HomeMy WebLinkAboutAQ_F_1900039_20220427_CMPL_InspRpt NORTH CAROLINA DIVISION OF Raleigh Regional Office A17W
AIR QUALITY Southern Veneer Specialty Products,LLC-
Moncure
Inspection Report NC Facility ID 1900039
Date: 04/28/2022 County/FIPS: Chatham/037
Facility Data Permit Data
Southern Veneer Specialty Products,LLC-Moncure Permit 03424/T29
306 Corinth Road Issued 4/20/2020
Moncure,NC 27559 Expires 3/31/2025
Lat: 35d 36.5760m Long: 79d 2.9560m Class/Status Title V
SIC: 2436/Softwood Veneer And Plywood Permit Status Active
NAILS: 321212/Softwood Veneer and Plywood Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Thomas Reams Thomas Reams Thomas Reams MACT Part 63: Subpart ZZZZ
EHS Coordinator EHS Coordinator EHS Coordinator NSPS: Subpart Dc, Subpart IIII
(910)605-9258 (910)605-9258 (910)605-9258
Compliance Data
Comments: Compliance Inspection—Appears to be in compliance. Inspection Date 04/27/2022
Inspector's Name Jeff Harris
/'+ Operating Status Operating
Inspector's Signature: Compliance Status Compliance-inspection
Action Code FCE
Date of Signature:4/28/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 50.62 0.6600 42.61 81.31 22.88 50.39 9721.04
2019 54.88 0.7900 48.98 60.86 19.21 54.63 9429.92
2018 60.22 0.8400 52.25 82.52 34.83 60.00 13256.42
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
04/16/2021 NOV Part 60-NSPS Subpart IIII Stationary Compression 05/11/2021
Ignition Internal Combustion Engines
04/16/2021 NOV Part 63 -NESHAP/MACT Subpart ZZZZ Stationary 05/11/2021
Reciprocating Internal Combustion Engines
07/15/2019 NOV Permit Permit Condition 08/12/2019
07/15/2019 NOV Part 60-NSPS Subpart Dc Small Industrial- 08/12/2019
Commercial-Institutional Steam Generating Units
07/15/2019 NOV 2D .0614 Compliance Assurance Monitoring 08/12/2019
07/15/2019 NOV 2D .I I I I Maximum Achievable Control Technology 08/12/2019
11/20/2018 NOV Permit Late Report(excluding ACC) 12/19/2018
11/20/2018 NOV Part 60-NSPS Subpart IIII Stationary Compression 12/19/2018
Ignition Internal Combustion Engines
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I)DIRECTIONS TO SITE: Southern Veneer Specialty Products,LLC -Moncure(Southern Veneer)is located at
306 Corinth Road(SR-1916) in Moncure,NC, Chatham County. From Raleigh,take US-1 South to Old US-1 (SR-
1011)and turn south(right). Travel approximately 3.5 miles and turn east(left) on Corinth Road(SR-1916). The
plant entrance is on the right,just past the railroad tracks.
(I1)FACILITY DESCRIPTION: Southern Veneer purchased this facility from Boise Cascade in 2019. This
plywood plant manufactures plywood from pine veneer and has previously manufactured plywood from hardwood
(poplar)veneer. The plywood ranges from 3 to 9 plies, and from '1/32-inch to 1 1/4-inch thick. The facility receives
trees, cuts them to length(10 feet), and debarks the wood. The bark is hammer milled,transferred to silos, and used
as wood fuel. The logs are heated in steam vats for about 24 hours to soften. The more the logs are heated,the less
glue is required. The logs are then sent to a spindle lathe. The lathe cuts continuous,thin sheets of veneer from
each log. The 22-inch core of the log is sold as battens (for packaging). Wood chips are further processed for wood
fuel or for sale to other wood products facilities. Veneers are cut into 4 feet x 8 feet pieces and then dried in dryers,
glue is applied,pieces are aligned in the composer and lay-up lines, and then are pressed in the plywood presses.
The plywood is then sawed to specifications and stacked for sale. Wood waste is used as fuel. Most of the plywood
is used to construct upholstered furniture. The facility produces softwood plywood,hardwood plywood, and
composite plywood(both softwood and hardwood). The actual production of the plywood typically occurs six
days/week. The dryers typically operate five days per week, 24 hours per day. There are around 120 employees at
the facility.
Safety Note: Standard safety equipment includes protective footwear& eyewear,hearing protection, and visibility
vest.
(III)INSPECTION SUMMARY: On April 27,2022,I(Jeff Harris)arrived on the site to perform a compliance
inspection. The Facility Contact,Mr. Tom Reams,met me at the main office of the facility. We proceeded to a
conference room where we reviewed the permit conditions and required records. Boiler records are maintained at
the utility building. The records appeared to be well maintained and complete.
After the records review,we proceeded to tour the facility. Most of the equipment was operating at the facility, as
detailed below. Comments about observations made during the inspection are provided below for each of the
emission sources and specific air quality regulations listed in the facility's current air permit. Overall,the facility
appeared to be managed well.
NOTE TO PERMIT WRITERS: Insignificant generator IES-19 was removed for repair in 2021 and was deemed
irreparable. It was replaced in March 2021 with another 250-horsepower diesel fire pump,manufactured in 2010.
(IV)PERMITTED EMISSION SOURCES: On the day of the inspection,the facility was operating under Air
Permit No. 3424T29. This permit became effective on April 20,2020 and expires on March 31, 2025. This permit
includes the following emission sources and control devices:
(a) one multicyclone (ID No. CD-02) installed on a blend chamber controlled fluidized bed wood burner(ID No.
ES-01-A) and boiler ES-01-B);
There was no visible exhaust coming from the wood burner dump stack on the day of the inspection. The wood
burner was operating on the day of the inspection.
[From another report] According to the staff,the boiler dump stack exhausts excess gases (and heat)when not
required by the veneer dryers. The flow diagrams indicate that the heated gases from the burner are directed either
towards the boiler(to produce facility steam)or to the dryers to process the veneer. In another diagram provided by
the facility, it appears that the gases headed to the dump stack and the gases directed towards the dryers are
processed by a multicyclone. Some of the gases from the boiler and the dryers are recirculated back to the wood
burner. The balance of the gases is emitted from the six stacks(3 for each dryer)or escape as fugitive emissions.
The boiler has a maximum rating of 150 psi and a maximum rated heat capacity of 29.79 mmBtu/hr.
(b) two direct wood-fired veneer dryers (ID Nos. ES-09 and ES-10);
ES09 is referred to as 62 little and is 12 feet wide. ES10 is referred to as 72 and is 16 ft wide. Both the dryers were
operating on the day of the inspection. These two dryers directly utilize the exhaust gases from the fluidized bed
wood burner. The visible emissions of the plume from this dryer was around 10%opacity.
(c) one cyclone(CD-03-WWTC) and one bagfilter(ID No. CD06) installed on:
• two string machines including saws (ID Nos. ES03-SMS-1,2);
• one core saw(green or dry veneer) (ID No. ES03-CS);
• one strip saw(ID No. ES03-SS);
• one core composer saw(ID No. ES03-CC);
• one panel sawing system (ID No. ES03-PSS);
• one plywood hog(ID No. ES16); and
• green wood sizing operations (ID No. ES17);
• tongue and groove saw(plywood finishing)(ID No. ES22)
The core saw and the panel sawing system were not operating during the onsite tour. The core composer with saw
was not operating. All other sources were not operating during the onsite tour. The bagfilter(CD06)was operating
at the time of the physical tour and no visible emissions were evident. The magnehelic gauge reading was 0.5 inches
of water; Mr. Reams indicated that a good operating range is from 0-3 inches of water. Of note,the strip saw is
referred to as the wedge saw and the plywood waste hog is referred to as the dry hog.
(d) one cyclone(ID No. CD18) installed on rechip blow hog(ES14) along with one woodwaste transfer cyclone
(CD-03-WWTC)/one bagfilter(ID No. CD06);
This equipment was operating at the time of the inspection with no visible emissions evident.
(e) one bagfilter(ID No. CD05) installed on a wood sander(ID No. ES04) along with one woodwaste transfer
cyclone (CD-03-WWTC)/one bagfilter(ID No. CD06);
This equipment was not operating at the time of the inspection since the facility is not currently making plywood
from hardwood(poplar)veneer.
69 one cartridge filter(ID No. CD21) installed on a dry wood residual storage silo (ID No. ES12);
The silo has been repaired from an earlier fire. Presently the silo appears to be in adequate condition.
(g) one vat operation (ID No. ES20);
There were vats in operation during the physical tour. Two are collocated in one structure. The other five vats are
adjacent to each other forming another structure. The five vats are smaller, and the facility is considering removing
them to install larger vats.
(h) one end sealer spray booth (ID No. ES21);
The equipment was not-in-service, and has been reported as taken out of service in 2015-2016.
(i) one glue mixing operation (ID No.ES-13-GM0);
The equipment appeared to be sound and well maintained. The equipment was operating during the tour.
0) one curtain coater(ID No.ES-13-CC);
The equipment along with ES-13-40HP, 40 panel hot press, is referred to as `layup' and appeared to be sound and
well maintained. The equipment was operating during the tour.
(k) one paper overlay operations (ID No.ES-13-PO);
The equipment was not operating during the tour, and has not been used in several years.
(l) one plywood spreader(ID No.ES-13-PS);
The equipment has been removed from the facility.
(m) one 25 panel hot press (ID No.ES-13-25HP); and
This equipment was not-in-service.
(n) one 40 panel hot press (ID No.ES-13-40HP);
The equipment along with ES-13-CC, Curtain coater,is referred to as `layup' and appeared to be sound and well
maintained. The equipment was operating during the tour.
(V)APPLICABLE AIR QUALITY REGULATIONS: As is the case with all Title V permits,Air Permit No.
03424T29 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid
redundancy in this report,the applicable air quality regulations are discussed individually, and all of the permitted
emission sources that are subject to a specific regulation are noted.
(1) 15A NCAC 2D.0512:PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING PLANTS
—The following emission sources are subject to 2D.0512:All woodworking operations and Edge Sealing Spray
Booth (ID Nos. ES-03-SMS-1,2, ES-03-CS, ES-03-SS, ES-03-CC, ES-03-PSS, ES 04, ES-12, ES-14, ES-16, ES-17,
ES-21, &ES22).
Appears to be in compliance-In accordance with 15A NCAC 2D .0512,the permittee shall not cause,allow,or
permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack,
vent, or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and
properly designed collectors. All duct work and control devices installed on woodworking equipment were
observed during the inspection in good physical condition.
No particulate emission testing is required for any of these sources by the facility's air permit. The permit requires
the facility to conduct monthly and annual inspections of the cyclones and bagfilters installed on the wood working
equipment,record the results of any inspection and maintenance activities in a logbook, and submit a semiannual
deviation report to DAQ. Also,the permit requires that weekly visible emission monitoring be performed on the
other wood-finishing units. Upon request,the facility provided records of the weekly,monthly and annual
inspection activities. Additionally,the facility has submitted the required semiannual reports on time summarizing
the facility's monitoring and record keeping activities.
(2) 15A NCAC 2D.0515:PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- The
following emission sources are subject to 2D.0515: The fluidized bed wood burner(ID No. ES-01-A), the
associated boiler(ID No. ES-01-B), and two associated direct wood-fired veneer dryers (ID Nos. ES-09, ES-
10).
Appears to be in compliance-The particulate emission limit for the wood burner and associated veneer dryers
is determined by the processed material in the system including the wood fuel and the dried veneer. To
demonstrate compliance with this requirement, air permit T24 required a performance test(for particulate
matter),which was performed in 2016. The Stationary Source Compliance Branch(SSCB)indicated that the
test results(12.1 lb./hr.)met the particulate limit(17 lb./hr.).
The most recent annual internal inspection of CD02 was conducted on December 30,2021.
(3) 15A NCAC 2D.0516:SULFUR DIOXIDE EMISSIONS FROM COMB USTION SOURCES- The following
emission sources are subject to 2D.0516: The fluidized bed wood burner(ID No. ES-01-A).
Appears to be in compliance -The sulfur dioxide emission limit for each of these sources is 2.3 pounds per million
Btu heat input. Since the facility burns exclusively wood waste and diesel fuel in its combustion equipment,the
15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during normal operating conditions.
Sulfur dioxide emissions testing/monitoring/record keeping/reporting is not required for these sources by the
facility's air permit.
(4) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are subject
to 2D.0521.
Appears to be in compliance-The visible emission limit for all plant emission sources is 20%opacity. During the
inspection,visible emissions related to the dryer operation were observed as— 10%opacity.
The permit requires the facility to perform periodic visible emissions observations on the boiler and woodworking
operations,record the results of the observations in a logbook, and submit a summary report of the observations on
a semiannual basis. Upon request,the facility provided records of the required visible emission observations.
Additionally,the facility has submitted the required semiannual reports on time summarizing the facility's
monitoring and record keeping activities.
(5) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart Dc) - The following
emission source is subject to NSPS Subpart Dc:Boiler(ID No. ES 01-B).
Appears to be in compliance -To comply with the requirements of 40 CFR 60, Subpart Dc -Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units,the facility must record and
maintain records of the amount of wood fuel burned during each month. Mr. Reams provided records of monthly
wood fuel combusted in ESO1-B.
(6) 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING- The following emission sources are
subject to 2D.0614: The fluidized bed wood burner(ID No. ES-01-A). and woodworking operations (ID Nos. ES-
03-SMS-1,2, ES-03-CS, ES-03-SS, ES-03-CC, ES-03-PSS, ES-04, ES-12, ES-14, ES-16, ES-17, &ES-22).
Appears to be in compliance -To comply with 15A NCAC 2D .0614,the permittee is required to record the
differential pressure across the multicyclone(CD02)to ensure that the pressure drops fall between 4"and 13".
This pressure requirement was added in the T25 version of the facility air permit. The facility is monitoring the
pressure drops across the multicyclone as required and differential pressure records were available for review. The
facility is required to provide a summary of excursions in their semi-annual reports. The 2'half 2021 semiannual
report was received on January 18,2022 and reviewed as complete.
For the woodworking operation,a Method 22 type observation is required to be performed daily on each bagfilter
outlet. The records I reviewed during the inspection appeared to indicate compliance with this daily opacity
observation requirement.
(7) I5A NCAC 2D.1100 and 2Q.0711: TOXIC AIR POLLUTANT REQUIREMENTS-All of the permitted
emission sources are subject to 2D.1100 and 2Q.0711.
Appears to be in compliance -Through the results of past air modeling,the emission rates of air pollutants were
established. From a review of the 2020 Emission Inventory, it appears that the emission rates for the pollutants of
concern were below the listed thresholds in the air permit.
(8) 15A NCAC 2Q Q.0317:LIMITATION TO AVOID BEING A MAJOR FOR HAZARDO US AIR POLL UTANTS-All
of the permitted emission sources are subject to 2Q.0317.
Appears to be in compliance -To avoid being a major source for hazardous air pollutants(HAPs)under 40 CFR
Part 63,the facility must limit facility-wide emissions to 10 tons per year of any listed HAP and 25 tons per year for
all HAPs combined.
[From a previous report] The former owner of this facility(Boise Cascade)performed an internal audit in April,
2014. During the audit, it was discovered that the hardwood emission factor that was being used for methanol
emissions from the presses was potentially lower than it should be. The methanol emission factor that was being
used had been taken from EPA AP-42 and was based on hardwood plywood being processed with a urea
formaldehyde-based adhesive. In contrast,this facility processes its hardwood plywood with a phenol
formaldehyde-based adhesive which potentially might emit higher methanol emissions. The stack test performed on
December 10, 2014 indicated that the methanol emission factor for their hardwood plywood should be 0.116
lb./MM sq. ft. instead of the AP-42 factor(0.032 lb./MM sq. ft.). This same stack test indicated that the methanol
emission factor for their softwood plywood should be 0.106 lb./MM sq. ft. instead of the AP-42 factor(0.14 lb./MM
sq. ft.). The impact of changing these emission factors increased the facility-wide 12-month rolling methanol
emissions.
The 12-month rolling totals of methanol for CY 2021-2022 ranged from 5.3 to 5.5 tons over the last year. The
facility must maintain monthly HAP emissions records and Mr. Reams provided these records for review.
(9) 15A NCAC 2D.18 0 6: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the permitted
emission sources are subject to 2D.1806.
Appears to be in compliance—To comply with 15A NCAC 2D .1806,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. No objectionable odors were detected during the compliance inspection. No odorous emissions
testing/monitoring/record keeping/reporting is required by the facility's air permit. There are no odor complaints
recorded in the Complaint Module(IBEAM).
(VI) OTHER REGULATORY REQUIREMENTS:
(1) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart IIII) - The
following emission sources are subject to NSPS Subpart IIII: The 250 horsepower(maximum)diesel fire pump
(IES-23).
Appears to be in compliance—To meet the requirements of this regulation,the generator engine must meet a
particulate matter,carbon monoxide,and a combined NMHC+NOx limit. Also,the facility has to maintain the
engine according to the manufacturer's recommendation. This is the primary backup pump,which automatically
turns on when the water pressure drops below a set point through the facility(100 psi). According to their staff,
there are incidences where the pumps are needed for fire-related issues. The hour meter on the generator indicated
44(+1148)hours on the day of the inspection and 1112.3 hours during the previous (February 2021)inspection.
[From another report] The facility received an NOD dated May 31,2018 at a time when the fire pump engine was
classified for emergency use. This NOD was for exceeding the 50-hour limit for non-emergency use for IES-23
according to the Subpart IIII requirements of the prior permit version T27. Since then,the facility has installed an
electric jockey pump engine to supply process water as a backup pump. The facility modified their permit(T28)to
reclassify IES-23 as a non-emergency engine. With permit T29,IES-23 was reclassified as an emergency fire pump
engine.
During this inspection,the facility provided records of maintenance which showed that the most recent engine
maintenance was conducted on April 25, 2022. The facility conducted regularly scheduled maintenance on a 6-
month,yearly and two-year maintenance schedule.
(2) 15A NCAC 2D.I I11:MAXIMUM A CHIE VABLE CONTROL TECHNOLOGY(40 CFR 63, Subpart ZZZZ) -
The following emission sources are subject to 2D.1111: The 190-horsepower diesel fire pump (IES-23) and the
250 horsepower diesel fire pump (IES-19).
Appears to be in compliance—Since IES-23 was manufactured after 2006, satisfying the requirements of 40
CFR 60, Subpart IIII, satisfies the requirement of this regulation. See the NSPS IIII discussion above.
IES-19 was removed for repair in 2021 and was deemed irreparable. It was replaced in March 2021 with
another 250-horsepower diesel fire pump,manufactured in 2010. During this inspection,the hour meter on the
new 250-horsepower diesel fire pump showed 14.5 hours. Its most recent engine maintenance was conducted on
April 25,2022. Records indicate that the generator is complying with the maintenance requirements of this
regulation. According to the hourly records(as noted above)the non-emergency usage appears to within the
allowable limit.
(VII)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the
Insignificant Activities List attached to the current air permit. Some of these sources were observed during the
inspection. No concerns were noted with regard to their operation or permit exemption status. The two plywood
spreaders (IES-I3-PS1/2)have never operated. IES-GEN1 is used for the server. As mentioned above, ES-19 was
removed for repair in 2021 and was deemed irreparable. It was replaced in March 2021 with another 250-
horsepower diesel fire pump,manufactured in 2010.
(VIII)ENFORCEMENT HISTORY: Southern Veneer has been issued the following notices according to DAQ
records: The facility received an NOV dated July 15,2019 for not maintaining 3.13,NSPS Subpart Dc
recordkeeping, CAM monitoring and recordkeeping, and major source HAP Avoidance monitoring. The former
Moncure Plywood has been issued two Notices of Violation/Notice of Recommendation for Enforcement
(NOV/NRE), five Notices of Violation(NOVs), and two Notices of Deficiency(NOD)according to DAQ records.
In 2018,the facility had submitted a modified permit application to NCDAQ to reclassify IES-23 as a non-
emergency engine under NSPS IIII. Prior to submitting this application,the facility exceeded the 50-hour limit and
the 100-hour limit(sum of non-emergency,readiness testing and maintenance use) in 2018. A NOV was issued to
the facility on November 20, 2018 for the 2018 exceedances. On May 31,2018,the facility was issued an NOD per
the requirements of NSPS IIII for exceeding the 50-hour limit for non-emergency use for IES-23. On August 10,
2015, a NOV was issued to the facility for not performing a stack test within the required time frame. On June 5,
2014, a NOD was issued to the facility for not maintaining records for the required five years. On February 8,2011,
an NOV was issued due to a late stack test report. On February 26,2010,a NOV/NRE was issued for missed
visible emissions observations and inspections. The company was assessed$4666 in civil penalties for these
violations. On November 1,2007,the company was issued a NOV for not maintaining a cyclone unit effectively so
to prevent excess particulate emissions. Also,this same NOV noted that records tracking the BTU heat input to the
steam generating unit were not complete. On June 7, 2007,the company was issued an NOV/NRE for various Title
V monitoring and record keeping violations. The company was assessed$2913 in civil penalties for these
violations. Prior to that,the company was issued an NOV on June 14,2006 for previous Title V monitoring and
record keeping violations. No civil penalties were assessed against the company in this case.
(IX) STACK TEST REVIEW: As indicated above in Section V. (2),Air Permit 03424/T24 requires that a
particulate test be performed on the fluidized bed wood burner(ESO1-A) and the associated dryers(ES09,
ES 10)within 180 days from the permit issuance date. This permit being issued on January 21, 2015 would
require that the test results be submitted by July 20,2015. The required performance test was finally completed
on June 30,2016 with the test results submitted on July 29,2016. The results were reviewed by SSCB with the
conclusion that compliance to the particulate standard was indicated. A performance test to determine more
accurate methanol emission factors for the presses was performed on December 10,2014. Another
performance test was performed on November 20,2012. The purpose of the testing was to demonstrate
compliance with 40 CFR 63 Subpart JJJJJJ(6J)by measuring the effectiveness of a tune up by monitoring
carbon monoxide(CO)concentrations. The test results were accepted by SSCB.
(X) 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.
Appears to be in compliance—Southern Veneer Specialty Products is subject to the 112(r)program general duty
clause,but does not maintain regulated chemicals onsite above the threshold quantities,which would require a risk
management plan.
(XI)EMISSION INVENTORY REVIEW: The following review was provided by the 2020 Emission Inventory
DAQ internal comments in IBEAM: CO,VOC, acetaldehyde, acrolein,Benzene, Cumene, ethyl chloride, ethylene
dichloride,formaldehyde,methyl bromide,methylene chloride,vinyl chloride,vinylidene chloride,and xylene
emission increases are due to a 46% increase in throughput for OS26,veneer dryers and wood burner(softwood).
S02,NOx,Arsenic compounds, Cadmium compounds, Carbon tetrachloride, Chlorine, Chromic acid, Chromium
compounds, Cobalt compounds,Hydrogen chloride,Manganese compounds,Mercury compounds,Methyl chloride,
Naphthalene,Nickel metal,Phosphorus metal and Polycyclic Organic Matter emission decreases dur to a 7 1%
decrease in throughput for OS31,Veneer dryers and heat source(wood burner)HAPS lb/mmBtu, (Hardwood).
Emission decrease of phenol is due to decrease in throughput for OS 10. Emission decrease of propionaldehyde is
due to a decrease in throughput of OS30. Several pollutants had emission changes greater than 10%but the lbs/yr
was less than the de minimus.
(XII) CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the April 27, 2022
inspection Southern Veneer Specialty Products appeared to be in compliance with the requirements of their Title V
permit. It is recommended that the facility be re-inspected in one year.