AQ_F_0200033_20190326_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Brushy Mountain Dry Kilns,LLC
NC Facility ID 0200033
Inspection Report County/FIPS:Alexander/003
Date: March 26,2019
Facility Data Permit Data
Brushy Mountain Dry Kilns,LLC Permit 05199/R10
844 Lewittes Road Issued 9/19/2017
Taylorsville,NC 28681 Expires 8/31/2025
Lat: 35d 55.6668m Long: 8 1 d 8.7372m Class/Status Small
SIC: 2421 /Sawmills&Planing Mills General Permit Status Active
NAICS: 321918/Other Millwork(including Flooring) Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Will Weatherly Will Weatherly Will Weatherly MACT Part 63: Subpart 6J
Manager Manager Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 03/26/2019
Inspector's Name Ryan Mills
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
2�/ Action Code FCE
Date of Signature: �/ C� / On-Site Inspection Result Compliance
Total Actual emissi ns i TO S/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 3.66 0.2400 4.70 0.6100 5.76 2.79 364.80
2011 2.83 0.1800 3.53 0.4800 4.32 2.07 273.60
*Highest HAP Emitted in pounq0j
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
08/18/2014 NOV 2D .1900 Open Burning 09/12/2014
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

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March 26,2019
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FTypeull CompliancePartial Compliance _Complaint Other:valuation Evaluation/Re-inspection Investigation
Data Date submitted for initial review: 4/3/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Insp.Date: 3/1/2021
Directions:
From the intersection of 1-40 and Hwy 64/90 in Statesville,travel west on Highway 64. Turn right onto
Adams Pond Lane and then turn left onto Highway 90. Turn right onto Lewittes Road. The facility is
located on the right, approximately 1 mile from Hwy 90.
Recommended to take two inspectors on this inspection.
Safety Equipment:
Safety shoes are recommended.
Safety Issues:
Uneven and sometimes muddy terrain. Large equipment can be in use at any time. There are also several
cats and dogs on the property.
Lat/Long Coordinates:
The "Maps of DAQ Regulated Facilities" is currently not accessible. However,the last compliance
inspection conducted in 2017 indicated the coordinates were accurate. Also,I used the coordinates,in
IBEAM and entered them into the"Google Maps"application and the coordinates appeared to be
accurate.
Email Contacts:
The email contact for Mr. Weatherly is current with no change needed.
1. The purpose of this site visit was to conduct a routine air quality inspection.The facility kiln dries
and manufactures various grades and sizes of lumber from uncured bulk woods. The facility is
currently operating from 7am-5pm,Monday through Thursday and 7am-3:30pm on Fridays with
five employees. Mr.Will Weatherly,Manager accompanied us during this inspection.
2. Facility Contact Information:
During the inspection I verified the facility contact information in IBEAM. The invoice contact
phone number needed to be changed to match Will Weatherly's. Sandra Sherer of this office
made the change in IBEAM.
3. Compliance history file review:
A Notice of Violation was issued on August 18,2014 for open burning of synthetic materials
along with a Notice of Deficiency, on the same date, for failure to provide the boiler tune-up

Brushy Mountain Dry Kilns, LLC
March 26, 2019
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records (0). The Notice of Deficiency was later rescinded when information from the test was
made available.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source rontrol Control System
Source ID Description y)m Description
ES-1 (NESHAP) [Bt
ood fuel-fired boiler(4.8 million CD-1 multicyclone(4 -9 inch diameter
uper hour maximum heat input tubes)
apacity)
Observed: The wood fuel-fired boiler and the multicyclone were both shutdown upon this inspection.
ES-2 Woodworking operations CD-2 simple cyclone(84 inches in diameter)
Observed: Neither the ripsaw or the wood planning operation tied to the corresponding wood collection system was in
use at the time of this inspection. No visible wood waste was seen around the vent and the ductwork appeared to be
sound and maintained. Mr. Weatherly stated that the planer is only operated approximately two to three times a month.
The cyclone wood dust storage silo is only emptied approximately two to three times a month.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Regulation
;IES-3 -LPG-fired boiler 4.2 million Btu per hour maximum heat input capacity) 2 0102 h 1 B
( P P p h') � ( )( )( )
!Observed: This boiler was not in operation during the inspection and is not connected to a fuel source and has not been
used in many years.
;IES-4-wood drying kiln 2Q .0102 (h)(5)
TIES-5 -wood drying kiln Q .0102 (h)(5)
IES-6 -wood drying kiln 2Q .0,102 (h)(5)
TIES-7 -wood drying kiln _ _ _ 2Q .0102 (h)(5)
;Observed: The facility has four wood drying kilns. Two of the kilns are in metal buildings, and the other two are
inside brick buildings. Two of the kilns were operating during the inspection with no visible emissions.A third kiln is
fused in rotation with the other two and was not in use during the inspection. The fourth kiln is not operating and is
currently being_used to store lumber.
;IES-8 - s ra ainting operation 2 .0102 h)(3
p_ Y p - - _ �— Q (_ )
,Observed: Spray painting(Cospaint)containing 62 g/l or 0.52 Ibs/gal of VOC is spray applied to the ends of the
jlumber for aesthetic reasons. Mr. Weatherly estimated the usage of the paint at eight 55 gallon drums per year. No
;spray paint operations were observed by me during the inspection.
TIES-9 -dip tank 2Q .0102 (h)(3)
Observed: One dip tank contains a solution of water and two types of chemicals by ISK Biocides,Inc.,NeX-Brite to
;brighten the wood and NeXgen for surface mold, stain from sap and fungi on the wood. The chemical,NeX-Brite,
contains no VOCs. The chemical,NeXgen, contains 95 g/1 or 0.79 Ibs/gal of VOCs. Mr. Weatherly estimated the usage
of each chemical as one 55-gallon drum per year. These chemicals are used from May to June each year. No lumber
was being preserved in the dip tank during the inspection.

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6. Observations of air emission sources and control devices not listed on the current permit:
a. None. -
7. Compliance with specific permit conditions and limitations:
a. Condition A.2.—"Emissions Inventory Requirement". At least 90 days prior to the expiration date of
the permit,the Permittee shall submit the air pollution emission inventory report. The report shall be
submitted to the Regional Supervisor,DAQ. The report shall document air pollutants emitted for the
2024 calendar year.
Observed: The report is not due at this time.
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b. Condition A.3. 15A NCAC 2D .504, "Particulates from Wood Burning Indirect Heat
Exchangers". Particulate matter emissions from the boiler(ES-1) shall not exceed the
allowable emission rate of 0.70 lbs/million Btu.
Observed: The facility was found to be in compliance with this regulation during the last
permit review completed by Jennifer Womick on September 15, 2017. The actual particulate
matter emissions are 0.30 lbs/million Btu. Therefore, compliance with this permit condition
is indicated.
c. Condition A.4. 15A NCAC 2D .0512 "Particulates from Wood Products Finishing Plants".
The Permittee shall not discharge particulate matter caused by the working, sanding, or
finishing of wood without providing, as a minimum for its collection, adequate duct work and
properly designed collectors, or other such devices as approved by the Commission.
Observed: The wood collection system for the woodworking operation is controlled by a
cyclone that appears to provide adequate control. Compliance with this permit condition is
indicated.
d. Condition A.5. 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources,"
sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million
Btu heat input.
Observed: Per MRO memo"2D .0516 analysis"dated 04/10/97, compliance is indicated for
No. 1 fuel oil,No.2 fuel oil,natural gas, butane,propane,)and wood fuel. Compliance with
this permit condition is indicated.
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e. Condition A.6. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is limited
to 20 percent opacity.
Observed: The wood collection system was not used during the inspection therefore; no
visible emissions were observed during the inspection. Compliance with this permit condition
is indicated.
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f. Condition A.7 15A NCAC 2D .0535 "Notification Requirement". Permittee of a source of
excess emissions that last for more than four hours and that results from a malfunction, a
breakdown of process or control equipment or any other abnormal conditions, shall notify the
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Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's
next business day of becoming aware of the occurrence.
Observed: As per a conversation with Mr. Weatherly,there have been no excess emissions
since the last inspection. Compliance with this permit condition is indicated.
g. Condition A.8. 15A NCAC 2D .0540. "Particulates from Fugitive Dust Emission Sources"
Permittee will not cause or allow fugitive dust emissions to cause or contribute to complaints
or excess visible emissions beyond the property boundary from process operations that do not
pass through a stack or a vent.
Observed: There were no fugitive dust emissions observed during this site visit and there
have not been any dust complaints against this facility since the previous inspection.
Compliance with this permit condition is indicated.
h. Condition A.9 15A NCAC 2D .0611. "Cyclone and Multicyclone Requirements". Conduct
an annual inspection of the cyclone. Perform inspections and maintenance as recommended
by the equipment manufacturer and list corrections made and dates of actions in a cyclone
logbook.
Observed: The last inspections and maintenance activities were completed for both cyclones
on February 20, 2019,February 13, 2019,November 7,2018, August 23, 2018,May 22,
2018,January 8, 2018, October 22, 2017,July 19, 2017,July 12, 2017,April 11,2017,
February 15, 2017 and December 2, 2017. During these dates different maintenance and
inspection activities were performed. Compliance with this condition is indicated.
i. Condition A.10 15A NCAC 2D .1111 as promulgated in 40 CFR 63 Subpart JJJJJJ-For the
wood waste-fired boiler(ID No. ES-1), specifically 40 CFR 63.11225(a)(4). The air permit
currently states that a tune-up must be completed by March 21, 2012 for existing sources. A
biennial tune-up is also required. It also states that an initial notification was due by
September 17, 2011. The Notification of Compliance Status (NOCS)was due by July 19,
2012 for existing sources. This facility is not required to complete an energy assessment,
because it has an existing wood boiler that has a heat input of less than 10 million Btu/hr.
Biennial compliance report is due by March 1 of every other year starting March 1,2015.
It should be noted that there were changes to the 6J rule following the issuance of Air Permit
No. 05199R09. This rule change extended the initial notification date to January 20, 2014
and the boiler tune-up due date to March 21,2014.
Observed: A Notice of Deficiency was issued to the facility on July 22, 2015 for not
conducting a biennial tune-up by the due date. The tune-up was later completed by Xact
Controls,Inc. on August 3, 2015. The facility also completed the Certification and
Notification of.Compliance Status Form. Copies were submitted to MRO in response to the
NOD. The next biennial tune-up was due by September 2017 and was conducted on
September 2017 by Xact Controls,Inc.An invoice along with a report on the results of the
tune-up was provided. The next biennial tune-up is due by October 2019. Compliance
with this condition is indicated.

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8. NSPS/NESHAP Review:
This facility is not subject to NESHAP Subpart QQQQQQ(6Q)—Wood Preserving-because it
does not use chromium, arsenic, dioxin, or methylene chloride;in wood preservation process.
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The facility does not have any gasoline storage tanks.The facility also does not have any
emergency generators or reciprocating internal combustion engines.
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9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered duringthe he inspection:
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None.
11. Section 112(r) applicability:
This facility does not appear to be subject to the requirements iof the Chemical Accident Release
Prevention Program, Section 112(r-) of the Clean Air Act.
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12. Compliance determination:
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Based on my observations,this facility appears to be in compliance with the applicable air quality
regulations at the time of the inspection.
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RCM:lhe
c: MRO File
C:\Users\lhelledge\State of North Carolina\DAQ-Mooresville Regional Office-ALEXANDER\00033\INSPECT_20190326.docx
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