Public Comment Period: Special Order by Consent for Trelleborg Coated Systems, Inc.

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DEPARTMENT OF ENVIRONMENTAL QUALITY 
ENVIRONMENTAL MANAGEMENT COMMISSION 
PUBLIC NOTICE 
SPECIAL ORDER BY CONSENT FOR 
TRELLEBORG COATED SYSTEMS, INC.  
RUTHERFORDTON, RUTHERFORD COUNTY

Trelleborg Coated Systems, Inc, (Trelleborg) manufactures coated fabrics by operating a variety of coating processes that apply rubber and urethane to woven fabric at its Grace Advanced Materials facility located at 715 Railroad Avenue in Rutherfordton, North Carolina. This facility operates under Air Quality Permit Number 01954T32, which allows for the operation of a horizontal six-bed carbon adsorption unit, also referred to as the solvent recovery system (SRS). The facility currently monitors concentrations of organic compounds in the common inlet gas stream to the SRS and in the exhaust of each of the six beds of the SRS on a rotating basis. 

As the SRS monitoring system is currently configured, the facility cannot meet the monitoring requirements of the applicable federal regulations, including 40 CFR 60 Subpart VVV - Standards of Performance for Polymeric Coating of Supporting Substrates Facilities and 40 CFR 63, Subpart OOOO - National Emission Standards for Hazardous Air Pollutants: Printing, Coating, and Dyeing of Fabrics and Other Textiles. 

Trelleborg has agreed to a Special Order by Consent (SOC) with the North Carolina Environmental Management Commission (NCEMC) to resolve ongoing compliance issues related to the SRS monitoring system. The company is committing to replace the existing SRS with a new regenerative thermal oxidizer (RTO). Per the terms of the SOC, the company must install the new RTO within twelve months of receiving a permit from DAQ allowing for the construction and operation of the new equipment. Within 180 days of commencing operation, the facility must conduct performance testing of the new RTO to establish the minimum combustion temperature necessary to ensure continual compliance with federal regulations. 

The SOC includes an upfront penalty and stipulated penalties for missing compliance deadlines. The SOC will expire when DAQ approves the RTO performance testing report, or on February 28, 2025, whichever comes first.

This proposed SOC may be viewed on the Division of Air Quality (DAQ) website: http://deq.nc.gov/about/divisions/air-quality/air-quality-enforcement/special-orders-by-consent

A copy of the proposed SOC may also be viewed at the following locations and additional information concerning the proposed SOC may be obtained by contacting:

Michael Koerschner, Regional Air Quality Supervisor
NC DEQ - Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778-8211
Phone 828-296-4500 

or

Steve Hall, Technical Service Section Chief
NC DEQ-DAQ Raleigh Central Office
217 West Jones Street
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone 919-707-8404

Interested persons are invited to review the proposed SOC and to submit written comments by email to daq.publiccomments@deq.nc.gov with “Trelleborg SOC” in the subject line or by mail to one of the above addresses. Any person requesting a public hearing regarding the proposed SOC should submit a written request with a statement supporting the need for such a hearing. The request for hearing should be sent to the DAQ at one of the two above addresses or at the above email address. 

All public comments and requests for hearing must be received by 5 p.m. on Wednesday, November 1, 2023. The Director of the DAQ shall take final action on behalf of the NCEMC on Consent Orders within 60 days of the initial public notice.