Permit Review for R06 - Mohawk Industries

March 22, 2006

1. Purpose of Application

The purpose of this application is to modify Air Permit No. 07589R06 for the following reason:

2. Facility Description

This facility makes carpet yarn.

3. Application Chronology/History

December 27, 2005 – Permit and fee received, DAQ

4. Permit Changes

The following changes were made between Permit No. 07589R05 and 07589R06:

Page Section Changes
Cover, all throughout Updated permit No., dates, etc.
2 2 Replaced 3-year emissions inventory with yearly.
3 8 40 percent VE added.
4-5 12 PSD avoidance added.
8 18 12-month requirement for Title V permit added.

5. New Equipment/Change in Emission and Regulatory Review

The following stipulations were changed/added/removed for this application.

Permit 07589R05, Stipulation 2: Emission inventory requirement every three years. (removed)

Permit 07589R06, Stipulation 2: Title V requirement for annual emission inventory. (added)

Permit 07589R06, Stipulation 7: A stipulation was added to allow equipment that existed as of July 1, 1971 to have 40 percent visible opacity emissions. This is because information has been obtained that both boilers were manufactured n 1963. (added)

Permit 07589R05, Stipulation 11: The synthetic minor stipulation limiting SO2 emissions to 100 TPY (SO2 is the limiting pollutant for Title V applicability purposes) was removed. (removed)

Permit 07589R06, Stipulation 12: A PSD avoidance limit of 250 TPY was added to the permit. The stipulation includes full Title V language for monitoring, recordkeeping, and reporting. (added)

Permit 07589R06, Stipulation 18: Stipulation for full Title V application within 12 months added. (added)

The application included a Toxics modeling request for arsenic, cadmium, and nickel, all of which are emitted from the boilers at levels above the TPERs. However, no stipulation for either 2D .1100 or 2Q .0711 were included in the permit because DAQ does not include boiler emissions alone for Toxics applicability.

The Company included three pages of insignificant activities to the application. These insignificant activities were not added to the permit because in each case the Company listed the basis for exemption as “no air emissions from” . Insignificant activities do not need to be added to the permit if air emissions do not exist, only if air emissions exist and the emission level is below the statutory threshold, or if the activity is exempted by category.

6. NSPS Issues:

No equipment at the facility is subject to NSPS.

7. PSD/NAA Issues:

Scotland County has been triggered for PSD increment tracking for PM10 and SO2. This modification is expected to increase SO2 and PM10 emissions, but at a rate less than the 1.0 lb/hr threshold.

NAA does not apply to Scotland County because it is in attainment.

8. MACT Issues:

MACT DDDDD should be evaluated for the existing boilers at the first time Title V review.

9. 112(r) Issues:

This facility is not subject to 112(r) at this time.

10. CAM Issues:

CAM does not apply because there are no control devices at the facility.

11. Facility Wide Air Toxic Air Pollutants:

This application did trigger toxics review. Toxics should be evaluated for other sources when the initial Title V permit application is processed.

12. Facility Compliance Status:

This facility was inspected on August 16, 2005, and appeared to be in compliance with applicable Air Quality regulations.

13. Conclusions, Comments, and Recommendations:

FRO recommends issuance of Permit No. 07589R06.

Recommend issuance of Permit No. 07589R06.