columbia, SC 29201
                                                                          Phone: 803-898-4123 Fax: 803-898-4079
 Company Name:                         Saint-Gobain ADFORS America, Inc.                        Permit Writer:        Katie R. Brown
 Permit Number:                                  TV-0560-0026                                       Date:                DRAFT

                         UNCONTROLLED POTENTIAL EMISSIONS (PROJECT ONLY)
      ID        Pollutant          lb/hr           TPY            Method for Estimating Emissions
              Formaldehyde                                       Results from Facility’s 2000 Indoor Air
   FP-03                            0.19            0.83
                 (H/T/V)                                                      Quality Tests
                                                                 Results from Facility’s 2000 Indoor Air
   FP-03    Methanol (H/T/V)       0.085            0.37
                                                                              Quality Tests
   FP-03       VOC (total)         0.275            1.20          Sum of Formaldehyde and Methanol
              Formaldehyde                                       Results from Facility’s 2000 Indoor Air
   FP-04                            0.12            0.53
                 (H/T/V)                                                      Quality Tests
   FP-04       VOC (total)          0.12            0.53                      Formaldehyde
              Formaldehyde                                       Results from Facility’s 2000 Indoor Air
   FP-05                            0.12            0.53
                 (H/T/V)                                                      Quality Tests
   FP-05       VOC (total)          0.12            0.53                      Formaldehyde
              Formaldehyde                                       Results from Facility’s 2000 Indoor Air
   FP-06                            0.12            0.53
                 (H/T/V)                                                      Quality Tests
   FP-06       VOC (total)          0.12            0.53                      Formaldehyde
              Formaldehyde                                       Results from Facility’s 2000 Indoor Air
   FP-07                           0.051            0.22
                 (H/T/V)                                                      Quality Tests
                                                                 Results from Facility’s 2000 Indoor Air
   FP-07    Methanol (H/T/V)       0.036            0.16
                                                                              Quality Tests
   FP-07       VOC (total)         0.087            0.38          Sum of Formaldehyde and Methanol
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08        PM               0.25            1.10
                                                                            dated July 2008**
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08       PM10              0.25            1.10
                                                                            dated July 2008**
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08       PM2.5             0.25            1.10
                                                                            dated July 2008**
                                                              Natural Gas, AP-42, Section 1.4, Tables 1.4-
 (01) FP-08        SO2             0.019           0.083
                                                              1 and 1.4-2, dated February and July 2008**
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08        CO               2.69           11.76
                                                                            dated July 2008**
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08        NOx              4.65           20.39
                                                                            dated July 2008**
                                                              Natural Gas, AP-42, Section 1.4, Tables 1.4-
 (01) FP-08       Lead           1.59E-05        6.96E-05
                                                              1 and 1.4-2, dated February and July 2008**
                                                               Propane, AP-42, Section 1.5, Table 1.5-1,
 (01) FP-08       VOC               0.36            1.58
                                                                            dated July 2008**
              Formaldehyde
 (01) FP-08                        48.3*           211.6           Results from RTO testing in 2005
                 (H/T/V)
                                                                 Results from Facility’s 2000 Indoor Air
 (01) FP-08 Methanol (H/T/V)        10.1            44.2
                                                                              Quality Tests
                                                              Sum of Formaldehyde, Methanol, and VOCs
 (01) FP-08    VOC (total)         58.76          257.38
                                                                            from combustion
H=HAP, T=TAP, V=VOC

*Reason for discrepancy with last OP: On last OP issuance, basis for the pre-control emissions of formaldehyde from the RTO was taken
from stack testing results from December 7, 2000. Since then, two new stack tests were performed in July 2005 and June 2010. The pre-
control values were taken from the July 2005 stack test because it yielded more conservative values. Additionally, the July 2005 test results
determined the RTO had a formaldehyde destruction of 99.6% where the June 2010 test determined a 99.1% destruction rating. To be
conservative, the controlled formaldehyde emissions were calculated using 96% (as required by 40CFR63 Subpart HHHH).
** For detailed sample calculations, see application received February 3, 2012.
                                                                      STATEMENT OF BASIS
                                                                             Page 3 of 5
                                                                    BAQ Engineering Services Division
                                                                       2600 Bull Street, Columbia, SC 29201
                                                                     Phone: 803-898-4123 Fax: 803-898-4079
 Company Name:                      Saint-Gobain ADFORS America, Inc.                      Permit Writer:       Katie R. Brown
 Permit Number:                               TV-0560-0026                                     Date:               DRAFT

                              CONTROLLED POTENTIAL EMISSIONS (PROJECT ONLY)
     ID             Pollutant         lb/hr           TPY            Method for Estimating Emissions
                                                                  Sum of Formaldehyde, Methanol, and VOCs
 (01) FP-08       VOC (total)           3.3           14.45
                                                                              from combustion
                 Formaldehyde
 (01) FP-08                            1.93            8.45         96% destruction efficiency from RTO
                    (H/T/V)
 (01) FP-08     Methanol (H/T/V)       1.01            4.42         90% destruction efficiency from RTO

                                                 FACILITY WIDE EMISSIONS
                                                Uncontrolled Emissions                              Controlled Emissions
              Pollutant
                                                        TPY                                                 TPY
                 PM                                      1.10                                               N/A
                PM10                                     1.10                                               N/A
                PM2.5                                    1.10                                               N/A
                 SO2                                    0.083                                               N/A
                 CO                                     11.76                                               N/A
                 NOx                                    20.39                                               N/A
                Lead                                  6.96E-05                                              N/A
                VOC                                     267.1                                             24.2***
            Formaldehyde                                219.5                                            16.34***
              Methanol                                  46.03                                             6.26***
                 CO2                                   19,601                                               N/A
                 CH4                                     0.32                                               N/A
                 N2O                                     1.41                                               N/A
                CO2e                                   20,045                                               N/A
             Total HAPs                                265.53                                               22.6
         Single Highest HAP
                                                         219.5                                         16.34***
           (Formaldehyde)
*** These values were determined by summing the controlled emissions from (01)FP-08 and the uncontrolled emissions from stacks FP01-
07 for each given pollutant.

                                 PROJECT REGULATORY APPLICABILITY REVIEW
                                                    Applicable
                   Regulation                                                              Comments
                                                    Yes    No
Section II(E): Synthetic Minor                              X  This is a Title V facility.
Section II(G): Conditional Major                            X  This is a Title V facility.
Standard 1: Fuel Burning Operations                         X  This facility has no indirect-fired fuel burning sources.
                                                               This facility has demonstrated compliance through modeling;
Standard 2: Ambient Air Quality Standards            X
                                                               see modeling summary dated 5/1/12.
                                                               The RTO is defined as an industrial incinerator. Therefore,
Standard 3: Waste Combustion/Reduction (state only)  X         opacity is limited to 20% and particulate matter emission are
                                                               limited to 0.5 lb/MMBtu total heat input.
Standard 3.1: HMI Waste Incinerators                        X  This facility has no medical waste incineration.
                                                               The honeycomb dryer and RTO are subject to a 20% opacity.
                                                               The honeycomb dryer only generates PM emissions via fuel
Standard 4: Emissions from Process Industries        X
                                                               combustion, meaning there is no process related PM expected
                                                               from this source.
                                                               None of the processes which are regulated by this standard
                                                               apply. In addition, construction of this facility began in 1982,
Standard 5: Volatile Organic Compounds                      X
                                                               after the July 1, 1979 and July 1, 1980 cut off dated associated
                                                               with this standard.
                                                                       STATEMENT OF BASIS
                                                                              Page 4 of 5
                                                                     BAQ Engineering Services Division
                                                                        2600 Bull Street, Columbia, SC 29201
                                                                      Phone: 803-898-4123 Fax: 803-898-4079
Company Name:                         Saint-Gobain ADFORS America, Inc.                       Permit Writer:          Katie R. Brown
Permit Number:                                  TV-0560-0026                                      Date:                  DRAFT

                                   PROJECT REGULATORY APPLICABILITY REVIEW
                                                    Applicable
                  Regulation                                                              Comments
                                                    Yes    No
                                                               This facility was constructed in 1982, therefore the July 1, 1979
                                                               VOC baseline value is 0 TPY. The facility has requested
Standard 5.1: BACT/LAER For VOC (state only)                X
                                                               federally enforceable limits of less than 100 TPY VOC for
                                                               BACT/LAER avoidance.
                                                               The RTO device is exempt from this standard, because its
                                                               burners have a rating of less than 10 MMBtu/hr. The
                                                               Honeycomb dryer burner has a heat input rating of 30
Standard 5.2: Control of Oxides of Nitrogen                 X
                                                               MMBtu/hr. However, this equipment was originally installed in
                                                               1982 and has not been modified. Therefore, the requirements of
                                                               this standard do not apply to the dryer at this time.
                                                               The facility has the PTE of greater than 250 TPY (it is not one
                                                               of the 28) of VOC. However, the facility has taken federally
Standard 7: Prevention of Significant Deterioration         X  enforceable limits of less than 250 TPY VOC for PSD
                                                               avoidance. This is achieved by operating the RTO at all times
                                                               while the Honeycomb Dryer is in operation.
                                                               The PSD major source baseline dates for PM10, SO2, and NO2
                                                               have been established as 11/30/1977, 11/30/1977, and 03/07/89
Standard 7(c): Ambient Air Increments                X         for NOx for Charleston County. The facility has demonstrated
                                                               compliance through modeling for PSD Class II increments; see
                                                               summary dated 5/1/12.
Standard 7.1: Standards for Non Attainment Areas            X  This facility is not located in a non-attainment area.
                                                               This facility has demonstrated compliance through modeling for
                                                               all TAPs; see modeling summary dated 5/1/12.

Standard 8: Toxic Air Pollutants (state only)          X                  The condition from the previous permit requiring the stack for
                                                                          CD-RTO to have a height of at least 75 feet has been removed.
                                                                          According to the inspection dated 2/2/12, the stack is already in
                                                                          place and has a height greater than 75 feet.
Regulation 61-62.6: Control of Fugitive Particulate
                                                                X         This facility does not have fugitive emissions.
Matter
40 CFR 60 - NSPS and Regulation 61-62.60: SC                              None of the processes, which are regulated by the regulation,
                                                                X
Designated Facility Plan and NSPS                                         apply.
40 CFR 61 - NESHAP and Regulation 61-62.61:                               None of the processes, which are regulated by the regulation,
                                                                X
NESHAP                                                                    apply.
                                                                          The source is subject to Subpart HHHH, The National Emission
40 CFR 63 – MACT and Area Source Standards and
                                                                          Standards for Hazardous Air Pollutants for Wet-Formed
Regulation 61-62.63: NESHAP For Source                 X
                                                                          Fiberglass Mat Production. The compliance date was April 11,
Categories
                                                                          2005.
Regulation    61-62.68:    Chemical         Accident                      The facility does not use regulated pollutants above threshold
                                                                X
Prevention                                                                quantities.
Regulation 61-62.70: Title V                           X                  This is a Title V facility.
                                                                          This facility does not meet applicability requirements under this
Regulation 61-62.72: Acid Rain                                  X
                                                                          regulation.
Regulation 61-62.96: Nitrogen Oxides (NOX) and
                                                                X         This facility is not in the NOX or SO2 budget training program.
Sulfur Dioxide (SO2) Budget Trading Program
Regulation 61-62.99: Nitrogen Oxides (NOX)
                                                                          This facility does not have any NOX emissions from cement
Budget Program Requirements for Stationary                      X
                                                                          manufacturing.
Sources Not In the Trading Program
                                                                          STATEMENT OF BASIS
                                                                                 Page 5 of 5
                                                                        BAQ Engineering Services Division
                                                                           2600 Bull Street, Columbia, SC 29201
                                                                         Phone: 803-898-4123 Fax: 803-898-4079
 Company Name:                        Saint-Gobain ADFORS America, Inc.                        Permit Writer:         Katie R. Brown
 Permit Number:                                 TV-0560-0026                                       Date:                 DRAFT

                             PROJECT REGULATORY APPLICABILITY REVIEW
                                            Applicable
               Regulation                                                         Comments
                                            Yes    No
                                                       On December 10, 2001, SGAA (then SGVA) submitted a letter
                                                       to DHEC outlining the applicability of the CAM rule as it
40 CFR 64 - Compliance Assurance Monitoring            relates to the fiberglass mat manufacturing operations. SGAA
                                                    X
(CAM)                                                  concluded that CAM rule did not apply to the facility. On
                                                       December 17, 2001, DHEC issued a letter stating that the CAM
                                                       rule did not apply to SGAA.

SUMMARY AND CONCLUSIONS
It has been determined that this source, if operated in accordance with the submitted application, will meet all applicable requirements and
emission standards.

								
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