February 14, 2000

Alan Klimek, Director
NC DAQ
1641 Mail Service Center
Raleigh, NC 27699-1641

Re: Steelcase, Inc., Fletcher, Henderson County, NC Title V Air Permit
DRAFT Permit No. 01968T23
Application No. 450177A5.A

Dear Mr. Klimek:

During the past two weeks, Lou Zeller and I have contacted eight people from Henderson and Buncombe counties who are affected by emissions from Steelcase, Inc. in Fletcher, NC.  Our staff and local members believe that nearby communities would be adversely affected if the new Title V permit for the furniture plant were to be approved as drafted.

Our concerns are multiple.  First, neither we nor local organizations nor local concerned citizens have had adequate opportunity to investigate the full impact of the new permit.  Second, local people and the media have been promised that Steelcase would reduce volatile organic compounds every year; from our conversations we believe that affected community people have been led to expect VOCs will be decreased every year and that Steelcase is "moving towards water-based finishing."  They and we need time to fully evaluate the Title V draft under consideration.  Therefore, I ask that you grant an extension of the comment period.  Further, the Board of Directors of BREDL requests a public hearing.

Our rationale for these requests include:

1) The new draft permit would allow emissions of VOCs at 1,826,000 pounds/year.  The draft permit allows a large increase in toxic pollutants emitted from the plant.  Comparison of actual VOC emissions for the years 1996 and 1998 show a total rise of 20.9%. Dangerous ethyl acetate, an NC TAP, increased by 180%.  Total [hazardous air pollutant] emissions also increased by 12%
(only two HAPs decreased: glycol ethers and MIBK 22% and 61%, respectively).  Specific HAP increases include:

ethyl benzene  +10%
formaldehyde +33%
methyl ethyl ketone  +31%
methanol +87%
phenol  +29%
toluene  +05%
xylene  +04%

(source: NC Emissions Facility Detail data years 1996-10/2/98 and 1998-1/5/00)

2) The new draft permit does not reflect any enforcement regimen for the federal NESHAP regulation.  A DAQ enforcement program which limits TAPs from finishing operations or a state enforcement program of federal limits such as scratch-testing should be guaranteed to protect public health and ensure compliance.

3) The speciation of VOCs from the natural gas-fired ovens should be a part of permitting decision making.  With almost two million pounds of VOCs per year, addition emissions from the ovens must be included for any margin of safety.  As Director you can and must add up all the pollution.

4) The abysmal compliance history of Steelcase alone should lead to the additional scrutiny which an extended comment period and a public hearing would provide.  If the company has changed its way of doing business, Steelcase should have no objection to a public review.

Thank you for consideration of our request.

Sincerely,

Janet Marsh Zeller, Executive Director
SteelcaseTitleV14feb00
_____________________________________________
BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
PO Box 88  ~ Glendale Springs, North Carolina  28629
www.bredl.org      Email bredl@skybest.com
Phone 336-982-2691 ~ Fax 336-982-2954


Title V Fact Sheet
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