HomeMy WebLinkAboutAQ_F_1400068_20140801_PRMT_Permit NC
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 1, 2014
Mr. Scott Greene
President
Quality Hardwoods, LLC
P.O. Box 2705
North Wilkesboro,NC 28659
Subject: Air Permit No. 02765R11
Quality Hardwoods, LLC
Lenoir, Caldwell County,North Carolina
Permit Class: Small
Facility ID# 1400068
Dear Mr. Greene:
In accordance with your completed application received July 17, 2014, we are forwarding
herewith Permit No. 02765RI 1 to Quality Hardwoods, LLC, Lenoir, Caldwell County,North
Carolina for the construction and operation of air emissions sources or air cleaning devices and
appurtenances. Additionally, any emissions activities determined from your air permit application
as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for
information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records
retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
Asheville Regional Office-Division of Air Quality
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:828-296-4500/FAX:828-299-7043
Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper
Mr. Scott Greene
August 1, 2014
Page 2
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from August 1,2014 until February 28, 2017, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements,limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
• The facility's name and ownership is changed from "Robinson Lumber Company,
Inc." to "Quality Hardwoods,LLC."
• The specific condition permit language covering National Emission Standards for
Hazardous Air Pollutants for Area Sources, Subpart JJJJJJ, Industrial, Commercial,
and Institutional Boiler GACT is updated with this name and ownership change.
Should you have any questions concerning this matter, please contact Christopher Scott at 828-296-
4500.
Sincerely,
Paul K. Muller, P.E., Regional Supervisor
Division of Air Quality,NCDENR
PKM:ces
Enclosures
c: Asheville Regional Office
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 027651111
Issue Date: August 1, 2014 Effective Date: August 1, 2014
Expiration Date: February 28, 2017 Replaces Permit: 02765R10
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Quality Hardwoods, LLC
2402 Norwood Street SW
Lenoir, Caldwell County,North Carolina
Permit Class: Small
Facility ID# 1400068
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
_..
ES-2 wood-fired boiler(13.9 million Btu CD-2 'one multicyclone
(NESHAP) 1per hour maximum heat input rate) ,(three, 6-inch diameter tubes)
ES-3 woodwaste collection system CD-3 one simple cyclone
..._... ....._ ..... __
(72 inches in diameter)
in accordance with the completed application 1400068.14A received July 17,2014 including any
plans, specifications,previous applications, and other supporting data, all of which are filed with the
Department of Environment and Natural Resources, Division of Air Quality (DAQ) and are
incorporated as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Permit No. 02765RI I
Page 2
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0504, 2D .0512, 2D .0516, 2D .0521, 2D .0535, 2D .0540, 2D .0611, 2D
.1111 (40 CFR 63, Subpart JJJJJJ) and 2D .1806.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request (with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2015 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0504
"Particulates from Wood Burning Indirect Heat Exchangers," particulate matter emissions
from the wood burning indirect heat exchangers shall not exceed the allowable emission
rates listed below:
Source Emission Limit
(lbs/million Btu)
wood-fired boiler(ID No. ES-2;
0.65
13.9 million Btu per hour maximum heat input rate)
4. PARTICULATE CONTROL REQUIREMENT- As required by 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.
5. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the
wood-fired boiler(ID No. ES-2) shall not exceed 2.3 pounds per million Btu heat input.
6. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 21)
.0521 "Control of Visible Emissions," visible emissions from the wood-fired boiler(ID No.
ES-2) and the woodwaste collection system (ID No. ES-3), manufactured after July 1, 1971,
shall not be more than 20 percent opacity when averaged over a six-minute period, except
that six-minute periods averaging not more than 87 percent opacity may occur not more than
once in any hour nor more than four times in any 24-hour period. However, sources which
must comply with 15A NCAC 2D .0524 "New Source Performance Standards" or .1110
"National Emission Standards for Hazardous Air Pollutants" must comply with applicable
visible emissions requirements contained therein.
Permit No. 02765R11
Page 3
7. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the 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:
a. Notify the 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 and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
8. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints or excessive fugitive
dust emissions from the facility are observed beyond the property boundaries for six minutes
in any one hour(using Reference Method 22 in 40 CFR,Appendix A), the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas, process areas stockpiles, stock pile working,plant parking lots,
and plant roads (including access roads and haul roads).
9. CYCLONE REQUIREMENTS - As required by 15A NCAC 2D .0611, particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform an annual (for each 12 month period following the initial inspection)
inspection of the cyclone system. In addition,the Permittee shall perform periodic
inspections and maintenance (I&M) as recommended by the manufacturer.
b. Recordkeeping Requirements - The results of all inspections and any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a cyclone logbook.Records of all maintenance activities shall be recorded in the
logbook. The cyclone logbook(in written or electronic format) shall be kept on-site
and made available to DAQ personnel upon request.
Permit No. 02765RI 1
Page 4
10. MULTI-CYCLONE REQUIREMENTS -As required by 15A NCAC 2D .0611,particulate
matter emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform an annual (for each 12 month period following the initial inspection)
internal inspection of the multi-cyclone system. In addition,the Permittee shall
perform periodic inspections and maintenance (I&M) as recommended by the
manufacturer.
b. Recordkeeping Requirements - The results of all inspections and any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a multi-cyclone logbook. Records of all maintenance activities shall be recorded in
the logbook. The multi-cyclone logbook (in written or electronic format) shall be
kept on-site and made available to DAQ personnel upon request.
11. GENERALLY AVAILABLE CONTROL TECHNOLOGY- For the wood-fired boiler (ID
No. ES-2),the Permittee shall comply with all applicable provisions, including the
notification,testing, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 2D .1111, as promulgated in 40 CFR 63, Subpart JJJJJJ,
"National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial,
Commercial, and Institutional Boilers", including Subpart A "General Provisions."
a. Compliance Requirements -As required by 15A NCAC 2D .1111, the Permittee
shall comply with the following requirements:
i. General Duty Clause (40 CFR 63.11205(a)) -At all times the Permittee shall
operate and maintain any affected source,including associated air pollution
control equipment and monitoring equipment, in a manner consistent with
safety and good air pollution control practices for minimizing emissions.
ii. Boiler Tune-up (40 CFR 63.11223) -The Permittee shall comply with the
following with respect to the tune-up:
A. Periodic tune-ups: A biennial tune-up is required and shall be
conducted no more than 25 months after the previous tune-up. The
following units are only required to conduct a tune-up every five
years: seasonal boilers (shutdown for 7 consecutive months or 210
consecutive days each 12-month period due to seasonal conditions;
only biomass or oil), limited-use boilers, and units with oxygen trim
systems, as defined in 40 CFR 63.11237. Each five-year tune-up must
be conducted within 61 months of the previous tune-up.
B. Fuel required for the tune-up: The permittee shall conduct the tune-up
while burning the type of fuel (or fuels in the case of boilers that
routinely burn two types of fuels at the same time)that provided the
majority of the heat input to the boiler over the 12 months prior to the
tune-up.
Permit No. 02765R11
Page 5
C. As applicable, inspect the burner, and clean or replace any
components of the burner as necessary. The Permittee may delay the
burner inspection until the next scheduled unit shutdown, but must
inspect each burner at least once every 36 months (72 months for 5-
year tune-ups).
D. Inspect the flame pattern, as applicable, and adjust the burner as
necessary to optimize the flame pattern. The adjustment should be
consistent with the manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio, as applicable, and
ensure that it is correctly calibrated and functioning properly. The
Permittee may delay the air to fuel ratio inspection until the next
scheduled unit shutdown, but must conduct the inspection at least
once every 36 months (72 months for 5-year tune-ups).
F. Optimize total emissions of carbon monoxide. This optimization
should be consistent with the manufacturer's specifications, if
available, and with any nitrogen oxide requirement to which the unit
is subject.
G. Measure the concentrations in the effluent stream of carbon monoxide
in parts per million, by volume, and oxygen in volume percent, before
and after the adjustments are made (measurements may be either on a
dry or wet basis, as long as it is the same basis before and after the
adjustments are made). Measurements may be taken with a portable
CO analyzer.
b. Notification and Reporting_Requirements - In addition to the notification and
reporting requirements of the Environmental Protection Agency (EPA),the
Permittee is required to prepare a Compliance Report. This report shall be prepared
by March 1 of every other year (or every five years depending on the frequency of
the tune-up requirements) starting March 1 the year following the first periodic tune-
up, and submitted upon request. If the source experiences any deviations from the
applicable requirements then the report must be submitted by March 15. The report
must meet the requirements of 40 CFR 63.11225(b)(1-4).
c. Recordkeeping Requirements - In addition to any other recordkeeping requirements
of the EPA, the Permittee shall maintain the following records as defined under 40
CFR 63.11225(c):
i. Copies of all required notifications.
ii. Maintain the following records to document conformance with the work
practices, emission reduction measures, and management practices:
A. Tune-up records - records must identify each boiler, the date of tune-
up,the procedures followed for tune-up,the manufacturer's
specifications to which the boiler was tuned, and the following:
Permit No. 02765R11
Page 6
I. The concentrations of CO in the effluent stream in parts per
million, by volume, and oxygen in volume percent,measured
at high fire or typical operating load,before and after the tune-
up of the boiler.
II. A description of any corrective actions taken as a part of the
tune-up of the boiler.
III. The type and amount of fuel used over the 12 months prior to
the tune-up of the boiler but only if the unit was physically
and legally capable of using more than one type of fuel during
that period. Units sharing a fuel meter may estimate the fuel
use by each unit.
B. A copy the Energy Assessment required by 40 CFR 63.11214(c).
C. Seasonal boilers - For each boiler that meets the definition of seasonal
boiler,you must keep records of days of operation per year.
D. Records of non-waste determinations per 40 CFR 63.11225(c)(2)(ii).
iii. Malfunction Records - Records of the occurrence and duration of each
malfunction of the boiler, or of the associated air pollution control and
monitoring equipment. Records of actions taken during periods of
malfunction to minimize emissions in accordance with the general duty to
minimize emissions in 40 CFR 63.11205(a), including corrective actions to
restore the malfunctioning boiler, air pollution control, or monitoring
equipment to its normal or usual manner of operation.
iv. Record Retention- You must keep each record for 5 years following the date
of each recorded action.
12. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required by 15A
NCAC 21) .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
B. GENERAL CONDITIONS AND LIMITATIONS
1. TWO COPIES OF ALL DOCUMENTS REPORTS TEST DATA MONITORING DATA
NOTIFICATIONS,REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION
REQUIRED BY THIS PERMIT shall be submitted to the:
Permit No. 02765RI I
Page 7
Regional Supervisor
North Carolina Division of Air Quality
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,NC 28778
828-296-4500
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - Any records required by the conditions of this
permit shall be kept on site and made available to DAQ personnel for inspection upon
request. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. These records must be kept on site for a minimum of 2
years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION A new air permit shall be obtained by the Permittee prior to
establishing, building, erecting, using, or operating the emission sources or air cleaning
equipment at a site or location not specified in this permit.
5. REPORTING REQUIREMENT -Any of the following that would result in previously
unpermitted, new, or increased emissions must be reported to the Regional Supervisor,
DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. This permit is subject to revocation or modification by the DAQ upon a determination that
information contained in the application or presented in the support thereof is incorrect,
conditions under which this permit was granted have changed, or violations of conditions
contained in this permit have occurred. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit,no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. This permit is nontransferable by the Permittee. Future owners and operators must obtain a
new air permit from the DAQ.
Permit No. 02765R11
Page 8
8. This issuance of this permit in no way absolves the Permittee of liability for any potential
civil penalties which may be assessed for violations of State law which have occurred prior
to the effective date of this permit.
9. This permit does not relieve the Permittee of the responsibility of complying with all
applicable requirements of any Federal, State, or Local water quality or land quality control
authority.
10. Reports on the operation and maintenance of the facility shall be submitted by the Permittee
to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be
required by the DAQ. Information required in such reports may include, but is not limited
to,process weight rates, firing rates,hours of operation,and preventive maintenance
schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct,hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. The Permittee must comply with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act(RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT- The Permittee shall retain a current copy of the
air permit at the site. The Permittee must make available to personnel of the DAQ, upon
request,the current copy of the air permit for the site.
15. CLEAN AIR ACT SECTION 112(r)REQUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY -Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases -Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces, processes, handles, or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
Permit No. 02765R11
Page 9
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance, the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification, report submittal, and test
results approval.
Permit issued this the 1st of August, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Paul K. Muller,P.E.
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 02765RI I
ATTACHMENT to Permit No. 02765RI 1, August 1, 2014
Insignificant/Exempt Activities
Exemption Source of
Source of
Source Title V i
Regulation TAPs? pollutants?
2Q .0102 - Yes
Lumber Kilns No
(c)(2)(E)(i)
- 2Q .0102
[I-ES-4 - De-stick Operation No Yes
.._(c)O(E)(i) i
2Q .0102
I-ES-S - Wood Dip-Tank F No ? Yes
(c)(2)(E)(i)
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 'Emission Rates
Requiring a Permit."